Privacy Policy

Last updated July 25, 2022

This Privacy Policy sets forth the privacy practices of Engine No. 1 (“Engine No. 1.,” “we,” “our,” or “us”) with respect to our collection, use, sharing, and disclosure of Personal Information, including, but not limited to, Personal Information collected through this website (the “Site”), how it is used, and the circumstances under which it may be shared and disclosed. This Privacy Policy constitutes a legally binding agreement between you and Engine No. 1 that conditions your use of the Site, where and as permitted by applicable law.

If you are a California resident, please review our California Privacy Note.

1. Personal Information We Collect

When you visit the Site and during our ordinary business activities, Engine No.1 may collect or ask you to provide certain nonpublic personal information (“Personal Information”) in order to help us manage our relationship with you and serve your investment needs. The Personal Information we may collect from you may include personally identifiable information including names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, information on investment activities, or other personal information, such ascertain special categories of personal data (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under applicable law, that may be contained in the relevant materials, documents, or obtained through background searches.

2. Sources of Personal Information

We may collect Personal Information from:

Your communications with us;
Your transactions with us;
Services providers; and
Affiliates.

3. How we Use Personal Information

We use Personal Information for the following business purposes:

To provide our products and services and serve your investment needs;
To provide customer service and process your requests and inquires;
To offer new products and services;
To process subscriptions;
To open an advisory account or securities brokerage account;
To process transactions for client accounts;
For account maintenance;
To confirm your identity;
To communicate with you;
To protect the security and integrity of the Site;
To prevent or investigate fraud or other unlawful activity, and detect security incidents; and
To comply with and enforce applicable legal requirements.

4. How we Share Personal Information

Your privacy is important to us. Engine No. 1 does not disclose any Personal Information to nonaffiliated third parties, except to service or manage a client’s account or as permitted by law. We do not sell any Personal Information.

Every client has the right to direct Engine No. 1 not to disclose the Personal Information about that client to a nonaffiliated third party. If a client would like to exercise its right to opt out of this Privacy Policy, each client must provide a written statement exercising that right. This right to opt out may be exercised at any time and will remain in effect until written notice revoking said right is received by Engine No. 1 from the client. However, in the event Engine No. 1 encounters circumstances where it is compelled by law to disclose a client’s Personal Information, Engine No. 1 must provide, to non-affiliated third parties, a client’s Personal Information even if the client has exercised its right to opt out.

5. How we Protect Personal Information

Engine No. 1 seeks to carefully safeguard Personal Information. We will use commercially reasonable efforts to ensure that Personal Information is kept secure and safe from any loss or unauthorized disclosure or use. We restrict access to our client’s Personal Information to employees requiring that Personal Information to provide our products or services.

6. Notice for Residents of the European Economic Area and United Kingdom

Engine No. 1 does not currently offer its products or services to natural persons resident in the European Union or the United Kingdom (“EEA/UK”) and, accordingly, is not required to comply with the EU General Data Protection Regulation (“GDPR”). Any personal data provided to us by you will be processed in the United States or other jurisdictions outside the EEA/UK which may not afford the same protections of personal data as under the GDPR.

7. Contact Us

If you have any questions or comments about this Privacy Policy, please feel free to contact Engine No. 1 at website@engine1.com.

8. Privacy Notice For California Consumers

Last updated: July 25, 2022

This notice contains disclosures required by the California Consumer Privacy Act (“CCPA”), is only relevant to residents of California, and applies only to the collection or other use of “personal information” that is subject to the CCPA. Consumers with disabilities may access this notice by emailing website@engine1.com.

Information We Collect.

In the past 12 months, we have collected the following categories of personal information about California consumers:

Category	Examples
A. Identifiers	A real name, alias, email address, Internet Protocol (IP) address, account name, or other similar personal identifiers.
B. Other personal information categories, as listed in the California Customer Records statute	A signature, telephone number.
C. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

We do not knowingly collect, solicit or sell personal information from anyone under the age of 16.

We collect personal information from the following categories of sources:

Your communications with us;
Service providers, including, but not limited to: administrators, lenders, banks, brokers, auditors, law firms, consultants, employment agencies, credit bureaus;
Affiliates not under the Engine No. 1 brand;
Nonprofit organizations; and
Government entities.

Use of Personal Information.

We may use the personal information we collect for one or more of the following purposes:

Providing you with information about our products and services;
Providing performance and other updates;
One or more of the following business purposes:
- Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
- Auditing related to our interactions with you (e.g., counting ad impressions to unique visitors, verifying positioning/quality of ad impressions, and auditing compliance, etc.);
- Legal compliance;
- Detecting and protecting against security incidents, fraud, and illegal activity;
- Debugging;
- Internal research for technological improvement;
- Internal operations;
- Activities to maintain and improve our services; and
- Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer.

Sharing Personal Information.

We may disclose personal information in one or more of the categories identified above to:

- Service providers, including but not limited to: administrators, lenders, banks, brokers, auditors, law firms, consultants, employment agencies, credit bureaus;
- Affiliates;
- Business partners;
- Legal or government regulatory authorities as required by applicable law; and
- In connection with a potential business transfer.

In the past 12 months, we have not sold any personal information we collect to third parties, and we have shared the categories of personal information we collect only as set forth above.

Rights of California Consumers.

The CCPA provides a California consumer the following rights, subject to certain exceptions and limitations:

The right to request (a) the categories and specific pieces of personal information we collect, use, disclose, and sell about you, (b) the categories of sources from which we collected your personal information, (c) our purposes for collecting or selling your personal information, (d) the categories of your personal information (if any) that we have either sold or disclosed for a business purpose, and (e) the categories of third parties with which we have shared personal information;
For certain categories of personal information, the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the past 12 months and the names and addresses of those third parties;
The right to request that we delete the personal information we have collected from you or maintain about you;
The right to opt out of our sale(s) (if any) of your personal information; and
The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

You may submit requests relating to your exercise of rights under the CCPA to us:

Via phone: (855) 322-4512

email website@engine1.com

through your Engine No. 1 contact

We may need to request additional information from you to verify your identity or understand the scope of your request. In verifying requests, we will require you to provide, at a minimum, a phone number or mailing address. If we are unable to verify your identity, we will need to deny your request.

You may designate an authorized agent to make a CCPA request on your behalf. In such case, we will ask the agent to provide proof that you have given the agent signed permission to act on your behalf. In addition, we will ask you to either (1) verify your identity directly with us in the manner described above or (2) directly confirm with us that you have provided the agent permission to make the request on your behalf.

© 2022 Engine No. 1 LP. All rights reserved. Use of this website is governed by the User Agreement. The content contained on this website is provided to users “AS IS” without any express or implied warranty. For information on your privacy, please read our Privacy Policy.

Engine No. 1 is an investment firm purpose-built to create long-term value and bring common sense back to capitalism.

To learn more about the firm, please see Engine No. 1 LLC’s Form ADV and Form ADV Part 2A.

This website may contain forward-looking statements, which reflect Engine No. 1’s current views with respect to, among other things, Engine No. 1’s operations and performance. You can identify these forward-looking statements by the use of words such as “anticipate” “approximately,” “believe,” “continue,” “estimate,” “expect,” “intend,” “may,” “outlook,” “plan,” “potential,” “predict,” “seek,” “should,” or “will,” or the negative version of these words or other comparable words. Forward-looking statements are subject to various risks and uncertainties. Accordingly, there are or will be important factors that could cause actual outcomes or results to differ materially from those indicated in these statements. Engine No. 1 undertakes no obligation to publicly update or review any forward-looking statement, whether as a result of new information, future developments or otherwise.

The description of Engine No. 1’s investment process and strategy is intended to be representative, but may be changed from time to time by Engine No. 1, and Engine No. 1 may alter the information at its discretion. Engine No. 1 intends to be focused and directed in the selection of opportunities to actively engage with portfolio companies. Engine No. 1 intends to measure the investment made by companies in their employees, communities, customers and the environment, including through the use of financial, operational, and sustainability metrics. While Engine No. 1 intends to seek opportunities to employ its active ownership beliefs, regulatory restrictions may limit the nature and extent of engagement in certain circumstances. Additionally, in the event that Engine No. 1 were to engage in active ownership, such activities may not be successful or, even if successful, an investment may still lose value or incur additional costs when engaging in active ownership.

All investments contain risk and may lose value. Investing in securities and other financial instruments entails substantial risk, including the possible loss of principal. Investors should conduct their own analysis and consult with professional advisors prior to making any investment decisions. The investment opportunities discussed or referenced herein may not be suited for all investors, and potential investors must make an independent assessment of the appropriateness of any investment opportunity in light of their own objectives and circumstances, including the possible risk and benefits of entering into such an investment opportunity. References to other securities are not an offer to buy or sell. The information contained herein is not complete, may change and is subject to, and qualified in its entirely by, the more complete disclosures, risk factors and other information contained in offering materials. The information is furnished as of the date shown. No representation is made with respect to its completeness or timeliness. This information is not intended to be, nor shall it be construed as, investment advice or a recommendation of any kind. Certain information has been obtained from third party sources and, although believed to be reliable, has not been independently verified and its accuracy or completeness cannot be guaranteed.

Past performance is not a guarantee of future results.

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