📒 Section 1: Introduction

This Compliance Manual describes those procedures which are necessary to ensure Tiny Supercomputer Management Company (UK) Ltd’s (”TSMC”) compliance with the Financial Conduct Authority's Rules as set out in the FCA Handbook and associated guidance (the “FCA Rules”), in TSMC’s capacity as an authorised small AIFM and otherwise. This manual was last updated on 13 May 2024.

Purpose of the Compliance Manual

The policies and procedures must be followed by TSMC staff, contractors or advisors (”TSMC Staff”) at all times, as any breach of these rules may result in enforcement action taken by the FCA or involve TSMC in civil liability. Failure to comply may also give rise to: (i) grounds of dismissal or termination of your engagement with TSMC; and (ii) in certain instances criminal proceedings being initiated against you by the relevant authorities.

Any questions regarding the content of this Compliance Manual should be directed to the TSMC “Compliance Team” (being the Compliance Officer, Sandra Wing Man Lyness, and the Deputy Compliance Officer, Harriet Dedman).

The specific objectives of the Compliance Manual are:

• to define TSMC’s policies relating to compliance;
• to explain clearly and simply the compliance obligations of all TSMC Staff;
• to guide those persons in the conduct of their day-to-day business;
• to assist in the training of any new joiners; and
• to help demonstrate that TSMC has carefully thought about and conscientiously designed systems to meet its regulatory obligations.

This Compliance Manual is not a substitute for the FCA Rules.  Where TSMC Staff are uncertain as to the application of FCA Rules, they must consult the TSMC Ops Team. Capitalised terms and expressions used in this Compliance Manual shall bear the same meaning as in the FCA Rules, unless defined otherwise in this Compliance Manual.

Updates and Amendments

The TSMC Ops Team will at least annually oversee a review of the Compliance Manual to ensure that it remains appropriate and aligned to the business being conducted.  A review will also be conducted in the event of any changes to the following:

• TSMC’s designated investment business;
• the requirements of the FCA; or
• TSMC’s procedures.

Only Harriet Dedman and Sandra Wing Man Lyness will be permitted to amend this Compliance Manual.

The Compliance Manual is strictly confidential. No part of it may be disclosed to outside parties without the prior written permission of the TSMC Compliance Officer.

Queries regarding the interpretation of procedures described in the Compliance Manual should in the first instance be discussed with Harriet Dedman and Sandra Wing Man Lyness.