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LEGG MASON FUNDS ICVCASSESSMENT OF VALUE REPORT

29th FEBRUARY 2020

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CONTENTS

MESSAGE FROM THE CHAIR

OUR APPROACH

ABOUT LEGG MASON

ICVC INVESTMENT MANAGERS

INTRODUCING THE BOARD

HOW WE MEASURE VALUE

ASSESSMENT OF VALUE

FUND REPORTS

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MESSAGEFROM THE CHAIR Dear Investor

We are pleased to present to you, on behalf of Legg Mason Investment Funds Limited (LMIF), our first annual assessment of value delivered report for Legg Mason Funds ICVC*.

In this report, we aim to help our investors better understand and assess how their money is invested and the value the ICVC and its individual sub-funds offer.

As we strive to assist our clients to achieve financial outcomes, we recognise that investors have diverse goals, whether that is long-term wealth accumulation, or providing steady income for retirement. Whatever the investment objective, we believe acting in their best interests is central to our responsibilities as an asset manager. That is why we work to deliver good value in all that we do – in the services we deliver, the fees we charge and the performance of our funds. It is a central part of Legg Mason’s corporate mission of ‘Investing to Improve LivesTM’.

Following approval by shareholders in May 2020, Legg Mason is to be acquired by Franklin Templeton. The transaction creates one of the world’s largest independent, specialised global investment managers, with a combined US$1.5 trillion in assets under management (AUM). We are confident this will build on our efforts to deliver value for investors.

This commitment to delivering value aligns completely with new rules from the Financial Conduct Authority (FCA). These are designed to improve the quality and transparency of information available to investors about the funds they own, in order to assist them as they make important financial decisions in relation to their savings.

To comply with these rules, LMIF is required to publish an annual assessment on how it has provided value to its investors.

Following a detailed evaluation, using information compiled from internal and external sources, the LMIF Board has assessed funds in the ICVC against the seven FCA-prescribed criteria:

• Quality of Service – the range and depth of services.

• Performance† – whether fund performance (after charges) has met investors’ reasonable expectations.

• Authorised Fund Manager (AFM) Costs & Charges – whether charges are reasonable and reflect the costs of providing services to investors.

• Economies of Scale – whether investors are benefiting from economies of scale by being invested in the fund.

• Comparable Market Rates – whether charges are reasonable in relation to what investors could pay elsewhere.

• Comparable Services – whether charges are broadly similar to different funds offered in the same product range.

• Classes of Units – whether investors are in the appropriate share class for their circumstances.

We are pleased to confirm that, in the Board’s view, the funds have delivered overall value. In this report, we provide a summary of the findings for each of the seven criteria, as well as a breakdown for each individual fund. We also include details of improvements which have already been made and recommendations for ways to further develop how we provide value in future years.

Yours faithfully

Victoria RockChairLegg Mason Investment Funds Limited

Past performance is not a guide to the future. The value of an investment and any income from it can go down as well as up. Investors may not get back the original amount invested. *Legg Mason Funds ICVC is an umbrella fund comprising individual ‘sub-funds’. For the purposes of clarity in this report, we refer to the overall fund as ‘the ICVC’, while an individual sub-fund is simply ‘the fund’.†This report has considered performance and other measures up to the funds’ year end 29th February 2020. Up-to-date performance of all funds can be found on the Legg Mason website.

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OUR APPROACH For this report we have assessed funds in the ICVC against the FCA’s seven criteria, to judge whether investors have received value for money:

• Quality of Service

• Performance

• AFM Costs & Charges

• Economies of Scale

• Comparable Market Rates

• Comparable Services

• Classes of Units

The assessment was carried out in two stages:

1) Information collection. We have collated data from internal and external sources. Data and information on performance and fees used in this report is from sources including Legg Mason and its affiliates, as well as independent research providers Morningstar and the Fitz UK charges database.

2) Analysis. The Board assessed individual funds against each of the seven criteria, with input and scrutiny from all of the ICVC’s directors, including the independent non-executive directors, as per the FCA’s requirements.

In our assessment, we have strived to achieve the following:

• A consistent and transparent methodology

• A report written in plain English

• Equal weighting for each criteria

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Funds considered in this report

Fixed Income Funds

• Legg Mason IF Brandywine Global Income Optimiser Fund

• Legg Mason IF Western Asset Retirement Income Bond Fund (previously Legg Mason IF Western Asset Global Blue Chip Bond Fund)

• Legg Mason IF Western Asset Global Multi Strategy Bond Fund

Equity Funds

• Legg Mason IF ClearBridge Global Equity Income Fund

• Legg Mason IF ClearBridge US Equity Fund

• Legg Mason IF ClearBridge US Equity Income Fund

• Legg Mason IF Japan Equity Fund

• Legg Mason IF Martin Currie Asia Pacific Fund

• Legg Mason IF Martin Currie Asia Unconstrained Fund

• Legg Mason IF Martin Currie China Fund (went into liquidation on 14th January 2020)

• Legg Mason IF Martin Currie Emerging Markets Fund

• Legg Mason IF Martin Currie European Unconstrained Fund (previously Legg Mason IF Martin Currie European Equity Income Fund)

• Legg Mason IF Martin Currie Global Equity Income Fund

• Legg Mason IF Martin Currie US Unconstrained Fund (previously Legg Mason IF Martin Currie North America Fund)

• Legg Mason IF QS UK Equity Fund

• Legg Mason IF Royce US Smaller Companies Fund

• Legg Mason IF RARE Global Infrastructure Income Fund

ABOUTLEGG MASONLegg Mason has a global portfolio of independent investment managers devoted to supporting clients’ long-term goals.

Founded in 1899, Legg Mason is headquartered in Baltimore, Maryland, USA, with AUM of US$780 billion (as at 31st May 2020). Clients can access diverse investment solutions, including equities and fixed income, built around our successful affiliate model:

Specialised expertise: Legg Mason brings together a family of nine well-established affiliate investment managers, offering a range of investment solutions, products and vehicles.

Independent thinking: Our investment managers are among the industry leaders in their respective specialist areas and use their unique investment approaches to identify the best opportunities.

Global coverage and presence: A broad spectrum of equity, fixed-income, liquidity and alternative solutions to suit a wide range of investment needs. We serve clients through 39 offices on six continents.

Active: We focus on long-term, actively managed strategies that aim to create sustainable value and a balance between risk and return.

Legg Mason Funds ICVC

The ICVC is an umbrella fund made up of various sub-funds. Operated either by Legg Mason affiliates or third-party managers, each one is a distinct fund with its own portfolio ofinvestments. Every individual fund has its own specific investment objective, with a purpose to optimise income and/or capital growth for investors. More information is availablein the ICVC’s prospectus and key investor information documents.

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Global value investing

Acting with conviction and discipline, Brandywine Global looks beyond short-term, conventional thinking to rigorously pursue long-term value across differentiated fixed income, equity and alternative solutions.

Global listed infrastructure investing

RARE is a specialised investment manager focused exclusively on global listed infrastructure. Established in 2006, RARE offers expertise across the infrastructure spectrum and aims to identify and invest in high-quality listed infrastructure assets with the goal of delivering strong absolute returns over an investment cycle.

Quality-focused equity

With a legacy dating back over 50 years, ClearBridge Investments is a leading global equity manager committed to delivering differentiated long-term results through authentic active management.

Small-cap equityRoyce Investment Partners specialises in small-cap investing, managing both US and international portfolios for individual investors, financial advisers and institutions. The firm is generally regarded as a pioneer in small-cap investing and has focused on this distinctive asset class for more than 40 years, leading to unparalleled domain knowledge of the smaller company investment universe.

Active equity specialists

Martin Currie builds global, stock-driven portfolios based on fundamental research, devoting all of its resources to delivering optimum investment outcomes and superior client relationships.

Global value fixed income One of the world’s leading global fixed income managers. Founded in 1971, the firm is known for team management and proprietary research, supported by robust risk management and a long-term fundamental value approach.

Systematic investment solutions

QS Investors is a quantitative asset manager that provides multi-asset class and global equity solutions. Its approach unites intellectual and academic precision with the power of data and technology in its quest to elevate the certainty of outcomes it delivers.

Japan equity specialists

Shiozumi Asset Management was founded in Japan in 2001 to provide highly specialised expertise in Japanese investment portfolio management. Based in Tokyo, Shiozumi is a bottom-up, growth orientated stock-picking manager that currently has a thematic bias driven by the Japanese economic position.

ICVC INVESTMENT MANAGERS

All the funds in the ICVC are operated on behalf of Legg Mason by our independent affiliates or by third-party investment specialists. Having honed their expertise over many decades and market cycles, these asset managers offer specialised capabilities across a range of asset classes and strategies.

Shiozumi Asset Management is a third-party investment specialist, not a Legg Mason affiliate.

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Fionnuala Doris Fionnuala is a lecturer in the Department of Economics, Finance and Accounting in Maynooth University, Ireland. Prior to joining Maynooth University, Fionnuala was Financial Controller and Company Secretary of Temple Bar Properties Ltd,

Dublin from 1999 to 2001. She trained with Price Waterhouse Coopers, Dublin from 1993 to 1996 and worked as an Audit Manager in its Asset Management group until 1999, where she specialised in the audit of UCITS funds. Fionnuala holds a BA in Economics from University College Dublin (1992), a Postgraduate Diploma in Accounting from Dublin City University (1993) and is a Fellow of the Institute of Chartered Accountants in Ireland.

Independent Non-Executive Directors

Joseph Keane Joseph has 30 years’ experience in investment funds’ management and administration, banking, and public accounting. He provides consultancy services to the mutual and hedge fund industry and acts as an independent

director to fund companies. Joseph was Chief Financial Officer of the Vega Hedge Fund Group from March 2004 to April 2007. In 2002, he founded CFO. IE and was its Chief Executive Officer until February 2004. Joseph was Head of Operations for SEI Investments, Global Fund Services from 2000 to 2002, and prior to that, Managing Director of ABN AMRO Trust Company (Cayman) in the Cayman Islands from 1995 to 2000. He is a Fellow of the Institute of Chartered Accountants in Ireland.

Christopher Kings Chris is currently responsible for the oversight and governance of all outsourced fund administration service providers for Legg Mason’s UK & Irish fund ranges. This includes transfer agency, fund accounting and custody. He

has over 15 years’ experience working with fund administration firms, including a detailed knowledge of clients and the onboarding process of UK & Irish funds. In this time, he has worked alongside compliance, risk and legal functions, in support of both UK & Irish Fund Boards, in overseeing the regulatory activities outsourced to third parties.

Jaspal Sagger As Head of Global Product Strategy and Development for Legg Mason Global Asset Management, Jaspal is responsible for product-related activities globally. He joined Legg Mason in February 2014, as Head of International Product Strategy,

and assumed the role of Head of International Product in January 2016. Previously, he was Head of Product, EMEA and Head of Product Strategy at HSBC Global Asset Management and was a member of the HSBC Asset Management’s European Executive Committee. Jaspal has a BA (Hons) in Business Studies and a Masters in International Banking and Finance from London Metropolitan University.

Victoria Rock (chair) Victoria is Head of Alternative Product for Legg Mason and chair of LMIF. She is responsible for Legg Mason’s alternative products and strategies including the US closed-end funds. Victoria spent more than 20 years at Citigroup, acting as

Managing Director and leading the Global Alternative Product Group, a platform of $40 billion in assets. Also prior to joining Legg Mason, she consulted to Coutts and Co, UK Private Bank (2012-2014) in respect of the set-up of a new product unit. She has a degree in History from Manchester College, Oxford.

Irene Brodie

Irene is responsible for European Marketing Strategy at Legg Mason. She has more than 30 years’ experience in financial services, 20 of which have been in asset management, including Martin Currie Investment Management

and Standard Life Investments. Irene has a breadth of experience across distribution disciplines spanning: fund sales; product development; client relationship management for strategic accounts; distribution strategy across global, wholesale and institutional channels; marketing strategy, and planning and execution. Irene also has change-management experience, having been involved in many projects, including business transformation within the context of mergers and acquisitions. She has a degree in Risk Management from Glasgow Caledonian University.

Justin EedeJustin joined Legg Mason in June 2001 and is Head of European and Americas International Distribution. He started his career in asset management with GT Global. Following the acquisition of GT by Invesco in 1998, he became a

Director of Business Development with responsibility for London and assumed this role at Invesco Perpetual until he joined Legg Mason. He graduated in French and Business Studies from the University of Southampton in 1996.

INTRODUCING THE BOARD

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The FCA has introduced seven criteria for all AFMs which must be included in the annual assessment of value reports. We have given equal weighting to each of the seven criteria:

HOW WE MEASURE VALUE

FCA Criteria Areas of focus

Quality of Service Determines the range, nature and quality of services provided to clients.

PerformanceMeasures the funds’ returns (after deduction of fees and costs) over relevant periods against suitable benchmarks. Assesses whether each fund performed within a range of reasonable outcomes.

AFM Costs & Charges* Examines the costs of the services provided to the funds.

Economies of Scale Assesses if LMIF has achieved savings from economies of scale and whether these are passed on to the investors.

Comparable Market Rates Reviews the funds’ charges compared with funds offered by competitors.

Comparable ServicesLooks at the funds’ charges compared with other products (including pooled investments vehicles, institutional mandates) managed by the investment managers, with similar investment objectives and policies.

Classes of Units Considers whether investors are placed in the most appropriate share class, or if there are others which could be available to them at a lower cost.

*See page 14 for more detail on breakdown of costs and charges

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ASSESSMENT OF VALUE We have reviewed the funds in the ICVC against each of the seven FCA criteria, before making an assessment on whether each fund has delivered value in each specific area and on an overall basis.

In this report, we have used a traffic-light system to show whether funds have delivered value and where recommendations have been made to improve how value is delivered in the future. In the sections below we cover the areas of focus and any specific actions taken.

16/17 Funds All but one of the funds were rated GREEN overall. All funds were judged to have delivered value to investors.

12/17 Funds Rated GREEN for every criteria*

4/17 Funds Rated AMBER for Performance

1/17 Funds Rated AMBER for AFM Costs & Charges

2/17 Funds Rated AMBER for Comparable Market Rates

Delivered value to the investor

Delivered value to the investor(with recommended actions)

Did not deliver value

Overall conclusions

*Legg Mason IF Martin Currie Asia Unconstrained Fund was not rated for Performance as it has only been recently launched, but has been rated Green for all other categories.

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SUMMARY OF VALUE ASSESSMENTS

Quality of Service

AFM Costs & Charges

Comparable Market Rates

Classes of Units

PerformanceEconomies

of ScaleComparable

ServicesOverall

Legg Mason IF BW Global Income Optimiser Fund

Legg Mason IF WA Retirement Income Fund

Legg Mason IF WA Global Multi Strategy Fund

Legg Mason IF CB Global Equity Income Fund

Legg Mason IF CB US Equity Fund

Legg Mason IF CB US Equity Income Fund

Legg Mason IF Japan Equity Fund

Legg Mason IF MC Asia Pacific Fund

Legg Mason IF MC Asia Unconstrained Fund Recently Launched

Legg Mason IF MC China Fund

Legg Mason IF MC Emerging Markets Fund

Legg Mason IF MC European Unconstrained Fund

Legg Mason IF MC Global Equity Income Fund

Legg Mason IF MC US Unconstrained Fund

Legg Mason IF QS UK Equity Fund

Legg Mason IF Royce US Smaller Companies Fund

Legg Mason IF RARE Global Infrastructure Income Fund

Delivered value to the investor

Delivered value to the investor(with recommended actions)

Did not deliver valueHere is a fund-by-fund breakdown of the value assessments against the seven FCA criteria. For more details see the individual fund reports starting on page 19.

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RECOMMENDATIONS AND IMPROVEMENTSThroughout the process, we have highlighted where improvements have already been made which we believe will deliver better value to investors. We have also made recommendations on where further improvements can be made in the future. A summary of the key points is below:

AFM Costs & Charges(See page 14)

Improvement. A review of charges (independent to the assessment of value process and before work on this report began) resulted in introducing a more transparent charging mechanism to replace the general administration charge (GAC) arrangements. The Board believes this change may make it easier for certain cost savings to be passed onto investors.

Improvement. Also independently of the assessment work covered in this report, the ICVC’s depositary has been changed to The Bank of New York Mellon (International) Limited, which the Board believes should also result in a cost saving for investors. This improvement was also initiated before the assessment of value work started.

Comparable Market Rates(See page 16)

Recommendation. In the case of Legg Mason IF QS UK Equity Fund, the Board has recommended reviewing whether fees should be lowered to more appropriately reflect the fund’s unique quantitative approach to investing. This is in conjunction with the fund’s regular oversight process.

Classes of Units(See page 18)

Recommendation. For the majority of the funds, the Board has recommended reviewing whether to close the Class A shares (for retail investors) and move those investors, where appropriate, to Class X (a ‘clean’ share class, where no rebates or commissions are paid out).

Performance(See page 13)

Recommendation. In the case of the Legg Mason IF QS UK Equity Fund, the Board has recommended reviewing the fund’s investment objective and policy, in order to provide more clarity for investors.

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QUALITY OF SERVICEDetermines the range, nature and quality of services provided to clients.

Areas of focus

There are several interlinked parts to the services offered by the ICVC and its funds, that constitute whether investors are getting value for money. For each fund in our assessment, we focused on:

• Integrity of the investment process

• Research provision

• Analysis of environmental, social and governance (ESG) factors

• Experience and expertise of portfolio managers

• Strength of risk systems

• Quality of oversight and governance

• Marketing materials

• External feedback

Communication is a vital part of the services investors receive. To represent value for money, all marketing material and other communications need to be accurate, timely and appropriate, in order for investors to make informed decisions. For all funds, the marketing focus is on optimising the customer experience by supplying product information, investment ‘thought-leadership’ material, as well as product data, fund commentaries, product presentations and website content.

Marketing materials include a product report to accompany bi-annual statements, with fund performance and commentary from the portfolio manager.

Criteria rating

The range, nature, extent and quality of the services provided to investors is of a good quality. Investors also receive clear communications and relevant information at appropriate times.

Individual bars relate to the colour rating for each of the 17 funds, in the order they appear in this report.

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PERFORMANCEMeasures the funds’ returns (after deduction of fees and costs) over relevant periods against suitable benchmarks.Assesses whether each fund performed within a range of reasonable outcomes.

Areas of focus

For each fund, we assessed the performance of each share class (after deductions of payments) over a range of appropriate timescales.

The 17 funds include equity and fixed-income portfolios. Within these are a range of objectives, investment time horizons and risk/reward profiles. We assessed the return of each fund over 1-year, 3-year, 5-year and, where relevant, 10-year, periods. For funds with an investment objective to provide income, we also assessed the yield (the income generated for the investor) over the same period. Performance was judged against relevant benchmarks and peer groups of funds which were of a similar size and/or objective.

We assessed whether each fund had met its investment objective and whether it had outperformed (or underperformed) its benchmark and peer group. The analysis included various other factors. For instance, we considered whether fund performance had been impacted by the preference during recent market cycles for particular styles over others – a notable example being periods when markets favoured ‘growth’ stocks (that is companies whose revenues and earnings are expected to grow at a faster rate than the market average) over ‘value’ (companies that appear to be trading for less than the value of their assets). We also took into account market preferences for specific sectors or regions. We also considered where funds had seen a change in investment objective and policy during the various time periods or had only recently been launched.

For more detail on recent fund performance visit the Legg Mason UK website.

Action taken

Four funds, while delivering against their investment objectives, underperformed their benchmark and IA sectors. However, the Board was confident in the return potential of these funds in a more favourable environment for their strategies.

The Board will continue to monitor these funds on an ongoing basis, as part of each fund’s regular oversight process.

In the case of the Legg Mason IF QS UK Equity Fund, the Board has recommended reviewing the fund’s investment objective and policy, in order to provide more clarity for investors.

Criteria rating

All funds delivered on their investment objectives over the period.

Legg Mason IF ClearBridge Global Equity Income Fund, Legg Mason IF ClearBridgeUS Equity Fund, Legg Mason IF ClearBridge US Equity Income and Legg Mason IF QS UK Equity Fund were all rated Amber.

Legg Mason IF MC Asia Unconstrained Fund was only recently launched and so has not been given a colour rating against this criteria.

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AFM COSTS & CHARGES Examines the costs of the services provided to the funds.

Areas of focus

We assessed the charges for each fund, considering the underlying costs for services and its performance objectives.

We compared a breakdown of each aspect of the ongoing charges figure (OCF) for each share class.

The largest proportion of the total costs and charges during the review period was the annual management charge (AMC), which is taken as a percentage of the value of the fund’s assets and varies depending on share class. Fund administration costs were covered by the GAC, which included distributing income and other payments to investors, fees and expenses related to maintaining the shareholders’ register, and other services.

Action taken

Prior to the assessment of value report, and independently of this process, we reviewed our expenses and administration costs and recognised we could be more effective in passing on benefits to investors. A review of charges resulted in the introduction of a new more-transparent charging mechanism, in place of the GAC. This may make it easier for certain cost savings to be passed onto investors. The new administration expenses scheme puts a cap on the total amount which can be taken from the fund’s assets. Under the GAC, this cap was a percentage of fund AUM. The new method sets an annual budget amount by expense type. This allows LMIF to immediately pass efficiencies of scale to investors as the fund grows, but also uses a cap to protect investors if the fund assets decline. LMIF monitors actual expenses against the budget on a continual basis.

Investors were notified ahead of 1st April 2020, when the various types of administrative costs which fall under the GAC changed.

Also, on 1st March 2020, as notified to investors, the ICVC’s depositary was changed to The Bank of New York Mellon (International) Limited. This change should result in a cost saving for investors. These changes, which happened outside the assessment of value report, demonstrate the effectiveness of the product lifecycle process.

Criteria rating

The costs and charges were considered to be reasonable when taking into account the underlying costs for the services provided and the performance objectives set for each fund. The management fees or annual management charge were considered to be reasonable when compared with the relevant peers. These changes are to be kept under review as part of the product lifecycle process.

Ongoing Charges Figure

GAC

AMC

Breakdown of costs and charges

This chart is indicative of a typical fund breakdown of costs and charges. It does not reflect any specific fund.

Legg Mason IF QS UK Equity Fund was rated Amber.

General Administration Charge

A flat monthly fee, covering fund administration costs.

Examples include:

- Maintaining shareholder register

- Distributing income and other payments to investors

- Calculating and publishing net asset value (NAV) and fund share prices

- Other regulatory, professional and audit fees

Fees vary between different share classes.

Now replaced by administration expenses.

Annual Management Charge

A yearly charge covering the management costs of running the fund.

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ECONOMIES OF SCALE

Investors have benefited from economies of scale at the overall ICVC level. They have also participated further in economies of scale derived from investing in Legg Mason-branded funds.

Areas of focus

We assessed whether LMIF has been able to achieve savings and benefits from economies of scale, relating to the direct and indirect costs of managing the ICVC and its individual funds. As part of the analysis we measured whether the individual funds had grown or contracted in size as a result of the sale and redemption of shares.

The analysis indicated, when looking at the services provided by Legg Mason and its investment managers, that investors are currently benefiting from all economies of scale which can be passed on.

However, investors in the individual funds within the ICVC benefit from the scale of the Legg Mason group, including its reputation and brand. Legg Mason’s scale gives it the ability to negotiate favourable pricing with service providers, such as The Bank of New York Mellon, due to the wide range of other products and services offered globally. Legg Mason is able to use its global scale and breadth of products to apply fee caps and waivers locally where funds are small, and the impact of fixed costs has an unduly large impact on overall total expenses. This allows for new products and share classes to be offered to investors while establishing broader distribution and assets growth.

These benefits are returned to investors in various ways. A relevant example for the ICVC is the recent depositary change, which leverages Legg Mason’s global relationship with The Bank of New York Mellon.

While some of the funds had seen material changes in size over the 12 months, no additional savings for investors were identified.

Assesses if LMIF has achieved savings from economies of scale and whether these are passed on to the investors.

Criteria rating

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COMPARABLE MARKET RATES

Areas of focus

We directly compared each fund’s OCF against other funds of similar objectives and/or size. The largest proportion of the OCF is management fees (referred to as the annual management charge, or AMC, in the ICVC’s prospectus). The OCF also includes administration, custody, audit and professional fees, as well as other costs charged to cover expenses, such as insurance or regulatory fees.

None of the funds charge performance fees.

We also compared each fund’s AMC in relation to the OCF and compared this against its peer group.

Action taken

In the case of Legg Mason IF QS UK Equity Fund, the Board has recommended reviewing whether fees should be lowered to more appropriately reflect the fund’s unique quantitative approach to investing. This is in conjunction with the fund’s regular oversight process.

It was also highlighted that, while the annual management fee for Legg Mason IF Martin Currie China Fund was in line or lower than others in its peer group, a larger general administration charge put it at the higher end compared with others in the IA sector. In this case, no further action has been recommended as the fund is now in liquidation.

Reviews the funds’ charges compared with funds offered by competitors.

Criteria rating

All funds had reasonable pricing for each share class.

Legg Mason IF Martin Currie China Fund and Legg Mason IF QS UK Equity Fund were rated Amber.

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COMPARABLE SERVICES

Areas of focus

For each fund, we compared the AMC for each share class against other pooled investment vehicles, including unit trusts and US mutual funds, with the same strategy managed by the relevant investment manager. We also compared charges against segregated accounts available through those investment managers.

For almost all the funds there were no accounts which were both comparable in size and had similar investment objectives and policies.

Looks at the funds’ charges compared withother products (including pooled investment vehicles, institutional mandates) managed by the investment managers, with similar investment objectives and policies.

Criteria rating

For all cases where applicable, the fees were reasonable compared with fees charged by the investment managers for any products of a comparable size and with a similar investment objective and policy to the fund.

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CLASSES OF UNITS

Share classes available

We have developed our share classes over time to adapt to customer requirements and changes in the industry. Not all share classes are available to all investors.

Hedged versions of the share classes are also made available. More information is available in the ICVC’s prospectus.

Areas of focus

We examined the current AUM for each fund by share class and client type and compared the percentage difference between each share class to judge whether it was reasonable, based on eligibility criteria and target investor.

Class X was added to the UK ICVC range ahead of the Retail Distribution Review (RDR) in 2012, which required UK financial advisers to charge customers fees for financial advice (instead of receiving commission or rebates from asset managers). As a result, investors using advisers should be invested by them in share classes, where no rebates or commissions are paid out (sometimes referred to as ‘clean’ share classes).

In most cases, the majority of investors were either in Class X or split between Class X and the legacy Class A. Fund platforms (on behalf of their clients) were generally the largest investor group, invested in Class A.

Action taken

The Board has recommended reviewing whether the Class A shares (which may be held by direct investors and through fund platforms) should be closed and investors moved to Class X on a mandatory basis.

Under this change, direct retail investors would be moved into Class X, while additional work would also take place to engage with fund platforms to ensure those investing via fund platforms are not worse off as a result of any transfer.

Considers whether investors are placed in the most appropriate share class, or if there are others which could be available to them at a lower cost.

Class A Available to all types of investors (including direct retail investors).

Class I Available to institutional investors who meet minimum investment and holding amounts, or to certain other investors (at the discretion of LMIF).

Class S Available for some funds to provide an incentive to grow assets to a sufficient scale. Institutional investors’ requirements are as Class I, but with lower pricing for a specified period of time.

Class X This is the default retail share class, available to sub-distributors or other intermediaries who have qualifying terms of business arrangements, such as fund platforms.

Criteria rating

Across the funds the pricing was reasonable based on the different share class eligibility criteria and target investor for each share class.

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LEGG MASON IF BRANDYWINE GLOBAL INCOME OPTIMISER FUND

Assessment of value:

Quality of Service

Investors have benefited from the range, nature, extent and quality of services provided. Investors also received clear communications and relevant information at appropriate times, to enable them to make informed decisions regarding their investments. The service was judged to be of good quality.


The pricing of each share class was reasonable when compared with peers.

Economies of Scale

The fund benefits generally at an overall ICVC level from economies of scale and is at scale. Investors in the fund also participate in economies of scale derived from investing in Legg Mason-branded funds, such as the ICVC. The specific benefits derived from these economies of scale are returned to investors in various ways. For the ICVC and this fund, an example is the recent depositary change – the lower fees leverage the global relationship with our service provider.

Performance

The fund has delivered on its investment objective to generate income in all market conditions. The fund outperformed its benchmark and performed in line with its IA peer group over five years. The fund’s yield (the income returned to investors) has reduced over the five-year period, which can partly be attributed to the decision to have a more cautious portfolio (given the uncertain economic and monetary policy environment).

Comparable Services

Fees were reasonable, compared with those charged by the investment manager for any products of a comparable size and with a similar investment objective and policy to the fund.

Classes of Units

The pricing of each share class was considered to be reasonable based on the different share class eligibility criteria and target investor for each share class.

Overall value rating

The Board has concluded the fund has delivered value to investors

Costs were reasonable, when taking into account the underlying costs of the services provided and the fund’s performance objectives. The changes to the ICVC’s depositary and the change to administration expenses should lead to cost savings for investors.

AFM Costs & ChargesFund objective

To generate income in all market conditions over a rolling three-to-five-year period. While the fund’s priority is to generate income, it will also seek to preserve capital

Benchmark GBP 3-month LIBOR Interest Rate

Peer group (IA sector) Sterling Strategic Bond

AUM(as at 29th February, 2020) £166 million

Launch date 19th November 2011

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LEGG MASON IF WESTERN ASSET RETIREMENT INCOME BOND FUND



Previously named Legg Mason IF Western Asset Global Blue Chip Bond Fund



Economies of Scale

The fund benefits generally, at an overall ICVC level, from economies of scale. However, due to the fund’s continuing relatively small size, it is subject to minimum fee levels contained in agreements with our service provider. To support the fund and its investors while it is not at scale, fees charged to the fund are capped. Amounts in excess of the cap are paid by Legg Mason – not the ICVC or its investors.

Comparable Services


Classes of Units


AFM Costs & Charges


Performance

The fund has delivered on its investment objective of providing income stability and capital preservation over the time period reviewed. The fund outperformed its benchmark but underperformed its IA peer group over three years (the fund moved to its new strategy in November 2015).

Quality of Service



Fund objectiveTo provide a regular income stream in excess of the prevailing level of interest rates in the UK, with a focus on capital preservation

Benchmark

A composite of the following three indices: (a) 50% ICE BofAML Sterling Corporate 1-10 Years Index; (b) 30% Bloomberg Barclays U.S. High Yield Corporate 2% Issuer Capped Index (GBP Hedged); and (c) 20% ICE BofAML U.K. Gilts 1-10 Years Index



Launch date12th February 1998, moved to current strategy in November 2015

21

LEGG MASON IF WESTERN ASSET GLOBAL MULTI STRATEGY BOND FUND



Economies of Scale

The fund benefits generally, at an overall ICVC level, from economies of scale. Despite a decline in size over the period reviewed, the fund remains at scale. Investors also participate in economies of scale derived from investing in Legg Mason-branded funds, such as the ICVC. The specific benefits derived from these economies of scale are returned to investors in various ways. For the ICVC and this fund, an example is the recent depositary change – the lower fees leverage the global relationship with our service provider.

Comparable Services


Classes of Units

The pricing of each share was considered to be reasonable based on the different share class eligibility criteria and target investor for each share class.

Performance

The fund has delivered on its investment objective to generate total return over the time period reviewed. The fund outperformed its benchmark but underperformed its IA peer group over five years. This outcome should be viewed in the context of a market cycle that at times did not favour emerging markets and non-UK credit. The fund’s peer group contains a diverse range of funds, some of which have benefited by having a very high concentration in specific themes and regions, whereas the fund’s approach is to be more globally diversified.

Quality of Service





AFM Costs & Charges


Fund objectiveTo maximise total return through income and capital appreciation by diversifying across a range of fixed income securities, sectors and currencies

Benchmark GBP 3-month LIBOR Interest Rate



Launch date 23rd May 2008

22

LEGG MASON IF CLEARBRIDGE GLOBAL EQUITY INCOME FUND

Comparable Services




Economies of Scale

The fund benefits generally, at an overall ICVC level, from economies of scale. However, due to its continuing relatively small size, the fund is subject to minimum fee levels contained in agreements with our service provider. To support the fund and its investors while it is not at scale, fees charged to the fund are capped. Amounts in excess of the cap are paid by Legg Mason – not the ICVC or its investors.

Classes of Units


AFM Costs & Charges


Quality of Service



Performance

The fund has delivered on its investment objective of achieving long-term capital growth and income for clients over the time period reviewed. The fund underperformed both its benchmark and IA peer group over five years. This outcome should be viewed in the context of a market cycle which has seen investors favouring stocks which have ‘growth’ characteristics (where revenues and earnings are expected to grow at a faster rate than the market average) over ‘value’ (companies that appear to be trading for less than the value of their assets) or those which pay out dividends, particularly over the past few years. The investment manager’s decision to have a large overweight exposure in European stocks and a large underweight in US stocks (relative to the MSCI World lndex and peer group) is the key reason for the underperformance. The investment manager believed the former offered better growth and income opportunities for investors, while the latter were richly priced and offered low income. However, the market, particularly in the US, has continued to favour growth and technology stocks. This meant the fund’s performance was weak, although it has delivered above-median income levels compared with its peer group. There is still confidence in the fund’s return potential in a more favourable environment for the strategy.



Fund objectiveTo achieve income and capital growth through investment of at least 70% of the net asset value of the fund in a range of equity and equity-related securities

Benchmark MSCI World Net Dividends Index

Peer group (IA sector) Global Equity Income


Launch date 23rd May 2008

23

LEGG MASON IF CLEARBRIDGE US EQUITY FUND



Comparable Services


Classes of Units


Economies of Scale


AFM Costs & Charges


Quality of Service



Performance

The fund delivered on its investment objective of achieving capital growth over the time period reviewed. The fund underperformed both its benchmark and IA peer group over five years. This outcome should be viewed in the context of a market cycle which has seen investors favouring stocks which have ‘growth’ characteristics (where revenues and earnings are expected to grow at a faster rate than the market average) over ‘value’ (companies that appear to be trading for less than the value of their assets), particularly over the last three years. There is still confidence in the fund’s return potential in a more favourable environment for the strategy.



Fund objectiveTo achieve capital growth, through investment of at least 80% of the net asset value of the fund in securities of US issuers

Benchmark S&P 500 index

Peer group (IA sector) North America


Launch date 2nd January 2003

24

LEGG MASON IF CLEARBRIDGE US EQUITY INCOME FUND



Comparable Services


Classes of Units


Economies of Scale


AFM Costs & Charges


Quality of Service



Performance

The fund delivered on its investment objective of achieving income and capital growth over the time period reviewed. The fund underperformed its benchmark over five years while slightly underperforming its IA peer group over the same period. This outcome should be viewed in the context of a market cycle which has heavily favoured internet and software companies which are perceived to have ‘growth’ characteristics (where revenues and earnings are expected to grow at a faster rate than the market average). These companies rarely pay dividends and for that reason fall outside of the fund’s natural investment universe. The peer group also contains a diverse range of funds, most of which do not have the same income orientation as this fund, so are therefore not subject to the same headwinds.



Fund objectiveTo provide total return by seeking to provide income as well as long-term capital growth over a rolling three-to-five-year period

Benchmark S&P 500 index



Launch date 17th October 2011

25

LEGG MASON IF JAPAN EQUITY FUND



Comparable Services


Classes of Units


Economies of Scale

The fund benefits generally, at an overall ICVC level, from economies of scale. Despite a decline in size over the period reviewed, the fund remains at scale. Investors also participate in economies of scale derived from investing in Legg Mason-branded funds, such as the ICVC. The specific benefits derived from these economies of scale are returned to investors in various ways. For the ICVC and this fund an example is the recent depositary change – the lower fees leverage the global relationship with our service provider.

AFM Costs & Charges


Quality of Service



Performance

The fund delivered on its investment objective of achieving long-term capital growth over the time period reviewed and solidly outperformed its benchmark and IA peer group over five years. The fund has regularly been the top performer in its peer group over that time frame by being highly differentiated from its peers, with a clear focus on investing in strong and fast-growing companies that are taking advantage of Japan’s changing economy.



Managed by Shiozumi Asset Management

Fund objectiveTo achieve capital growth through investment in securities of Japanese companies

Benchmark Japan TSE 1st Section (TOPIX) index

Peer group (IA sector) Japan


Launch date 8th October 1996

26

LEGG MASON IF MARTIN CURRIE ASIA PACIFIC FUND



Comparable Services


Classes of Units


Economies of Scale


AFM Costs & Charges



Quality of Service


Performance

The fund delivered on its investment objective of achieving long-term capital growth over the time period reviewed. The fund outperformed both its benchmark and IA peer group over five years. Using its disciplined process, the fund has invested in attractively priced and growing companies in the Asia Pacific region during a period of overall strength for the markets.



Fund objective

To achieve long-term (over five or more years) capital growth through investment in the Asia Pacific region excluding Japan and seek to outperform the MSCI AC Asia Pacific ex Japan Net Dividends Index over rolling three-year periods (net of fees)

Benchmark MSCI AC Asia ex Japan Net Dividends Index

Peer group (IA sector) Asia Pacific excluding Japan


Launch date 26th June 2015

On 24th March 2020, the Board of Directors approved a proposal to merge this fund with the Legg Mason IF Martin Currie Asia Unconstrained Fund, subject to regulatory and shareholder approval.

27

LEGG MASON IF MARTIN CURRIE ASIA UNCONSTRAINED FUND



Comparable Services


Economies of Scale


Classes of Units

The pricing of each share class fund was considered to be reasonable based on the different share class eligibility criteria and target investor for each share class.

AFM Costs & Charges



Quality of Service


Performance

The fund was only launched in September 2019, which is too short a time frame to assess its performance against its benchmark, IA peer group or investment objective of delivering long-term capital growth. It is anticipated that Martin Currie’s investment approach will provide a robust portfolio of well-researched companies operating in Asia ex Japan, that can generate a competitive return over a long-term time horizon.

Recently Launched



Fund objectiveTo provide long-term (over five or more years) growth through investment in Asian (excluding Japan) equities and equity-related securities

BenchmarkNominal Asia (excluding Japan) GDP Growth and MSCI AC Asia (excluding Japan) Index

Peer group (IA sector) Asia Pacific excluding Japan


Launch date 27th September 2019

Subject to regulatory and shareholder approval the Legg Mason IF Martin Currie Asia Pacific Fund is due to merge with this fund.

28

LEGG MASON IF MARTIN CURRIE CHINA FUND

Comparable Services



The pricing of each share class was reasonable when compared with peers. However, while the annual management fee for each share class was in line or lower than others in the peer group, the fund’s general administration charge was larger, resulting in overall costs being at the higher end compared with others in the IA sector.

Economies of Scale

The fund has benefited generally, at an overall ICVC level, from economies of scale. Investors were notified when the fund closed that it was no longer commercially viable because its size meant it could no longer be managed in an economical way. A resurgence of interest was not anticipated that would attract sufficient new inflows to make the fund commercially sustainable.

Classes of Units


AFM Costs & Charges


Quality of Service



Performance

The fund delivered on its investment objective of achieving long-term capital growth over the time period reviewed before its closure. The fund outperformed both its benchmark and IA peer group over the near-five-year period up to its closure in January 2020. Using its disciplined process, the fund invested well in a diversified range of high-performing companies in China and Hong Kong during a period where these markets showed overall strength.



Fund objective

To achieve long-term (over five or more years) capital growth through investment in China and seek to outperform the MSCI Zhong Hua Net Dividends Index over rolling three-year periods (net of fees)

Benchmark MSCI Zhong Hua Net Dividends Index

Peer group (IA sector) Sector China/Greater China

AUM(as at 29th February, 2020) N/a (this fund went into liquidation on 14th January 2020)


29

LEGG MASON IF MARTIN CURRIE EMERGING MARKETS FUND



Comparable Services


Classes of Units


Economies of Scale


AFM Costs & Charges


Quality of Service



Performance

The fund has delivered on its investment objective of achieving long-term capital growth over the time period reviewed. The fund solidly outperformed both its benchmark and IA peer group over five years. Using its disciplined process, the fund has invested in attractively priced, high-quality and growing companies in emerging markets. The fund has benefited from its focus on technology-related businesses and those that are consistently growing faster than others in emerging markets.



Fund objective

To achieve long-term (over five or more years) capital growth through investment in emerging markets and seek to outperform the MSCI Emerging Markets Index over rolling three-year periods (net of fees)

Benchmark MSCI Emerging Markets Index

Peer group (IA sector) Global Emerging Markets



30

LEGG MASON IF MARTIN CURRIE EUROPEAN UNCONSTRAINED FUND



Comparable Services


Classes of Units


Previously named Legg Mason IF Martin Currie European Equity Income Fund.

Economies of Scale

The fund benefits generally at an overall ICVC level from economies of scale. However, due to its continuing relatively small size, the fund is subject to minimum fee levels contained in agreements with our service provider. To support the fund and its investors while it is not at scale, fees charged to the fund capped. Amounts in excess of the cap are paid by Legg Mason – not the ICVC or its investors.

AFM Costs & Charges


Quality of Service



Performance

The fund has delivered on its investment objective of achieving long-term capital growth over the time period reviewed. The fund has outperformed both its benchmark and IA peer group over five years. Following a change of approach in December 2018, the fund is more concentrated with a focus on quality growth. This transformation has driven stronger absolute performance and relative performance, when compared with its benchmark and peer group in a period when European markets rose generally.



Fund objective

To provide long-term (over five or more years) capital appreciation through investment in a concentrated portfolio comprised of at least 80% of its net asset value in European (excluding UK) equities

Benchmark MSCI Europe ex UK Net Dividends Index

Peer group (IA sector) Europe (excluding UK)



31

LEGG MASON IF MARTIN CURRIE GLOBAL EQUITY INCOME FUND


Comparable Services



Classes of Units


Economies of Scale

The fund benefits generally, at an overall ICVC level, from economies of scale. Despite a decline in size over the period reviewed, the fund remains at scale. Investors also participate in economies of scale derived from investing in Legg Mason-branded funds such as the ICVC. The specific benefits derived from these economies of scale were returned to investors in various ways. For the ICVC and this fund an example is the recent depositary change – the lower fees leverage the global relationship with our service provider.

AFM Costs & Charges


Quality of Service



Performance

The fund has delivered on its investment objective of achieving long-term capital growth and income over the time period reviewed. The fund underperformed its benchmark but outperformed the IA peer group over five years. This outcome should be viewed in the context of a market cycle which has seen investors favouring stocks which have ‘growth’ characteristics (where revenues and earnings are expected to grow at a faster rate than the market average) over ‘value’ (companies that appear to be trading for less than the value of their assets) or those which pay out dividends, particularly over the past few years. However, the fund has delivered above-median income and capital appreciation levels compared with its IA peer group.



Fund objectiveTo achieve income, with the potential for capital growth over the long term (over five or more years), by investing in securities of companies listed globally

Benchmark MSCI AC World Index




32

AFM Costs & Charges


LEGG MASON IF MARTIN CURRIE US UNCONSTRAINED FUND



Comparable Services


Classes of Units


Previously named Legg Mason IF Martin Currie North America Fund

Economies of Scale

The fund benefits generally, at an overall ICVC level, from economies of scale and is at scale. Investors also participate in economies of scale derived from investing in Legg Mason-branded funds such as the ICVC. The specific benefits derived from these economies of scale are returned to investors in various ways. For the ICVC and this fund an example is the recent depositary change – the lower fees leverages the global relationship with our service provider.


Quality of Service


Performance

The fund has delivered on its objective of achieving long-term capital growth over the time period reviewed. The fund outperformed both its benchmark and IA peer group over five years. There was a modest change of approach in December 2019 and the fund is focused on a concentrated but diversified set of ‘growth’ companies (where revenues and earnings are expected to grow at a faster rate than the market average) that are considered to be high-quality. These have performed strongly over the period in review.

Fund objectiveTo achieve capital growth over periods of five or more years, through investment of at least 80% of the net asset value of the fund in a portfolio of US equities

BenchmarkMSCI USA (Net Dividends) Index (prior to 20 December 2019 MSCI North America Net Dividends Index)






33

LEGG MASON IF QS UK EQUITY FUND

Comparable Services


Classes of Units


Economies of Scale


AFM Costs & Charges

Costs were reasonable, when taking into account the underlying costs of the services provided and the fund’s performance objectives. The general administration charge was higher than the IA Sector median; however, it should be noted that due to this fund’s investment approach (see the performance section), it should be compared with peers with similar investment methods. The changes to the ICVC’s depositary and the change to administration expenses should lead to cost savings for investors.


Quality of Service


Performance

The fund has delivered on its investment objective of achieving capital growth over the time period reviewed. The fund underperformed both its benchmark and IA peer group over five years. The fund uses a quantitative-investment approach, meaning it applies factor-based models targeting quantifiable characteristics to select stocks to invest in. This systematic process selects stocks which look attractive on several fundamental aspects – attractive valuation, solid cash flow, positive technical factors, balanced volatility and healthy income. Over the last five years, some of these factors (such as higher cash flow and higher dividends) have not been in favour, which meant the stocks selected delivered less than the index return. The performance outcome should be viewed in the context of a market cycle which has seen investors favouring stocks which have ‘growth’ characteristics (where revenues and earnings are expected to grow at a faster rate than the market average) over ‘value’ (companies that appear to be trading for less than the value of their assets), particularly over the past few years. This fund takes a more balanced approach between investment styles. There has been marked improvement in performance in the last year and there is still confidence in the fund’s return potential in a more favourable environment for the strategy.


The pricing of each share class was reasonable when compared with peers. However, while all the funds in the peer group feature dividend-paying companies, not all of them are necessarily using a quantitative approach to select the companies within the portfolio, like this fund does, as it is not a common approach for funds in the UK.

Fund objectiveTo achieve capital growth through investment in quoted securities of UK companies

Benchmark FTSE All Share Index

Peer group (IA sector) UK All Companies


Launch date 31st October 1995


The Board has concluded the fund has delivered value to investors but with recommended actions.

Recommendation: The Board has recommended reviewing the fund’s investment objective and policy, in order to provide more clarity for investors.

Recommendation: The Board has recommended reviewing whether fees should be lowered to more appropriately reflect the fund’s unique quantitative approach to investing. This is in conjunction with the fund’s regular oversight process.

34

LEGG MASON IF ROYCE US SMALLER COMPANIES FUND



Comparable Services


Classes of Units


Economies of Scale

The fund benefits generally, at an overall ICVC level, from economies of scale. Despite a decline in size over the period reviewed, the fund remains at scale. Investors also participate in economies of scale derived from investing in Legg Mason-branded funds, such as the ICVC. The specific benefits derived from these economies of scale are returned to investors in various ways. For the ICVC and this fund an example is the recent depositary change – the lower fees leverages the global relationship with our service provider.

AFM Costs & Charges



Quality of Service


Performance

The fund has delivered on its investment objective of achieving capital growth over the time period reviewed. The fund underperformed both its benchmark and IA peer group over five years. This outcome should be viewed in the context of a market cycle which has heavily favoured ‘growth’ (businesses where revenues and earnings are expected to grow at a faster rate than the market average) and companies which are earning little or no profits over the sort of quality and ‘value’ stocks (companies that appear to be trading for less than the value of their assets) held in this fund. There is still confidence in the fund’s return potential in a more favourable environment for the strategy.



Fund objectiveTo achieve capital growth, through investment of at least 80% of the net asset value of the Fund in securities of smaller US companies

Benchmark Russell 2000 Index

Peer group (IA sector) North American Smaller Companies


Launch date 29th March 2004

35

LEGG MASON IF RARE GLOBAL INFRASTRUCTURE INCOME FUND



Comparable Services


Classes of Units


Economies of Scale

The fund benefits generally, at an overall ICVC level, from economies of scale and is at scale. Investors also participate in economies of scale derived from investing in Legg Mason-branded funds, such as the ICVC. The specific benefits derived from these economies of scale are returned to investors in various ways. For the ICVC and this fund an example is the recent depositary change – the lower fees leverage the global relationships with our service provider.

Performance

The fund delivered on its investment objective of achieving attractive income and its secondary objective of long-term capital growth over the time period reviewed. The fund outperformed both its benchmark and IA peer group over three years (it was launched in July 2016, so cannot currently show a longer five-year track record). The fund has invested in a range of strong dividend-paying and dividend-growing infrastructure stocks based around the world and this has generated a healthy return above the IA peer group.


Quality of Service




AFM Costs & Charges


Fund objective

To provide investors with an income comprised of dividends with a secondary investment objective of long-term (over five or more years) capital growth. The fund seeks to outperform the OECD G7 Inflation Index by 5.5% over an investment time frame of five years (gross of fees)

Benchmark OECD G7 Inflation Index plus 5.5%



Launch date 1st July 2016

36

DISCLAIMER

Legg Mason Funds ICVC is an umbrella investment company with variable capital, authorised in the UK by the Financial Conduct Authority as an undertaking for collective investment in transferable securities (“UCITS”).

Information has been prepared from sources believed reliable. It is not guaranteed in any way by any Legg Mason, Inc. company or affiliate (together “Legg Mason”).

Past performance is not a guide to the future. The value of an investment and any income from it can go down as well as up. Investors may not get back the original amount invested.

Before investing you should read the application form, Prospectus and KIID (and accompanying Supplementary Information Document). These and other relevant documents may be obtained free of charge in English from Legg Mason Investment Funds Limited, 201 Bishopsgate, London EC2M 3AB or from www.leggmason.co.uk.

Issued by Legg Mason Investment Funds Limited, registered office 201 Bishopsgate, London, EC2M 3AB. Registered in England and Wales, Company No. 00970167. Authorised and regulated by the UK Financial Conduct Authority. E20010

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