Important information

Please read this important information before proceeding further. It contains legal and regulatory notices relevant to the information contained on the https://www.axa-im-usa.com website (hereinafter the "Website"). These terms of use apply to your use of this Website and it is therefore important that you read them carefully. Any user who accesses and uses this Website shall be deemed as agreeing to these terms of use, in the version in force at the time the site is used. At any time, these terms may be revised by updating this posting. These terms are effective immediately upon posting and you are bound by any such revisions each time you access and use this Website. You should therefore periodically visit this page to review any updated terms. If you have any questions on these terms of use, you may contact William Obre, Head of US Marketing and Communications, AXA IM:

by mail: 100 West Putnam Ave, Third Floor, Greenwich, CT 06830 or
by phone +1 203 983 4238, or
by e-mail: contactus@axa-im.com

If you do not agree to these terms, do not use this Website.

Terms of use

The purpose of this Website is to provide corporate information about the US business of AXA Investment Managers ("AXA IM"), a multi-expert investment management company, which includes AXA Rosenberg Investment Management LLC ("Rosenberg Equities") and AXA Investment Managers Inc. ("AXA IM Inc."), both SEC-registered investment advisers (AXA IM's US business, collectively, "AXA IM US").

AXA IM publishes and hosts this Website on behalf of AXA IM US. AXA Investment Managers is a "société anonyme" incorporated under the laws of France, registered with the Corporate and Trade Registry of Nanterre under the number 393 051 826 RCS Nanterre, with its registered office located at Cœur Défense Tour B - La Défense 4, 100 Esplanade du Général de Gaulle, 92400 Courbevoie, France. When you use this Website, you also accept that such use and any information on the Website will be governed by French law and that any dispute arising out of or in connection with the use of this Website or the information on it will be submitted to the exclusive jurisdiction of the French courts.

AXA IM US does not claim that content within this Website is appropriate or available to use in all locations. As such, you are not entitled to access this Website if doing so would involve a breach of law by you or AXA IM US/AXA IM in any country. Due to the global nature of the internet, you also agree to comply with all local rules with respect to your online conduct, including all laws, rules, codes and regulations of the country in which you reside and the country from which you access this Website.

Certain information provided through this site has been filed with the United States Securities and Exchange Commission ("SEC") (such materials being referred to as "SEC Materials"). AXA IM US does not assume any duty of disclosure beyond that which is imposed by law, and expressly disclaim any duty to update any information set forth in the SEC Materials. The SEC Materials should be read in conjunction with AXA IM US's periodic reports filed with the SEC, including the disclosures therein of certain factors which may affect AXA IM US's future performance. Individual statements appearing in the SEC Materials are intended to be read in conjunction with and in the context of the complete SEC Materials in which they appear, rather than as stand-alone statements.

Certain statements included in both the SEC Materials and other public disclosures of AXA IM US contained on this site are "forward-looking statements" within the meaning of the Private Securities Litigation Reform Act of 1995. Such forward-looking statements are subject to risks, uncertainties and other factors which could cause actual results to differ materially from future results expressed or implied by such forward-looking statements. The most significant of such factors include, but are not limited to, the following: the performance of financial markets, the investment performance of AXA IM US's sponsored investment products and separately managed accounts, general economic conditions, future acquisitions, competitive conditions, and government regulations, including changes in tax rates. AXA IM US cautions readers to carefully consider such factors. Further, such forward-looking statements speak only as of the date on which such statements are made; AXA IM US undertakes no obligation to update any forward-looking statements to reflect events or circumstances after the date of such statements.

The use of certain sections of this Website may be subject to further special terms of use, which are indicated on the pages concerned. These special terms are an integral part of the terms of use of this Website.

Please note that in any case, application for an investment and subscription shall be based solely on such relevant documentation to be provided to the subscribers prior to their investment and will be accepted only from jurisdictions where such investment is lawful.

Information given for purely informative purposes

All data and information featured on this Website are provided by AXA IM US for purely informative purposes. Such data and information do not represent, or be construed as representing, a solicitation, an offer, or a recommendation by AXA IM US to buy or sell an investment, a service or to take part in any other transaction. It cannot either be construed as investment advice from AXA IM US or any other affiliated companies and has no legal or contractual value.

Some sections of this Website contain information, studies, analyses and comments on investment strategies, financial markets, economic trends, etc. This information is aimed solely at professionals and is not aimed at individuals.

Decisions based on information contained on this Website are the sole responsibility of the user, and in exchange for using this Website, the user agrees to hold AXA IM/AXA IM US harmless against any claims for damages arising from any decisions that the user makes based on such information.

This information has been obtained from reputably reliable sources, but there can be no guarantees over its accuracy, currency or completeness. More generally, despite the efforts made by AXA IM US to gather and confirm all information, AXA IM US cannot give any representation, warranty or undertaking of any nature, whether express or implied, as to the accuracy, up-to-date character, completeness or in general terms the quality or reliability of the information available on the Website. This information may be withdrawn or amended at any time without notice.

In this respect, neither AXA IM/AXA IM US nor any of their affiliates, directors, officers or employees, nor any third-party vendor retained by AXA IM/AXA IM US can be held liable towards the user, so far as this is permitted under French, US or other applicable laws, for any direct or indirect consequences arising out of or in connection with the use of such information.

This site does not provide any investment or tax advice or recommendation

Nothing on this Website constitutes investment advice. Neither the information, nor any opinion contained in this site constitutes a solicitation or offer by AXA IM/AXA IM US or their affiliates to buy or sell any securities, futures, options or other financial instruments, nor shall any such security be offered or sold to any person in any jurisdiction in which such offer, solicitation, purchase or sale would be unlawful under the securities laws of such jurisdiction. This Website also does not constitute, and should not be considered to be, tax advice. Depending on each country and local jurisdiction, tax rules are complicated and their impact on a particular individual may differ depending on the individual's specific circumstances. Investors should consult with their legal or tax advisor regarding their specific situations. Decisions based on information on this Website are the sole responsibility of the user, and in exchange for using this Website, the user agrees to hold AXA IM/AXA IM US harmless against any claims for damages arising from any decisions that the user makes based on such information.

Performance Warning

Past performance is not a guide to future performance and no representation or warranty, express or implied, is made regarding future performance. The value of investments and any return from them can go down as well as up. You may not get back the amount originally invested. Some investments discussed on this Website may have a high level of volatility. High-volatility investments may experience sudden and large falls in their value, causing losses when that investment is realized. Those losses may equal your original investment. Indeed, in the case of some investments, the potential losses may exceed the amount of initial investment and, in such circumstances you may be required to pay more money to support those losses. Income yields from investments may fluctuate and, in consequence, initial capital paid to make the investment may be used as part of that income yield. Some investments may not be readily realizable and it may be difficult to sell or realize those investments. Similarly, it may prove difficult for you to obtain reliable information about the value or risks to which such an investment is exposed.

Rosenberg Equities data

Although its investment approach is driven by bottom-up stock selection akin to that of a traditional fundamental investor, Rosenberg Equities seeks to achieve its clients’ investment objectives primarily in reliance on analytical models. The goal of Rosenberg Equities’ systematic approach is not to replicate a perfect “model” portfolio; instead, like other long-term, fundamentally oriented investors, it seeks to create portfolios possessing ex-ante those fundamental and statistically important characteristics reflecting its investment beliefs. Rosenberg Equities’ ability to implement its investment objectives depends on various considerations such as the models’ economic, analytical and mathematical underpinnings, the accurate encapsulation of those principles in a complex computational (including software code) environment, the quality of the models’ data inputs, changes in market conditions, and the successful expression of the models' views into the investment portfolio construction process.

Many of these have subjective elements that present the possibility of human error. While the investment process principally relies on models, Rosenberg Equities’ process also incorporates the investment judgment of its portfolio managers who may exercise discretion in attempting to capture the intent of the models, particularly in changing market conditions. Rosenberg Equities’ success in implementing its investment objectives may depend on the ability of portfolio managers and others to interpret and implement the signals generated by the models. Rosenberg Equities has established certain systematic rules and processes for monitoring client portfolios to ensure that they are managed in accordance with their investment objectives, but there is no guarantee that these rules or processes will effectively manage the risks associated with its investment process under all market conditions. While Rosenberg Equities employs controls designed to assure that its models are sound in their development and appropriately adapted, calibrated and configured, analytical error, software development errors, and implementation errors are an inherent risk of complex analytical models and quantitative investment management processes.

These errors may be extremely hard to detect, and some may go undetected for long periods of time or indefinitely. Rosenberg Equities’ controls, including its escalation policies, are designed to ensure that certain types of errors are subject to review once discovered. However, the effect of errors on its investment process and, where relevant, performance (which can be either positive or negative) may not be fully apparent even when discovered. When Rosenberg Equities discovers an investment process error in one of its models, it may in good faith and in accordance with its obligations, decide not to correct the error, to delay correction of an error, or develop other methodology to address the error, if not inconsistent with the client’s interests. Also, Rosenberg Equities generally will not disclose to affected clients investment process errors that are not the result of a contractual or regulatory breach, or that are non-compensable, unless it otherwise determines that information regarding the error is material to its clients.

Third-Party Content

Data and other materials appearing on this Website that are provided by third parties are believed by AXA IM US to be obtained from reliable sources, but AXA IM US cannot guarantee and is not responsible for their accuracy, timeliness, completeness or suitability for use. AXA IM US is not responsible for, and does not prepare, edit or endorse, the content, advertising, products or other materials on or available from any website owned or operated by a third-party that is linked to this Website via hyperlink. The fact that AXA IM US has provided a link to a third-party's website does not constitute an implicit or explicit endorsement, authorization, sponsorship or affiliation by AXA IM US with respect to such website, its owners, providers or services. If you use any such third-party content, you will be doing so at your own risk and should read the terms of use applicable to those specific sites.

Timeliness of all content

All content on this Website is presented only as of the date published or indicated, and may be superseded by subsequent market events or for other reasons. In addition, you are responsible for setting the cache settings on your browser to ensure you are receiving the most recent data.

Personal data protection

Personal data protection and cookies – Use of cookies by AXA Investment Managers

This website uses cookies to collect certain anonymous information when you visit our website (such as to measure and analyse information with respect to visits to our website, and use of our social media sharing tool). By pursuing your navigation on the website, you accept the use and installation of these cookies. We allow third-party companies, including LinkedIn, AddThis and Google Analytics, to collect certain anonymous information when you visit our website. This non personally identifiable information is stored for up to 1 year. We use this information to increase the efficiency of our website. To that effect we use your IP-address (and possibly other comparable numbers which are exchanged between computers during regular internet use) to collect, among others, traffic data and data regarding your browser type and computer. These companies may use non-personally identifiable information during your visits to this and other websites in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use a cookie or a third party web beacon to collect this information. To learn more about this behavioral advertising practice, you can visit http://www.youronlinechoices.eu.

You can refuse installation of cookies by using the option « do not track » or configuring your browser as following:

Mozilla Firefox 54.0 and above

Click on Tool menu, Options, Privacy; in Track, click on “manage the do not track Setting”. Do not check this box
Search Cookie and choose your option

Microsoft Internet Explorer 11.0 and above

Click on Tool icon then Internet Options: advanced options/ Security/ uncheck “Do Not Track” request
Click on tool icon, internet options/ Confidentiality: Select appropriate level

Google Chrome 59.0 and above

Click on Tool/ settings/ advanced/ Privacy and Security, un-check “Send do not track request”
Click on Tool/ settings/ advanced, click on Content settings/ Cookies: “Allow sites to save and read cookie data

Safari 4.0 and above

Click on Tool then Preferences
Go to the tab Security

If you meet any issue, please contact our webmaster at the following address:

webmasters@axa-im.com and indicate your browser, computer or mobile device configuration.

Personal Data (the "Data")

When consulting this website, AXA Investment Managers (AXA IM) collects your Data, specifically your IP address and, where applicable, your first name, surname and email address via forms. AXA IM, as data controller, undertakes that the collection and handling of this Data for information or external communication purposes shall comply with legal and regulatory provisions.

All the Data collected will be processed confidentially by AXA IM in accordance with applicable laws and regulations by:

The authorised people of AXA IM's information and external communications department,

The authorised people of subsidiaries, partners and service providers of AXA IM Group in order that they may complete the tasks entrusted to them.

The international nature of AXA IM Group therefore implies that the communication of nominative information may involve the transfer of this information between countries that are not members of the European Economic Area (Area), with these countries applying different Data protection legislation to countries within the European Union.

AXA IM may also assign certain services to providers located outside the European Economic Area (Canada, Hong Kong) for the performance of limited IT services (IT support and maintenance for reading and entering data). A framework agreement shall define the performance and security conditions incumbent upon service providers and standard contractual clauses, as per the General Data Protection Regulation (GDPR), which shall govern the transfer of Data to an AXA Group subsidiary in Hong Kong.

To ensure that personal data is protected, European Model Clauses and Binding Corporate Rules (BCR) are used in all agreements with AXA entities located outside the European Economic Area. You can obtain a copy of them by sending a request to the Global Data Protection Officer (DPO) of AXA IM at the following address: dataprivacy@axa-im.com.

AXA IM shall only keep your Data for the time period required to complete the operations for the reasons for which the Data was collected, and this in accordance with the legal regulations in force, i.e. for one year.

In accordance with applicable laws and regulations, you have the right to access, to rectify, to erase, to restrict the processing, to oppose on legitimate grounds relate to your personal data. You may exercise these rights by addressing an email to the Global DPO of AXA IM at the following address: dataprivacy@axa-im.com or by writing to the AXA IM Data Protection Department at the following address: AXA Investment Managers, Tour Majunga, La Défense 9, 6 place de la Pyramide, 92800 Puteaux.

You also have the right to give directives regarding the retention, deletion and communication of these personal data in the event of your death.

We take your request very seriously and we do our best to provide you with a satisfactory answer. If for any reason, we failed to respond to the above request, be informed that you have the right to lodge a complaint with the Supervisory Authority.

Non-liability of AXA IM/AXA IM US for usage of the Website

Users must accept that any access to this Website or any use of its content is carried out under their sole responsibility. As a consequence, neither AXA IM, AXA IM US, nor any of its affiliates, directors, officers or employees can be held responsible for any direct or indirect damage arising out of or in connection with such access or use, in particular but not limited to any damage caused by the interruption, withdrawal or malfunctions of the Website, in particular in the event of maintenance or restoration of the servers, a technical fault of the servers, overloading of the network, a cut in the telephone line, error, negligence or fault of the internet access providers, of a third party or of clients, or an internet-borne virus. In addition, users of this Website agree that the Internet is not a secure medium for communication of information and that AXA IM/AXA IM US will not be responsible for any loss or damage that could result from interception by third parties of any information made available through this Website.

Misuse

You must not misuse the Website by knowingly introducing viruses, trojan horses, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorized access to the Website, or to restricted areas of the Website, the server on which the Website is stored or any server, computer or database connected to the website. You must not attack our Website via a denial-of-service or distributed denial-of-service attack or take any action with similar effect. We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of the Website or to your downloading of any material posted on it, or on any website linked to it.

Communicating with us via the site

E-mail submitted to this Website should be considered neither secure nor confidential. AXA IM/AXA IM US make no representation whatsoever concerning the security or confidentiality of your e-mail messages and specifically make no representation that any e-mail message submitted through this site will be received by AXA IM/AXA IM US.

Any communications or material you transmit to this Website by electronic mail or otherwise, including data, questions, comments or suggestions, will be treated as non-confidential and non-proprietary and will become the property of AXA IM/AXA IM US or their affiliates. Such communications or material shall be used for any purpose, including, but not limited to, reproduction, disclosure, transmission, publication, broadcast and posting.

Furthermore, AXA IM/AXA IM US are free to use any ideas, concepts, know-how or techniques contained in any communication you send to this Website for any purpose whatsoever, including, but not limited to, developing and marketing products using such information. AXA IM/AXA IM US shall be under no obligation to respond to any communication that it may receive.

Hypertext links/Use of links

No hypertext link to this Website may be set up without the prior written consent of AXA IM US. This condition applies regardless of the type of link used.

AXA IM US may authorize some links to exist between this Website and other third party websites that are beyond its control. By permitting such links however, AXA IM US makes no representation as to the accuracy, completeness, timeliness or suitability of the information on the third party websites and does not accept any responsibility with regards to the content, services, products or materials offered on such websites.

You may not link to this Website unless you comply with these linking conditions ("Linking Conditions"). AXA IM US grants you a limited, revocable, nonexclusive right to create a hyperlink to this Website ("Link"), provided you comply at all times with the following conditions:

The Link must be made to the home page at https://www.axa-im-usa.com.
The text of the Link must read "AXA Investment Managers." You may not use any AXA IM logo or graphic, or any other AXA Group trademark, as part of the Link without AXA IM US's express written permission; and
The Link and surrounding context on the linking site must not: (a) falsely represent or misrepresent any relationship between the linking website and AXA IM/AXA IM US, including suggestions of affiliation, endorsement, or sponsorship; (b) portray AXA IM US or its affiliates or their products or services, in a false, misleading, derogatory, or otherwise offensive manner; or (c) deliver the content in a framed environment or alter the layout, content, look, or feel of the Website.

Ownership of Other Materials

Adobe®, Acrobat®, Acrobat® Reader, and the Acrobat logo are trademarks of Adobe Systems Incorporated. Microsoft® and Internet Explorer are trademarks of Microsoft Corporation. Morningstar® is a trademark of Morningstar, Inc. If MSCI information appears on this Website, it may only be used for your internal use, it may not be reproduced or redisseminated in any form, and it may not be used as a basis for or a component of any financial instruments or products or indices. None of the MSCI information is intended to constitute investment advice or a recommendation to make (or refrain from making) any kind of investment decision and may not be relied on as such.

Historical data and analysis should not be taken as an indication or guarantee of any future performance analysis, forecast or prediction. The MSCI information is provided on an "as is" basis and the user of this information assumes the entire risk of any use made of this information. MSCI, each of its affiliates and each other person involved in or related to compiling, computing or creating any MSCI information (collectively, the "MSCI Parties") expressly disclaims all warranties (including, without limitation, any warranties of originality, accuracy, completeness, timeliness, non-infringement, merchantability and fitness for a particular purpose) with respect to this information. Without limiting any of the foregoing, in no event shall any MSCI Party have any liability for any direct, indirect, special, incidental, punitive, consequential (including, without limitation, lost profits) or any other damages. (www.mscibarra.com). FTSE International Limited ("FTSE") © FTSE 2013. FTSE® is a trade mark of London Stock Exchange Plc and The Financial Times Limited and is used by FTSE under license. All rights in the FTSE Indices vest in FTSE and/or its licensors. Neither FTSE nor its licensors accept any liability for any errors or omissions in the FTSE Indices or underlying data. No further distribution of FTSE Data is permitted without FTSE's express written consent. STOXX indices are the intellectual property (including registered trademarks) of STOXX Limited, Zurich, Switzerland and/or its licensors. "Standard & Poor's®", "S&P®", "S&P 500®", "Standard & Poor's 500", "500", "S&P MidCap 400", "S&P SmallCap 600", "S&P 500 Pure Value", "S&P 500 Pure Growth", "S&P MidCap 400 Pure Value", "S&P MidCap 400 Pure Growth", "S&P SmallCap 600 Pure Value", and "S&P Small Cap 600 Pure Growth" are trademarks of Standard & Poor's Financial Services LLC ("S&P"). Citigroup® is a registered trademark of Citigroup and/or its affiliates and has been licensed for use by S&P.

Frank Russell Company is the source and owner of the Russell Index data contained or reflected in this material and all trademarks and copyrights related thereto. The presentation may contain confidential information and unauthorized use, disclosure, copying, dissemination or redistribution is strictly prohibited. Frank Russell Company is not responsible for the formatting or configuration of this material or for any inaccuracy in this presentation thereof. Any and all copyrights of "Nikkei Stock Average", "Nikkei Stock Index 300", "Nikkei 500 Stock Average", "NIKKEI JAPAN 1000" and "Nikkei JASDAQ Average", as well as any and all intellectual property rights and any other rights subsisting in the indications of "Nikkei", "Nikkei Stock Average", "Nikkei Stock Index 300", "Nikkei 500 Stock Average", "NIKKEI JAPAN 1000" and "Nikkei JASDAQ Average", are owned by Nikkei Inc. Unauthorized use or unauthorized sale and exploitation of this data is prohibited.

Intellectual property/copyright and trademarks

This Website is protected by domestic laws and international agreements on intellectual property. All intellectual and other property information contained in this Website shall continue to be held by the AXA IM Group and no rights of any kind in it shall pass to the users. The reproduction, representation, distribution (by electronic or any other means), amendment, or use of all or part of the form or content of this Website, through any medium, for public or commercial use, is therefore strictly forbidden, unless AXA IM US has given its prior express written consent. You may however copy pages and/or sections of this Website for your own personal, informational and non-commercial use, provided that you do not alter the content in any way, such as removing any copyright or other notices relating to intellectual property. None of these elements or information may be resold or redistributed in any way.

The names "AXA Investment Managers" and "Rosenberg Equities" and all associated logos are trademarks that have been registered by AXA IM or its affiliated companies. The reproduction, removal, reuse or modification in any way of the distinctive signs found on the pages of this Website is forbidden.

AXA IM US neither warrants nor represents that your use of materials displayed on this Website will not infringe rights of third parties not owned by or affiliated with AXA IM US. Nothing contained on the Website should be construed as granting, by implication, estoppel or otherwise, any license or right to use any trademark displayed on this Website without the written permission of AXA IM US or the owner of the trademark. Images displayed on this Website are either the property of, or used with permission by AXA IM/AXA IM US. The use of these images by you, or anyone else authorized by you, is prohibited unless specifically permitted. Any unauthorized use of the images may violate copyright laws, trademark laws, the laws of privacy and publicity, and communications regulations and statutes. If you download any information from this Website, you agree that you will not copy it or remove or obscure any copyright or other notices or legends contained in any such information.

You are hereby advised that AXA IM US will aggressively enforce its intellectual property rights, including pursuing all remedies available under civil and criminal law.

Export Controls

Software downloaded from or accessed through this Website is further subject to the United States Export Controls. No software from this Website may be downloaded or exported (i) into (or to a national or resident of) any country to which the United States has embargoed goods; or (ii) anyone on the United States Treasury Department's list of Specially Designated Nationals or the U.S. Commerce Department's Table of Deny Order. By downloading or using the software, you represent and warrant that you are not located in, under the control of, or a national or resident of any such country or on any such list.

Each Provision of these Terms of Use is Separately Enforceable

If any provision of these terms is deemed unlawful, void or for any reason unenforceable, then that provision will be deemed severable from these terms and will not affect the validity and enforceability of the remaining provisions. The preceding terms and conditions of use represent the entire agreement between AXA IM/AXA IM US and the user relating to the subject matter herein.

Termination

The rights granted to you herein terminate immediately if you fail to comply with the Terms of Use. AXA IM US, in its sole discretion, reserves the right to temporarily or permanently terminate your access to and use of this Website at any time and for any reason whatsoever, without notice or liability. AXA IM US will not be liable to you or any third party for any termination of your access to or use of this Website.