Jun 2024: Nubank – A snowball at the top of a long wet hill

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Nubank – A snowball at the top of a long-wet hill

June 2024 ($11.7)

 

We spent some time last week thinking hard again about Nubank. We reflect further on a business we think has the potential to be very big and very important in the global banking system. We are loathe to make the Amazon comparison, but there is a scale of large industry disruption and customer centricity occurring here that suggests using such a lens is appropriate. What is also interesting is that, with a company growing very fast (c.25% of Brazilians have a Nubank as their primary account) changes in the company’s financial model are happening quickly.

7 Powers comes to life

Available on request, we have the company’s most recent investor call transcript, with our annotations. Investors with good mental models in their head we hope quickly will find much to like:

  • This is a company with super-low unit-costs (c.80% below mainstream banks it estimates)
  • It is hugely customer centric, i.e. trying to offer more competitive loans and deposit pricing whenever it can
  • It is also very aware of its disrupter status and using it powerfully to:

a) make a noise about its brand and new products, which customers love

b) crucially to pass some of its operating efficiencies on to customers

  • It is a fully capitalised bank and importantly seen as such by customers

The actions of its now 100m account holders suggest what Nu is doing is powerfully resonating. These 100m people have decided they like the competitive interest rate on a Nu credit card, or the extra money they can earn in a Nu Mexican deposit account (the 15% interest rate on offer is roughly 3x the rate other Mexican banks pay today). Crucially, 100m people have decided also to trust Nu with their money.

Reading the Nu Holdings annual report or an investor call is a little like watching Hamilton Helmer’s, 7 Powers book spring into life. The company has for 10 years (in Brazil) and for the last two years in Mexico powerfully used its upstart, counter positioning traits. This makes a noise and gets it noticed, but already this is morphing into scale economics, i.e. re-investing its unit-cost advantage to drive a bigger wedge between it and the sleepy banking incumbents.

Pattern recognition

We have had quite a few experiences of this challenger situation now in our careers and have learnt much from each of them. Often the picture is clearer nearer the end of the journey, but with Nubank currently still only powerful in one country we think we are far nearer its beginning. Great examples of counter-positioning businesses that became industry leaders include Netflix and Ryanair. We know both well and saw them real time morph from scrappy disrupters to unit cost/scale economy leaders. We often describe our job as largely pattern recognition; Nu Holdings we think, is a wonderful example of just that.

Here is what we said about counter-positioning, and how market incumbents react to it, in our Netflix piece. We think it highly relevant to where Nubank finds itself today vs its LATAM (and global) banking peers.

Counter-positioning

Sometimes it is hard to remember where you first heard something. We had read about counter-positioning before reading 7 Powers, but the book’s work on it we thought useful. We have certainly seen a great deal of real life counter-positioning via the challenger businesses we follow in Ryanair, JDW, Amazon, Schwab etc. 7 Powers articulates well the common traits that these businesses often display and how they impact incumbent players. Helmer brilliantly refers to the five stages of how incumbents react to counter-positioning. They are listed below:

  1. Denial
  2. Ridicule
  3. Fear
  4. Anger
  5. Capitulation (frequently too late) Source: 7 Powers, Hamilton Helmer

These are excellent and so true. Your author as an ex-airline analyst saw these close at hand when British Airways or Lufthansa was often asked about Ryanair in its early days. Denial and Ridicule were common. With Ryan’s intra-EU market share now at 16%, such companies are at the capitulation stage! Whilst we did not hear Blockbuster answer questions about early-stage Netflix, we can only imagine their replies were similar. Denial, Ridicule, then in their case bankruptcy.

Power Progression

The second area of Helmer’s work we think appropriate to highlight for Netflix is what he describes as ‘power progression’. This is his way of thinking how a Sustainable Competitive Advantage (SCA) is being developed. Holland’s approach has been to look for SCA of some form and also the presence of owner managers. Helmer links the two. For many years now we have watched great owner managers innovate and pivot businesses. Helmer rightly describes “Innovation as the first step to gaining some sort of power.”

Whilst this is not rocket-science it is a useful mental tool as we see the best owner manager’s change and adapt to new market positions. What they of course are looking for is a SCA in the future environment. We have now seen more than a few owner managers make such transitions. We have also seen Mr Market often terrified of the potential consequences during such a period of flux. (Next moving online, Facebook’s Meta/AI investment, Frasers stopping discounting++). Source: Holland Advisors: Netflix – The Discovery Channel, April 2023

A Snowball…

Nu Holding’s CEO David Velez comes from this culture (ex-Sequoia) so he knows the theory we are outlining above well we suspect. Whilst this is useful, what is more powerful to our conviction on Nu is where the business now finds itself. As per the Peter Lynch quote, repeated later, an investors job in such a situation is not to re-invent the wheel.

Instead, it is to assess whether the business in front of them is powerful and if so, to then think logically about what might happen next in its rollout. To be considered a “Snowball” in investment terms you need to possess a few traits that make the superiority of your business model over peers self-evident. Not exclusively these traits will likely include:

  • Lowest unit cost,
  • Differentiated product,
  • High customer centricity,
  • A financial model that affords growth (i.e. good ROIC)
  • A visionary owner manager that knows what levers to pull

More succinctly put you need to be a horse (business model) of an exceptional standard who is being ridden by a great jockey (manager).

The long-wet hill

No matter how good the horse and jockey, what will affect your ability to grow (i.e. how fast for how long) however will be the length and gradient of the downhill of wet snow in front of you. Here is where our blood starts to pump a little quicker on Nu Holdings. Nu’s customer offering is better than all global banking peers, but cheaper to run and creates a higher ROIC as a result.

We think the Nu Holdings model is powerful and a counter positioning upstart who has already morphed into a scale economy shared model that customers love. Crucially however its competitors (globally) are asleep at the wheel. Even if they were to wake up, we are not sure what they could do to combat the threat that Nu is bringing to their door? This threat is only today being experienced by banks in Brazil and Mexico, but this mouse trap travels. Of that we are sure of – we think Mr Velez is too!

By way of an example, the Q1 Nu investor call transcript is interesting in its description of the Mexican banking market. Nu CEO David Velez explains that Mexican banking profits are largely made up of deposit spreads. I.e. the banks have been paying deposit holders 4-5% vs a 12% central bank rate, thus making almost risk-free returns. It is perhaps not odd therefore that when Nubank offers 15% to deposit account holders it gains 1-2% share of the entire deposit market in 24 months (and 6% credit card market share).

Mexican banks like all others trying to compete with Nu have dual cost bases (online and in branch) and thus need fat product margins to cover them. This means they cannot hope of competing with Nubank in terms of the interest rates offered. Deposit capital is flocking to Nubank and it is highly logical that more will follow as such a better offer is being made to the customer. Once the Mexican banks realise the scale of the existential problem facing them, they might try to cut costs to make ends meet. Likely this will mean closing branches, thus giving customers an even worse service, arguably creating a spiral with diseconomies of scale. Low headline PE’s will likely make such banks dangerous value traps. If you want to know where such a journey leads, read Nick Sleep below.

We do not live close to either Brazil or Mexico, but we suspect the incumbent banks are somewhere on that five-stage process of denial to capitulation we outlined above. We do not envy them.

Mexican bank deposit greedy profits are not replicated across the world, nor is the terrible service offered by Brazilian banks when Nubank started up. That said global banking is not an industry that has served customers well and it has been slow to change. Crucially the dual cost disadvantaged structure (online and in branch) is replicated worldwide. Additionally, no bank we are aware of has used the scale economy shared model to give customers great deposits rates say, as Nu is doing in Mexico. (The only example we can think of is JPM that sometimes uses its scale to muscle into new areas – all you can eat global research for $10k comes to mind!).

With a super low unit-cost structure and a desire to share that with customers we think this business model can travel – fast. Today it may be likely to grow further in LATAM, but why would it not come to Europe? Spain and Portugal would be our first bets. Nu’s ex-IR Director recently speculated they will target Spanish and Portuguese speakers living in US. EU/US regulators would surely welcome this deflationary force that is good for the customer. This all suggests to us Nubank might have a long-wet hill of snow in front of it. Even without such geographic expansion the company could be 8-10x its current asset (and profit) size just from its Brazil and Mexico operation’s maturing.

The future of banking..?

We wonder if a part of the Nubank investment story that is missed is the importance of its acceptance as a bank. I.e. in customers (and regulators) eyes it is not a payment platform or an FX provider, it is a fully-fledged bank with all the capital and reputational requirements for safe money that go with such a badge. An important truth is that customers think about banks very differently from how they think about money transfer platforms. That Nu’s customers compare it directly with mainstream banking peers, i.e. those that also have capital, and long-standing trusted brands is crucial.

We add to this the fact that such customers rate Nu’s service far more highly (via very high NPS scores) than they do competitors. This is despite these competitors spending 5x as much in cost terms as Nu! The longer-term implication of that statement we think all need to carefully consider.

The net result of this is a better product for the customer, and a more efficiently run bank that is much more profitable for shareholders (Brazil ROE >40%). This to us is analogous to what happened with the likes of Amazon, yes; but also say Spotify. Simply put this just looks a better banking mouse trap than the one almost all westerners are using today.

Clearly for much wider extrapolation of this model into USA and Europe, Nu needs to keep performing as it is today/become a business model others want to copy and fear. However, if it can do so, it might mean existing banking structures/entities are potentially as broken today as High Street retail was 15 years ago.

In the Appendix of this note is Nick Sleep’s discussion of Amazon vs the High Street retail offer in c.2006. Its essence was just to ask, ‘why can’t this superior business model one day have a very big market share..?’ The rest, as they say, is history! A shorter extract is shown below:

It seems to us that the basic building block of internet retailing, its skeletal structure, is far more robust, scalable and cheaper than the high street equivalent. In other words, its power law is very high, and implies that businesses with the simplicity of operation as say, Amazon.com, have a shot at being far bigger, quicker and more profitable than their high street equivalents. Nomad has an investment in Amazon for more reasons than the firm’s simplicity of operations. But when this basic building block is combined with the scale efficiencies shared model (which increases the moat as the firm grows), customer centric orientation of the firm’s founder, as well as his healthy disdain for Wall Street, this combination makes us think that we may have a mouse that can turn into an elephant. To those who argue Amazon is large already we ask two questions: what do you think e-commerce will be as a proportion of US retailing in ten-years’ time, and what do you think it was last year? Write both numbers down and turn to the end of this letter*** for the answer to the second question… (The answer was 2.6%). Extract from Nomad Investor letter 2006. Source Igy Foundation website

Sleep and his business partner Qais Zakaria dared to ask how big internet retailing could be and what that might mean for the future scale of Amazon? All we are doing here in 2024 is asking the exact same question of the online banking sector and Nu Holdings. How big could they be?

Some might regard the idea of forecasting Amazon, Ryanair or Netflix dominance 10-20 years’ ago as guesswork. We accept such forecasting is very hard, but we think there are moments when it looks a little easier. That is all Peter Lynch below is encouraging us to do. It is what we are trying to do as we balance our assessment of Nu’s seemingly powerful business model vs the existing banking industry that we assess Nu as so superior to. The actions of 100m customers so far suggests this is more than just a pipe dream.

“I don’t think that with great stocks you need a super-computer or an advanced Sun microsystems to figure out the math.”

Take the example of a company I missed: Wal-Mart. You could have bought Wal-Mart ten years after it went public. Let’s say you’re a very cautious person. You wait. Now ten years after it went public, it was a twenty-year-old company. This was not a start-up. So it’s now ten years after the public offering. You could have bought Wal-Mart and made 30 times your money.

The reason you could have done that is that ten years after it went public, it was only in 15% of the United States. And they hadn’t even saturated that 15%. So you could say to yourself, now what kind of intelligence does this take? This company has minimal costs, they’re efficient, everybody who competes with them says they’re great, the products are terrific, the service is terrific, the balance sheet is fine, and they’re self-funding. So you say to yourself, why can’t they go to 17%? Why can’t they go to 21%? Let’s take a huge leap of faith: why can’t they go to 23%? All they did for the next two decades was roll it out. They didn’t change it. I only wish they had started out in Connecticut instead of Arkansas. Source: Peter Lynch interview 2002

A powerful self-financing model

If the maths around Nubank’s business model were merely better than existing banks (say it looked set to make a 20% ROEs, by offering far more competitive products), then we would like/respect it as a business with growth potential. Arguably this is the model of companies like Costco, JDW or Ryanair. Such companies Returns on Capital are good, but not very high. Their ROE/ROIC’s of 15-25% are arrived at via high asset-turns, rather than high mark-ups. Such models have however enabled them to grow solidly by re-investing much of their profits for long periods. In turn more consumers turn up for their services.

What is exciting about Nu Holdings as an investment is that the company looks set to earn an ROE of c.40% or more we think. Doing so in a sector known for its capital intensity. Such outputs will create large sums for the company to re-invest into more industry growth at a potentially similarly high ROIC rate. In March we wrote on the subject of supernatural compounders and the traits we look for in such businesses (Holland Views : In search of Nirvana. March 2024). The more time we spend on Nubank, the more we think it one such company.

At the same time the regulated and capital-intensive nature of the banking sector means other new entrants coming behind Nu will not find catching up at all easy. This suggests to us the Nu snowball could surf down the hill at a fast rate, and even nimble competitors might wallow in its wake. (Too many metaphors? Probably!).

“In the first quarter of the year, Nu Holdings achieved an adjusted net income of US$443 million, reflecting an adjusted annualized return on equity of 27%. We believe that this performance surpasses that of most peers in the region, despite maintaining a considerable excess capital of US$2.4 billion at the holding level and with two subsidiaries in Mexico and Colombia that are still operating with negative profitability. If one were to look at our operations in Brazil alone, our return on equity remained well above 40%.” David Velez, Nu Bank CEO Q1 Analyst call 2024

It is interesting to us that Nu started in Brazil and Mexico, where competition is weak. Sam Walton of Wal-Mart built his scale vs weaker competition also.

Price is what you pay, value is what you get

Our Ryanair and Netflix learnings lead us to admire and believe in what Nubank might achieve as a disruptor that then uses its scale powerfully. Our Amazon experience maybe informs the price we should pay for such a business or at least how we should assess its valuation. Your author was for too many years, too quick to dismiss Amazon as an investment due to its high headline valuation. Only with more work and a little luck did the opportunity present itself in 2022 for him to right that wrong (Holland Advisors: Amazon – The one that got away, or did it? May 2022). Holland’s multi-year Amazon mistake was not to think far enough out to see the scale of compounding that would most likely be achieved. Particularly when the group’s high ROIC was constantly reinvested. Also, when Amazon’s near-in investment for long term growth was better considered. In that vein Nu Holdings recently disclosed that c. 40% of operational staff are working on products not part of the company’s current offering!

With this in mind there are a few ways to consider Nu Holding’s valuation today we suggest. The first is just to believe, as we do that the group can find plenty of opportunities to invest all its generated capital in the underserved banking sector globally over the next 10+ years. Simply put, if the company achieves an ROE of 30% and redeploys all that capital internally for a similar IRR, then profits/intrinsic value will grow annually at that rate, i.e. c.30%. We suspect readers would happily pay 30x earnings for such an entity. Indeed, were its PE to fall to 20x in year 10 investors IRR’s would still be c. 25%.

Underearning today

However, we also think it right to adjust Nu Holding’s current earnings as they represent a low level of maturity for existing customer spending. When we wrote on Nubank in January the company’s monthly revenue per user (ARPAC) was $10.5, having been c.$8 only 12 months previously. In just a single quarter this ARPAC has risen to $11.4.

Charts in the company presentation pack (see below) clearly show how such ARPAC trends higher the longer customers have been with the company. Crucially this is happening without significant further investment (i.e. this is just existing customers maturing with greater usage of existing products through time). Long tenanted customers have ARPAC’s of c.$27. With the company having a very low, and stable unit cost base, natural maturity improvements in ARPAC would have a huge effect on Nu’s profitability due to powerful operational gearing.

Fig.1 Nubank monthly ARPAC by year of customer joining

httpsapi.mziq.commzfilemanagerv2d59a081d2-0d63-4bb5-b786-4c07ae26bc744082caeb-2ebf-0239-8253-de31e1c97325origin=1.jpeg Source: Nubank Q1 24 Results

The adjustment we made for this in January was to assume a $15 ARPAC. Making the same adjustment now to the group’s Q1 figured just reported is instructive

  • Q1 2024 Net income/annualised = $442m X4 =$1,768m
  • Q1 2024 annualised ROE = 27% (c.$1,768m/$6,600m)
  • Q1 2024 revenue $2,735 = $912m per month. Annualised = $10,940
  • $912m/average active customers of 80.3m = ARPAC $11.4

If ARPAC adjusted to $15, then Holland underlying earnings power might evolve as follows:

  • Average active customers of 80.3m x $15 = $1,204m monthly revenue
  • New Q1 2024 annualised revenue of $14,448
  • Implied extra marginal revenue of $3.5bn
  • Despite low/stable unit costs we assume only 60% flow through to PBT + 30% tax
  • Incremental revenue at $3.5bn x 60% = $2.1bn extra PBT
  • After 30% tax = $1.47bn uplift in net income
  • New Q1 24 annualised net income = $1,768m + $1,470m = $3,238m
  • ROE = 49% ($3,238m/$6,600m)
  • Look through PE = 17x ($56bn/$3,328)

NB: This ROE of 49% matches with company guidance of Brazilian ROE >40%. Also, with the scale of investment it alludes to making in new products and services.

Bumps in the road

Nubank is different to the ‘fin-techs’ that have come before. The main reason is that it is a bank. It is regulated like a bank, has the capital of a bank and is crucially trusted by consumers with their savings, like a bank. Yes, this is because of the bank’s capital base and Brazilian license (it is still waiting for one in Mexico) but also because Nubank accepts savings and offers loans, like a bank.

Reputationally this looks to be a good thing with the company now widely known and trusted in its chosen markets. That said expanding into loan products quickly or lending to the under-banked is no easy task. Whilst the company claims it is building proprietary knowledge to help its lending decisions other ambitious companies who tried to grow fast in finance have made similar predictions in the past. Thus far the company has seemingly had good lending outcomes, whilst balancing these against its market share growth ambitions. We are not blind to the idea that such good credit outcomes will always be the case. Indeed, with likely plans to expand in more countries, for the company not to have some sort of credit hiccup would be surprising. The right question on this for investors: Is the danger of such an event enough to dampen the otherwise powerful compounding on offer? Alternatively, we should remind ourselves that the last ten years in Brazil have hardy been smooth sailing economically, i.e. this business has been built in a tricky lending environment. The above comments come under the risk category that all banks possess, ‘credit risk’. The reality that we fully accept is that history proves this risk often lands more at the door of newer lending institutions who have a greater focus on growth. Our eyes are open.

A separate risk for Nubank must also be considered, that of political risk. Wal-Mart and Amazon grew the scale of their businesses in their home US market, Nubank is starting in Brazil and Mexico. Whilst these markets have weaker banking competitors such regions do not come without real political risk. Recent elections in these countries and political attitudes towards free markets and central bank independence are evidence of that fact.

When considering competitive risk, we are looking for Nubank potential global peers, and in truth not finding many. We find disruptive fintech’s (Monza, Revolt, Sony Bank, Rakuten, N26) almost all of which however are assets light money transfer businesses. They offer better value services than mainstream banks, thus are well set to keep stealing incumbent’s FX and related revenues. As yet, however we have yet to find another sizable, fully regulated truly digital bank, i.e. one taking deposits and making loans. We are open to ideas on this point from readers. Are there other global companies that might more closely compare with what Nubank that we should be looking at?

In summary

We love disrupter business with super low unit-costs. We love them even more when they have high ROIC/ROE business models, thus can self-fund their growth. When such a company also has a long runway of growth ahead and is led by a passionate, visionary owner manager we think there is good reason for excitement. As we asserted in January, maybe Nubank will prove itself to be a “Supernatural Compounder”. We take a moment just to remind you of a little maths from that note; a ten year 30% compounder is worth 14x its starting capital value.

The credit and political risks at Nubank are clear and not to be easily dismissed. For Nubank, like Amazon fifteen years ago, the scale of the opportunity in front of it is potentially enormous. To deliver on such opportunity will require tackling difficult challenges (just like Amazon building a last mile network or its AWS division). Also, maybe just a touch of luck (no political disasters in Nu’s core countries in next 5y). The reality is that bumps in the road are an inevitable part of such a company’s future expansion. If the core Brazilian division can be grown through ARPU expansion as the company suggests it will become an enormous cash cow many times its current size. That (at =/>40% ROE’s) will both fund expansion and allow a few mistakes elsewhere along the way.

With kind regards

Andrew Hollingworth

The Directors and employees of Holland Advisors may have a beneficial interest in some of the companies mentioned in this report via holdings in a fund that they also act as managers to.

Appendix

Extract form Nomad Investor letter 2006. Source Igy foundation website

What can Investors learn from Scaling Laws?

This might be the right way to think about scaling in organisms, but does it tell us anything about companies, and especially firms as they grow? The question that needs to be answered is: why is it predictable that a business will grow from a mouse to an elephant? This is a little like asking the meaning of life, and we will try hard not to give an answer as intractable as Douglas Adams’ suggestion in The Hitch-Hiker’s Guide to the Galaxy (where the answer to life, the universe and everything was “42”!). Several tenets are important. A business ought to be able to self-fund its own growth, and if the opportunity set is large, then the return on capital needs to be suitably high. Second, barriers to entry should increase with size; that way a company’s moat is widened as the firm grows. To do this, the basic building block of the business, its skeletal structure, is probably best kept very simple. In short, we want a skeletal structure that can support growth from mouse to elephant without too much skeletal reengineering.

Let’s consider traditional high street retailing. Goods are sent from the supplier to the retailers’ central warehouse, where they are stored until demanded by the shops. Goods are then sent to the high street stores. These are expensive pieces of real estate and have high operating costs. Price aside for a moment, the quality of service the consumer perceives is largely a function of staff levels, staff helpfulness, product range, shop furnishings and so on. So, there are lots of constantly variable elements to service quality at the most expensive end of the distribution system. It seems to us that the skeletal structure is highly complex, and many things can go wrong.

Contrast this to the internet model. Goods are sent from the supplier to a central warehouse, but often only after the order has been taken. The goods are then sent direct to the customer with the expensive high street real estate missed out. The quality of service perceived by the customer is the speed of delivery, the feel of the web site, functionality of the web site (such as recommendations), breadth of product range and so on and these factors are inherently more controllable. They are fixed in terms of expense and also customer experience (a web site viewed in New York looks the same as the same website viewed in London or Hong Kong). So, whilst quality is inherently patchy at most high street retailers, it is fixed at Amazon. This is important as it is complexity that is one of the main reasons firms fail as they try to grow.

It seems to us that the basic building block of internet retailing, its skeletal structure, is far more robust, scalable and cheaper than the high street equivalent. In other words, its power law is very high, and implies that businesses with the simplicity of operation as say, Amazon.com, have a shot at being far bigger, quicker and more profitable than their high street equivalents. Nomad has an investment in Amazon for more reasons than the firm’s simplicity of operations. But when this basic building block is combined with the scale efficiencies shared model (which increases the moat as the firm grows), customer centric orientation of the firm’s founder, as well as his healthy disdain for Wall Street, this combination makes us think that we may have a mouse that can turn into an elephant. To those who argue Amazon is large already we ask two questions: what do you think e-commerce will be as a proportion of US retailing in ten-years’ time, and what do you think it was last year? Write both numbers down and turn to the end of this letter*** for the answer to the second question. See below

*** The US Census Bureau estimates that e-commerce sales grew from 2.7% to 3.1% of all retail sales in the United States during the quarters of 2006. The source document can be found at www.census.gov/mrts/www/data/html/07Q1table1.html.

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This document does not consist of investment research as it has not been prepared in accordance with UK legal requirements designed to promote the independence of investment research. Therefore even if it contains a research recommendation it should be treated as a marketing communication and as such will be fair, clear and not misleading in line with Financial Conduct Authority rules. Holland Advisors is authorised and regulated by the Financial Conduct Authority. This presentation is intended for institutional investors and high net worth experienced investors who understand the risks involved with the investment being promoted within this document. This communication should not be distributed to anyone other than the intended recipients and should not be relied upon by retail clients (as defined by Financial Conduct Authority). This communication is being supplied to you solely for your information and may not be reproduced, re-distributed or passed to any other person or published in whole or in part for any purpose. This communication is provided for information purposes only and should not be regarded as an offer or solicitation to buy or sell any security or other financial instrument. Any opinions cited in this communication are subject to change without notice. This communication is not a personal recommendation to you. Holland Advisors takes all reasonable care to ensure that the information is accurate and complete; however no warranty, representation, or undertaking is given that it is free from inaccuracies or omissions. This communication is based on and contains current public information, data, opinions, estimates and projections obtained from sources we believe to be reliable. Past performance is not necessarily a guide to future performance. The content of this communication may have been disclosed to the issuer(s) prior to dissemination in order to verify its factual accuracy. Investments in general involve some degree of risk therefore Prospective Investors should be aware that the value of any investment may rise and fall and you may get back less than you invested. Value and income may be adversely affected by exchange rates, interest rates and other factors. The investment discussed in this communication may not be eligible for sale in some states or countries and may not be suitable for all investors. If you are unsure about the suitability of this investment given your financial objectives, resources and risk appetite, please contact your financial advisor before taking any further action. This document is for informational purposes only and should not be regarded as an offer or solicitation to buy the securities or other instruments mentioned in it. Holland Advisors and/or its officers, directors and employees may have or take positions in securities or derivatives mentioned in this document (or in any related investment) and may from time to time dispose of any such securities (or instrument). Holland Advisors manage conflicts of interest in regard to this communication internally via their compliance procedures.

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The Information does not take account of the investment objectives, financial situation and particular needs of any particular person and is not general advice to any class of persons. Therefore, you should not rely on the Information and should obtain relevant and specific professional advice in making any investment decision. Furthermore, nothing on this Website constitutes or should be construed to constitute: (i) an offer, advice, invitation or solicitation from us or our affiliates to buy or sell any investments or securities, futures, options or other financial instruments; (ii) an invitation or inducement to engage in investment activity or a financial promotion of any kind; or (iii) investment advice or recommendation. 4. Stock exchange prices and exchange rates The prices/values shown on this Website in relation to different underlying securities are based on the prices notified to Holland Advisors (London) Ltd as the last sale price of the relevant securities on the stock exchange on which they are traded as at the time and date shown. Those figures may vary throughout the course of, and between, stock exchange trading days, market trading times and business days in general. Holland Advisors (London) Ltd has not verified the figures with the relevant stock exchange and you should verify the accuracy of those figures separately before relying on them. 5. Permitted users of the Website The laws and regulations of the country from which you access this Website may include restrictions on the distribution of the Information. This Website is not directed at or intended for distribution to or use by any person or entity in any jurisdiction where (by reason of that jurisdiction’s applicable securities laws, person’s nationality, residence or otherwise) such distribution, publication, availability or use of this Website or any part of its contents would be contrary to applicable law or regulation or would subject Holland Advisors (London) Ltd to any registration or licensing requirement within such jurisdiction. If you are such a person or entity, you are not authorised to enter the Website. It is your responsibility to ensure that your use of this Website complies with any restrictions or any applicable local laws regarding use of the Information on this Website. Persons or entities in respect of whom such restrictions apply must not access the relevant pages on this Website. The Information displayed on this Website contains material that may be interpreted by the relevant authorities in the country where you are viewing this Website as a financial promotion or an offer to purchase securities. Accordingly, if you reside in any such country or fall within the scope of any law that seeks to regulate financial promotions in the country of your residence or in the country in which you are viewing this Website, please cease accessing or using this Website immediately. If you are uncertain about your position under the laws of the country in which you are viewing this Website, then you should seek clarification by obtaining legal advice from a lawyer practicing in the country of your residence or in the country in which you are viewing this Website before accessing this Website. You may not use any part of the material or Information on this Website to establish, maintain or provide or assist in establishing, maintaining or providing a stock market for trading in securities. 6. Investment Performance and Accuracy of Information The Site contains material about the past performance of our Funds. The value of an investment in a Fund may go up as well down so that an investor’s investment in a Fund, when redeemed, may be more or less than the original investment amount. By its nature, investment in a Fund managed by Holland Advisors (London) Ltd is only suitable for sophisticated investors who do not require immediate liquidity for their investment, for whom an investment in a Fund does not constitute a complete investment programme and who fully understand and are willing to assume the high risk involved in the investment programme of a Fund. THE PAST PERFORMANCE OF ANY INVESTMENT, INVESTMENT STRATEGY OR INVESTMENT STYLE IS NOT INDICATIVE OF FUTURE PERFORMANCE. Whilst the information contained on the Website has been given in good faith and every effort has been made to ensure its accuracy, the Information may not be complete or accurate for your purposes. This Website and the Information is provided on an “as is” basis and Holland Advisors (London) Ltd may not, and has no obligation to, update the Information or correct any inaccuracy which subsequently becomes apparent. The Information and/or opinions and estimates comprised in the Information may be changed or withdrawn without notice and may become outdated. You, therefore, should verify any information or other material obtained from this Website before you use it. HOLLAND ADVISORS (LONDON) LTD, ITS DIRECTORS OR OFFICERS DISCLAIM ALL REPRESENTATIONS AND WARRANTIES, WHETHER EXPRESS OR IMPLIED, INCLUDING BY WAY OF EXAMPLE BUT NOT LIMITATION AS TO RELIABILITY, COMPLETENESS, FITNESS FOR PURPOSE OR ACCURACY OF THE INFORMATION ON THIS WEBSITE OR ON ANY THIRD PARTY WEBSITE LINKED TO THIS WEBSITE. IN ADDITION, WE DO NOT REPRESENT OR WARRANT THAT THIS WEBSITE OR THE SERVERS THAT MAKE THE WEBSITE AVAILABLE WILL BE UNINTERRUPTED, ERROR FREE, OR FREE FROM INFECTION, VIRUSES, WORMS OR ANY OTHER HARMFUL CODE WHICH MAY HAVE CONTAMINATING OR DESTRUCTIVE PROPERTIES. YOU ARE FULLY RESPONSIBLE FOR ENSURING PROTECTIVE STEPS TO BE TAKEN SUCH AS VIRUS CHECKING. The Information is assembled from material prepared by Holland Advisors (London Ltd) or its agents but may not include Information made known to Holland Advisors (London) Ltd officers (or agents) subsequent to the date of publication of the Information indicated on the Website. If you use the Information, you do so at your own risk. Please recognise that the previous performance of securities or other instruments does not guarantee or predict future performance. 7. Exclusion of liability TO THE FULLEST EXTENT PERMITTED BY LAW, HOLLAND ADVISORS (LONDON) LTD ACCEPT NO LIABILITY TO YOU OR ANY THIRD PARTY FOR ANY LOSSES OR DAMAGES, INCLUDING, WITHOUT LIMITATION, DIRECT OR INDIRECT DAMAGES, CONSEQUENTIAL OR SPECIAL DAMAGES, LOSS OF USE, DATA OR PROFITS, COSTS OR EXPENSES INCURRED OR SUFFERED BY YOU OR THIRD PARTY, WHETHER IN CONTRACT OR DUE TO NEGLIGENCE OR OTHER TORTIOUS ACTION, ARISING OUT OF OR IN CONNECTION WITH THE ACCESS TO, USE OF, RELIANCE ON, OR PERFORMANCE OF THIS WEBSITE OR ANY INFORMATION CONTAINED ON THIS WEBSITE, WHETHER DUE TO INACCURACY, ERROR, OMISSION OR ANY OTHER CAUSE AND WHETHER ON THE PART OF US, OUR SERVANTS, AGENTS OR ANY OTHER PERSON. NOTHING IN THE TERMS OF USE EXCLUDES, RESTRICTS OR MODIFIES ANY CONDITION, WARRANTY OR LIABILITY WHICH MAY AT ANY TIME BE IMPLIED BY STATUTE OR ANY OTHER APPLICABLE LAW WHERE TO DO SO IS ILLEGAL OR WOULD RENDER ANY PROVISION OF AN AGREEMENT VOID. 8. Third Party Websites We may provide, on our Website, links to websites operated by third parties as a convenience to you. If you use these other sites, you will leave this Website. If you decide to visit any linked site, you do so at your own risk and it is your responsibility to take all protective measures to guard against viruses or other destructive elements. Holland Advisors (London) Ltd makes no representations, warranties or guarantees of any kind about any of the content of any other website which you may access by hypertext link through this Website. When you access any other website by means of a link from this Website, you should understand that your access to that other website is independent of Holland Advisors (London) Ltd and Holland Advisors (London) Ltd has no control over the content of the website, nor does Holland Advisors (London) Ltd in any way endorse or approve the content of that website. In no event will Holland Advisors (London) Ltd in any way be liable to you or any other person(s) or organisation(s) for loss or damage (whether direct, indirect, consequential, special or other) for any use of any site linked to it by means of hypertext or otherwise. 9. Indemnity You agree to indemnify Holland Advisors (London) Ltd and its officers from and against any claim brought by third parties against Holland Advisors (London) Ltd and its officers as a consequence of your breach of the Terms of Use. Furthermore, if your use of this Website results in the need for servicing, repair or correction of equipment, software or data, you assume all costs thereof. 10. Intellectual Property Rights and Licence The copyright, trade mark or any other intellectual property rights in the Website and the Information are owned by or licensed to Holland Advisors (London) Ltd. You may download or print out a hard copy of individual pages and/or sections of this Website provided you do not remove any copyright or other proprietary notices. Any downloading or other copying from this Website will not transfer title to any software or material to you. You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link to or use for any public or commercial purpose this Website without the prior written permission of Holland Advisors (London) Ltd. Any rights not expressly granted in the Terms of Use are reserved. 11. Operation of the Website You should be aware that the internet, being an open network, is not secure. If you choose to send any electronic communications by means of this Website, you do so at your own risk. Holland Advisors (London) Ltd cannot guarantee that such communications will not be intercepted or changed or that they will reach the intended recipient safely. 12. Privacy Any personal data relating to you will be collected, used and recorded by us in accordance with current data protection legislation, the Terms of Use and our Privacy Policy. You must read our Privacy Policy as it forms part of the Terms of Use. 13. Governing law The Terms of Use are governed by the laws of England and Wales and the courts of England and Wales will have exclusive jurisdiction over any disputes arising under them. 14. Waiver If you breach the Terms of Use and we take no action, we will still be entitled to use our rights and remedies in any other situation where you breach the Terms of Use. 15. Our details This website is owned and operated by Holland Advisors London Ltd. You can contact us at: Holland Advisors London Ltd, The Granary, 1 Waverley Lane, Farnham, Surrey, GU9 8BB. Updated and effective as of  31st March 2024
Disclaimer
Please read the following conditions of use of this website. This website is directed at high net worth experienced investors and institutional investors who understand the risks involved with the investments being promoted and it should not be relied upon by retail clients (as defined by Financial Conduct Authority). The information on this website is issued by Holland Advisors (London) Limited (hereafter referred to as “Holland Advisors”), a limited liability company (7431314) incorporated in England and Wales, which is authorised and regulated by the Financial Conduct Authority (FRN: 538932). This website is for information purposes only and does not constitute an offer or solicitation to buy or sell securities, funds or any other financial instrument. The information is directed inside the United Kingdom and is not directed at any persons in jurisdictions where it would be against local law or regulation.  In particular, information on this site is not directed at any person, partnership or corporation being resident in the United States of America. Holland Advisors disclaims all responsibility if you access or download any information in breach of any law or regulation of the country in which you reside. Information on this site The information provided does not constitute advice. Holland Advisors believes that the sources of the information in this website are reliable. However it cannot and does not guarantee, either expressly or implicitly, and accepts no liability for, the accuracy, validity, timeliness or completeness of any information or data (whether prepared by it or by any third party) for any particular purpose or use or that the information or data will be free from error. Holland Advisors does not undertake any responsibility for any reliance which is placed by any person on any statements or opinions which are expressed herein. Neither Holland Advisors nor any of its directors, officers or employees will be liable or have any responsibility of any kind for any loss or damage that any person may incur resulting from the use of this information. This does not exclude or restrict any duty of liability that Holland Advisors has to its customers under the regulatory system in the United Kingdom. All Information may be changed or amended without prior notice although Holland Advisors does not undertake to update this site regularly. Marketing Communications Documents on this site do not constitute investment research as they have not been prepared in accordance with UK legal requirements designed to promote the independence of investment research. Therefore, even if they contain research recommendations they should be treated as marketing communications and as such will be fair, clear and not misleading in line with Financial Conduct Authority rules. These communications are not personal recommendations to you and any opinions cited are subject to change without notice. Holland Advisors takes all reasonable care to ensure that the information on this site is accurate and complete; however no warranty, representation, or undertaking is given that it is free from inaccuracies or omissions. Documents on this site are based on, and contain, current public information, data, opinions, estimates and projections obtained from sources we believe to be reliable. Past performance is not necessarily a guide to future performance. The content of these documents may have been disclosed to the issuer(s) prior to dissemination in order to verify their factual accuracy. Investments in general involve some degree of risk, therefore Prospective Investors should be aware that the value of any investment may rise and fall and you may get back less than you invested. Value and income may be adversely affected by exchange rates, interest rates and other factors. The investments discussed on this website may not be eligible for sale in some states or countries and may not be suitable for all investors. If you are unsure about the suitability of an investment given your financial objectives, resources and risk appetite, please contact your financial advisor before taking any further action. Holland Advisors and/or its officers, directors and employees may have or take positions in securities, funds or derivatives mentioned on this site (or in any related investment) and may from time to time dispose of any such securities (or instrument). Holland Advisors manages these potential conflicts of interest internally via its compliance procedures. Fund Information Parts of this site may refer to Funds managed or advised by Holland Advisors. These are not solicitations to invest and any potential investors should refer to the “Our Funds” section of the website in order to learn more about these Funds and find out how and where to obtain the relevant full legal documentation. Linked Websites This site may be linked to third party websites or contain information provided by third parties. Holland Advisors does not make any representation as to the accuracy or completeness of such websites or information, has not and will not review or update such websites or information, and cautions browsers that any use made of such websites or information is at their own risk. Holland Advisors does not accept any liability arising out of the information contained on any linked website or Information provided by a third party and the use of such sites and information is at your own risk. This does not exclude or restrict any duty or liability that Holland Advisors has to its customers under the regulatory system in the United Kingdom. Indemnity You agree to indemnify and defend Holland Advisors, its affiliates and licensors, and the officers, directors, employees, and agents of Holland Advisors and its affiliates and licensors, from and against any and all claims, liabilities, damages, losses, or expenses, including legal fees and costs, arising out of or in any way connected with your access to or use of this website and the Information. Use of Cookies If you agree to these terms and conditions a “cookie” might be placed on your computer. A cookie is a packet of information that does not identify individual users of a website, but allows the collection of website activity (such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site). We can use this information for statistical purposes, which allows us to analyse and improve our website. The cookie will expire automatically after 6 months or you can manually remove cookies in your browser settings. Copyright, Trademarks and Other Rights Copyright, trademarks, database rights, patents and all similar rights in this site and the information contained in it are owned by Holland Advisors or relevant third party providers. You may use the Information and reproduce it in hard copy for your personal reference only. The information contained herein and any supplemental documentation provided is confidential and should not be copied, reproduced or redistributed without the prior consent of Holland Advisors. Governing Law You agree that your use of this site and any dispute arising from this use is subject to English law and you submit to the jurisdiction of the Courts of England & Wales.
Privacy Notice
This is the privacy notice of Holland Advisors London Ltd our company number is 07431314. Our registered office is at The Halt, Smugglers Way, The Sands, Farnham, Surrey, GU10 1NB.
Introduction
This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you. In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’. This notice applies to personal data collected through our website www.hollandadvisors.co.uk. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
Data Protection Officer
We have appointed a data protection officer (‘DPO’) who is responsible for ensuring that our privacy policy is followed. If you have any questions about how we process your personal data, including any requests to exercise your legal rights, please contact our DPO, Claire Brunt at  claire@hollandadvisors.co.uk.
Personal data we process
1. How we obtain personal data The information we process about you includes information:
  • you have directly provided to us
  • that we gather from third party databases and service providers
  • as a result of monitoring how you use our website or our services
2. Types of personal data we collect directly When you use our website, you may provide personal data by submission of data by our Sign Up or Contact Us forms. This can be categorised into the following groups:
  • personal identifiers, such as your first and last names
  • contact information, such as your email address and your telephone number for communication
  • records of communication between us including messages sent through our website, email messages and telephone conversations
  • marketing preferences that tell us what types of marketing you would like to receive
3. Types of personal data we collect from your use of our services By using our website and our services, we process:
  • technical information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
  • usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages
  • your preferences to receive marketing from us; how you wish to communicate with us; and responses and actions in relation to your use of our services.
4. Our use of aggregated information We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity. For example, we may aggregate usage information to assess whether a feature of our website is useful. However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice. 5. The bases on which we process information about you The law requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category. If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data. If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information. 6. Information we process with your consent Through certain actions when there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, you provide your consent to us to process information that may be personal data. Wherever possible, we aim to obtain your explicit consent to process this information, for example, we ask you to agree to our use of non-essential cookies when you access our website. We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists. You may withdraw your consent at any time by instructing us  claire@hollandadvisors.co.uk. 7. Information we process for the purposes of legitimate interests We may process information on the basis there is a legitimate interest, either to you or to us, of doing so. Where we process your information on this basis, we do after having given careful consideration to:
  • whether the same objective could be achieved through other means
  • whether processing (or not processing) might cause you harm
  • whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
  • improving our services
  • record-keeping for the proper and necessary administration of our business
  • responding to unsolicited communication from you to which we believe you would expect a response
  • preventing fraudulent use of our services
  • exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property
  • insuring against or obtaining professional advice that is required to manage business risk
  • protecting your interests where we believe we have a duty to do so
How and when we process your personal data
8. Your personal data is not shared We do not share or disclose to a third party, any information collected through our website.
Use of information we collect through automated systems
9. Cookies Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date. They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered. They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors. Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them. Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate. The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website. 10. Personal identifiers from your browsing activity Requests by your web browser to our servers for web pages and other content on our website are recorded. We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution. We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
Other matters
11. Your rights The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at  http://www.knowyourprivacyrights.org 12. Communicating with us When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business. We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service. 13. Complaining If you are not happy with our privacy policy, or if you have any complaint, then you should tell us. When we receive a complaint, we record the information you have given to us on the basis of consent. We use that information to resolve your complaint. 14. Retention period Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us to provide you with the services you have requested. 15. Compliance with the law Our privacy policy complies with the law in the United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’). 16. Review of this privacy policy We shall update this privacy notice from time to time as necessary.