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For professional clients only A guide to passive fund management More than simply tracking the market

More than simply tracking the market - HSBC...More than simply tracking the market 3 Introduction The challenging market environment of recent years has led to many investors moving

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Page 1: More than simply tracking the market - HSBC...More than simply tracking the market 3 Introduction The challenging market environment of recent years has led to many investors moving

For professional clients only

A guide to passive fund management

More than simply tracking the market

Page 2: More than simply tracking the market - HSBC...More than simply tracking the market 3 Introduction The challenging market environment of recent years has led to many investors moving

2 More than simply tracking the market

Introduction 3

Building a passive fund 4

What should I look for in a passive 6 fund provider?

Why choose HSBC Global 8 Asset Management

Important Information 11

Over recent years, there has been a rapid growth in inflows into

passive investments, such as index tracker funds and Exchange

Traded Funds (ETFs). Passive funds aim to offer investors low-

cost, diversified and transparent market access.

The goal of passively-managed funds is to track a benchmark

index, which usually represents a broad market or a segment

within that market. However, the day-to-day management of

passive funds goes beyond merely buying and holding the

underlying securities. These daily tasks range from managing

corporate actions and dividend cash flows to implementing

index rebalances.

This document sets out the key responsibilities of passive fund

managers and how they run their portfolios on a day-to-day basis

to ensure that they track their benchmark in the most efficient

way possible.

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More than simply tracking the market 3

IntroductionThe challenging market environment of recent years has led to

many investors moving into passive funds, as they seek more

cost-efficient market access.

Rising global demand for passive investments has led to the

development of a wide range of passive funds, covering a broad

spectrum of market areas, sectors and asset classes.

We expect investor demand for passive solutions to continue

growing, both as a result of recent regulatory changes (such as

those brought in by the Retail Distribution Review) and rising

interest in passive investments from investors looking to reduce

the cost of managing their investment portfolios. Subsequently,

we believe that passive funds are likely to play a greater role in

the core of investor portfolios over the coming years.

The many roles of the passive fund managerAs with any investment, the knowledge and experience of

the individual fund manager play a key role in the successful

running of a passive fund. Passive fund managers have to be

able to handle proprietary research and in-house models to make

their own informed decisions about the most efficient way to

manage cash flows and other corporate actions (such as index

rebalancing and dividends). At the same time, managers ensure

that the risk profile of their fund remains within the established

limits compared to the underlying benchmark. During falling

and difficult markets, the ability of a fund manager to navigate

these challenging market conditions becomes crucial for the

performance of the fund.

As such, passive fund managers have a variety of dynamic

operational roles to play in managing their investors’ money.

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4 More than simply tracking the market

Building a passive fundHSBC Global Asset Management’s range of passive funds is

based on a robust investment process.

We start with what we call the “universe analysis” of the

underlying index, focusing mainly on FX allocation, rebalancing

costs, dividends and taxes. While defining the indexation

methodology, we consider client-specific requirements in relation

to the constraints of the fund. The objective of this exercise is to

minimise tracking error as much as possible.

In order to decide on portfolio construction, we then look at

the investable universe with respect to liquidity, volume, index

turnover and volatility, as well as the distribution between large

and small cap stocks within it and its composition at the country,

sector and industry level. A matrix approach is then used to

manage factor risk in the portfolio and to ensure that it has

a neutral position relative to the risk exposure implied by the

benchmark.

We then carry out pre- and post- trading analysis to ensure that

our portfolio is implemented in the most pragmatic and effective

way. Another part of this trading analysis, which is aimed at

minimising costs, is to estimate the actual costs, whether they

are explicit (taxes, custodian and execution) or implicit (market

impact).

Continuous fund monitoringAfter the launch of a fund, and throughout its life, passive fund

managers continuously monitor and analyse their portfolios, to

ensure that the fund closely tracks its benchmark.

The cost and risk management activities undertaken by passive

fund managers on an ongoing basis in the management of their

portfolios are outlined below.

Cost ManagementThe objective of a passive investment fund is to replicate the

performance of its benchmark index. However, the costs of

managing the fund will most likely prevent it from delivering the

exact benchmark return. This is because, unlike the fund, the

index itself does not incur any trading costs when it rebalances.

In practice, costs play a key role in determining portfolio

performance. Passive fund managers concentrate on minimising

the impact of a range of factors that drive fund costs, and

subsequently the fund’s tracking difference to the benchmark.

Key cost considerations include:

` Index rebalancing

When an index rebalances (i.e. when it goes through

regular review of its composition and constituent weights),

passive portfolio managers also need to rebalance the funds

tracking that particular index accordingly. They will therefore

buy and sell securities, so that the fund matches the new

composition of the benchmark. However, buying and selling

equities involves trading costs, which will have an impact on

the passive fund’s performance relative to the index.

` Corporate actions

Corporate actions (such as mergers and acquisitions, stock

splits, rights issues, spin-offs or the receipt of interest/

dividends) also need to be processed by a passive fund

manager, which may then generate trading costs or

other implicit costs related to the corporate activity in the

underlying investment.

For example, dividends paid by the underlying stocks of a

passive fund need to be reinvested, as keeping them in

the portfolio would create a ‘cash drag’. This refers to the

impact on the fund’s performance from being underexposed

compared to its benchmark due to cash accumulation.

` Taxation

Taxation can also add to the difference between the

performance of a passive fund and that of its benchmark.

A common example of such a difference would be the

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A growing passive product rangeOver the past 25 years, there has been a significant

increase in the scale and scope of passive investment

products available to investors.

The first widely-used passive investment product was

the index tracker fund, which came to prominence in the

1980s and 1990s.

The next stage in passive investment in Europe was

represented by the emergence of Exchange Traded

Funds (ETFs) during the 2000s. ETFs added liquidity and

transparency to the index trackers’ core strengths of

cost-effective and diversified market access.

At present, a growing range of ‘smart beta’ solutions,

such as HSBC Alternative Indexation or RAFI*, is being

pioneered by many passive fund managers. Smart beta

uses quantitative analysis or other proprietary research

to come up with alternative investment strategies. These

include using alternative weighting methods to the

traditional market capitalisation approach, or constructing

new alternative market capitalisation based indices

that have a stronger grounding in actual economic

fundamentals.

Other methods of gaining index exposure include

segregated mandates.

Individual circumstances (such as tax eligibility or any

client restrictions) can help advisors to decide which

type of passive investment product is right for their

clients’ specific needs.

* In partnership with FTSE, Research Affiliates (RA) launched

a series of indices based on the Fundamental Index (FI) methodology developed by Research Affiliates.

withholding tax (WHT) rate paid on dividends. An index might

assume that the tax rate on a stock’s dividend is 30% for a

given country, while the fund, as a result of a favourable tax

treaty between the stock’s country and the fund’s domicile

country, might actually only pay a 15% tax rate. The reverse

is also possible and, in some instances, the fund might pay a

higher WHT rate than that assumed by the index.

Risk managementComprehensive risk management also forms a crucial part of

the passive fund manager’s role. This is not only key during the

portfolio construction process, but continues on an ongoing basis

over the life of the fund.

Passive fund managers carry out risk management analysis on a

daily basis. This starts with the verification of the net asset value

and performance attribution, which allows them to monitor how

closely the fund is tracking its benchmark.

Other factors, such as the fund’s current exposure to foreign

currency, sectors or countries, are also taken into account. In

addition, risk management monitoring considers the impact

of the treatment of corporate actions, index rebalancings and

exchange rate movements. This is done on an on-going basis.

Passive fund managers also need to be aware of changes to the

taxation or regulatory environment, to see what impact these

might have on fund performance. When considering global

portfolios, this includes keeping track of potential changes across

several regulatory regimes at once.

At a trading level, fund managers have to be aware of all the

different market holidays that occur around the world and how

these are handled by index providers, as well as the specific

trading and settlement rules on each exchange.

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There are several key factors to consider when choosing the right

passive fund provider for your clients’ investment needs.

These include:

` Experience

` Scale

` Index methodology

` Tracking performance

` Costs

` Commitment to innovation

ExperienceAs with any investment decision, it is worth seeking out fund

managers that have a long track record in managing passive

investments if you are seeking to invest in a passive product.

Many leading fund managers, including HSBC Global Asset

Management, now offer over 25 years’ experience in managing

passive investments.

ScaleLarger passive fund managers are able to achieve greater

economies of scale, which can lead to lower costs for clients.

Global passive fund managers also need to maintain and develop

relationships with traders and brokers around the world, to

ensure best execution and low trading costs. It is also in passive

fund managers’ interests to have a local presence in key global

trading centres, so they can keep up to date with changing

regulations and understand exactly how local markets work.

HSBC Global Asset Management has extensive expertise and

a long track record in both developed and emerging markets

and we can offer direct market access on many local stock

exchanges. We are therefore able to go further than other

providers in offering full physical replicated passive investment

products. This long experience also supports our aim to keep

down our costs, which helps to both minimise fees and maintain

a strong tracking performance.

Index methodologyThere are several ways to construct a passive fund.

HSBC Global Asset Management believes that the full physical

replication approach to passive fund construction (i.e. buying all

of the stocks in the underlying index and in the same proportion

as the index) is the best approach to take, as it allows us to

construct funds with a high degree of transparency

and simplicity.

Where it is not cost-effective to buy all of the securities in

the underlying index (e.g. for broad indices such as the FTSE

All-Share or the MSCI World), we use a process known as

optimisation, where we own a proportion of securities in the

underlying index.

Although some studies have shown that synthetic funds (which

use swaps and other derivative products to obtain market

access) can offer a lower tracking error over time than full

physical replicated funds, we believe that the risks associated

with such synthetic funds – the most important of which is

counterparty risk – make them a less attractive investment

option.

Moreover, it is not always the case that synthetic funds provide

clear outperformance when compared to physical funds. For

example, HSBC Global Asset Management has developed a

range of physical ETFs (notably in Russia and Emerging Markets)

that offer very competitive tracking performance compared to

rival synthetic funds. This has been achieved by leveraging our

local expertise in these markets, enabling us to carry out direct

investment in local stocks wherever possible. This helps to

reduce the tracking error of our funds.

Tracking performanceAs we stated above, the full replication element to HSBC Global

Asset Management’s investment approach reduces the potential

for any significant divergence in tracking performance. When

deciding upon any investment in a passive fund, it is crucial to

consider its historic tracking performance.

In doing so, it is worth looking at both tracking difference

(the difference between the net asset value of a fund and

its benchmark) and tracking error (how consistent this return

difference has been over time, computed using the standard

deviation of the tracking difference).

If, over time, the tracking error of a passive fund relative to

its benchmark index increases disproportionately, the return

objective of the overall investment portfolio would not be met.

Consequently, HSBC Global Asset Management’s replication

approach across its range of passive investment products aims

to minimise tracking error as far as possible. A low tracking

error means that a passive fund is meeting its main investment

objective, namely matching the returns of its benchmark closely.

What should I look for in a passive fund provider?

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CostsA commitment to competitive costs is essential for a passive

fund manager. Passive investments – such as index trackers and

ETFs – have historically tended to have lower costs than active

funds. This reflects the fact that passive funds do not require

large teams of active managers or stock-pickers to generate

outperformance, as the objective of a passive fund is only to

match the performance of its benchmark.

The key measurement of cost for both ETFs and index

tracker funds is the Ongoing Charges Figure (OCF). The OCF

incorporates elements such as the annual management fee

and a list of other operating costs carried by the asset manager;

these include administration, custody, trustee and audit fees,

as well as legal, regulatory and registration expenses. On the

other hand, corporate actions and index rebalancing - which both

generate trading costs - are not included in that figure. There are

also entry/exit fees to consider for index-tracker funds and trading

spreads and brokerage fees for ETF investments.

HSBC Global Asset Management is able to use its global

footprint and existing local expertise to devise cost-effective

passive investment products that offer a range of market

exposures, from global down to country-specific. Within

emerging markets, our trading scale often enables us to

negotiate attractive dealing costs on local exchanges, which we

can then pass on to investors via lower OCFs.

Our passive investment team is also able to call upon the full

infrastructure and expertise of the wider HSBC group in areas

such as global banking and markets, through to custodian and

administrative services. Moreover, our integrated IT systems

help us to achieve efficient execution and portfolio management.

Commitment to innovationPassive investments are currently experiencing a period of rapid

growth, with more and more fund managers looking to leverage

their own proprietary research to develop new ‘smart beta’

investment solutions. A commitment to innovation is therefore

another key strength that you should consider when choosing a

passive investment partner.

HSBC Global Asset Management remains committed to

innovation in smart beta and we have now enhanced our

passive range by offering investors Alternative Indexation

solutions. Alternative Indexation offers a complementary

option to commonly used benchmarks, whereby we use our

own proprietary research to develop traditional or alternative

weighting schemes.

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Why choose HSBC Global Asset Management?HSBC Global Asset Management’s range of passive investment

products (index tracker funds, ETFs and Alternative Indexation)

has been designed with the investor in mind. To that end, we

have used our global presence to create a broad range of passive

funds across both developed and emerging markets that provide

exposures to the areas where our clients are looking to invest.

HSBC Global Asset Management is a leading global investment

manager with a long track record of providing sound investment

solutions to a wide range of investors around the world. We

have been managing passive investments for over 25 years. The

fact that we have a common investment management team

working across our global passive range ensures that portfolio

construction and risk management processes are consistent

across our range of products.

HSBC Global Asset Management has a long track record in

emerging market investment and we can subsequently offer

direct market access on many local stock exchanges. We are

therefore able to go further in offering passive funds based on

this fast-growing market sector than other providers.

HSBC Global Asset Management’s robust quantitative portfolio

management and trading processes ensure that our funds are

able to track their benchmark indices closely.

HSBC Global Asset Management also believes in high levels of

transparency across its range of passive investment products.

We provide a daily list of the securities held by each fund

(portfolio composition file) as well as monthly fund factsheets.

Moreover, our overall investment approach remains conservative.

We believe in strong levels of risk management and governance

for our passive funds, aiming to deliver minimum tracking error at

a competitive price to our clients.

We believe that HSBC Global Asset Management is now well

placed to take a leading position in passive investment, offering

investors a broad range of complementary passive investment

solutions that can work alongside the active portions of client

portfolios.

Index Tracker Funds range Exchange Traded Funds range

HSBC AMERICAN INDEX FUNDHSBC FTSE 100 INDEX FUNDHSBC FTSE 250 INDEX FUNDHSBC FTSE ALL SHARE INDEX FUND HSBC EUROPEAN INDEX FUNDHSBC JAPAN INDEX FUNDHSBC PACIFIC INDEX FUNDHSBC UK GILT INDEX FUND

HSBC ESI WORLDWIDE EQUITY UCITS ETFHSBC EURO STOXX 50 UCITSHSBC FTSE 100 UCITSHSBC FTSE 250 UCITSHSBC FTSE EPRA/NAREIT DEVELOPED UCITSHSBC MSCI AC FAR EAST ex JAPAN UCITSHSBC MSCI BRAZIL UCITSHSBC MSCI CANADA UCITSHSBC MSCI CHINA UCITSHSBC MSCI EMERGING MARKETS FAR EAST UCITSHSBC MSCI EMERGING MARKETS LATIN AMERICA UCITSHSBC MSCI EMERGING MARKETS UCITSHSBC MSCI EUROPE UCITSHSBC MSCI INDONESIA UCITS

HSBC MSCI JAPAN UCITSHSBC MSCI KOREA UCITSHSBC MSCI MALAYSIA UCITSHSBC MSCI MEXICO CAPPED UCITSHSBC MSCI PACIFIC ex JAPAN UCITSHSBC MSCI RUSSIA CAPPED UCITSHSBC MSCI SOUTH AFRICA UCITSHSBC MSCI TAIWAN UCITSHSBC MSCI TURKEY UCITSHSBC MSCI USA UCITSHSBC MSCI WORLD UCITSHSBC S&P 500 UCITSHSBC S&P BRIC 40 UCITSHSBC WORLDWIDE EQUITY UCITS ETF

HSBC Global Asset Management

Passive Investment Product Overview

HSBC Global Asset Management

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More than simply tracking the market 9

Index Tracker Funds range Exchange Traded Funds range

HSBC AMERICAN INDEX FUNDHSBC FTSE 100 INDEX FUNDHSBC FTSE 250 INDEX FUNDHSBC FTSE ALL SHARE INDEX FUND HSBC EUROPEAN INDEX FUNDHSBC JAPAN INDEX FUNDHSBC PACIFIC INDEX FUNDHSBC UK GILT INDEX FUND

HSBC ESI WORLDWIDE EQUITY UCITS ETFHSBC EURO STOXX 50 UCITSHSBC FTSE 100 UCITSHSBC FTSE 250 UCITSHSBC FTSE EPRA/NAREIT DEVELOPED UCITSHSBC MSCI AC FAR EAST ex JAPAN UCITSHSBC MSCI BRAZIL UCITSHSBC MSCI CANADA UCITSHSBC MSCI CHINA UCITSHSBC MSCI EMERGING MARKETS FAR EAST UCITSHSBC MSCI EMERGING MARKETS LATIN AMERICA UCITSHSBC MSCI EMERGING MARKETS UCITSHSBC MSCI EUROPE UCITSHSBC MSCI INDONESIA UCITS

HSBC MSCI JAPAN UCITSHSBC MSCI KOREA UCITSHSBC MSCI MALAYSIA UCITSHSBC MSCI MEXICO CAPPED UCITSHSBC MSCI PACIFIC ex JAPAN UCITSHSBC MSCI RUSSIA CAPPED UCITSHSBC MSCI SOUTH AFRICA UCITSHSBC MSCI TAIWAN UCITSHSBC MSCI TURKEY UCITSHSBC MSCI USA UCITSHSBC MSCI WORLD UCITSHSBC S&P 500 UCITSHSBC S&P BRIC 40 UCITSHSBC WORLDWIDE EQUITY UCITS ETF

HSBC Global Asset Management

Passive Investment Product Overview

What to consider when investing in an index tracker fund and an ETF

Market risk

The value of investments and any income from them can go

down as well as up, and investors may not get back the amount

originally invested.

Currency risk

Where overseas investments are held, the rate of currency

exchange may cause the value of such investments to go down

as well as up.

Emerging market risk

Investments in emerging markets are by their nature higher

risk and potentially more volatile than those inherent in some

established markets.

Geographic risk

Some of the Index tracker Funds and Exchange Traded Funds

invest predominantly in one geographic area; therefore any

decline in the economy of this area may affect the prices and

value of the underlying assets.

Property risk

The value of interests in real estate companies may be affected

by changes in interest rates, tax laws and environmental laws

and regulations. While the value of interests in REITs may be

affected by the value of the property owned or the quality of the

mortgages held by the trust.

Russian risk

There are significant risks inherent in investing in Russia, which

could affect the value of investment. These include a lack of

clarity in laws and regulations in the following areas: investor

protection, banks and other financial services, the Russian

economic system, taxation, transaction settlement and fiduciary

duty and responsibilities of company management. Please see

the supplement for full information. Investors and potential

investors should read the relevant Key Investor Information

Document (KIID) and full prospectus and supplement for full

details of the risks involves prior to making a decision to invest.

If you have any doubt about the suitability of an investment you

should consult a financial adviser.

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This document is intended for professional clients only and

should not be distributed to or relied upon by retail clients.

The material contained herein is for information purposes only

and does not constitute investment advice or a recommendation

to any reader of this material to buy or sell investments. Care has

been taken to ensure the accuracy of this document, but HSBC

Global Asset Management (UK) Limited accepts no responsibility

for any errors or omissions contained therein.

Fund information

The HSBC index tracker funds referred to are sub-funds of HSBC

Index Tracker Investment Funds, an Open Ended Investment

Company that is authorised in the UK by the Financial Conduct

Authority. The Authorised Corporate Director and Investment

Manager is HSBC Global Asset Management (UK) Limited.

HSBC ETFs are sub-funds of HSBC ETFs plc, an investment

company with variable capital and segregated liability between

sub-funds, incorporated in Ireland as a public limited company,

and authorised by the Central Bank of Ireland. The company

is constituted as an umbrella fund, with segregated liability

between sub-funds.

Shares purchased on the secondary market cannot usually

be sold directly back to the Company. Investors must buy and

sell shares on the secondary market with the assistance of an

intermediary (e.g. a stockbroker) and may incur fees for doing so.

In addition, investors may pay more than the current Net Asset

Value per share when buying shares and may receive less than

the current Net Asset Value per Share when selling them.

For investors in the UK

All applications are made on the basis of the current HSBC ETFs

plc Prospectus, relevant Key Investor Information Document

(“KIID”), Supplementary Information Document (SID) and Fund

supplement, and most recent annual and semi-annual reports,

which can be obtained upon request free of charge from HSBC

Global Asset Management (UK) Limited, 8 Canada Square,

Canary Wharf, London, E14 5HQ. UK, or from a stockbroker or

financial adviser. Investors and potential investors should read

and note the risk warnings in the prospectus, relevant KIID, SID

and Fund supplement. UK-based investors in HSBC ETFs plc are

advised that they may not be afforded some of the protections

conveyed by the Financial Services and Markets Act (2000), (‘the

Act’). The company is recognised in the United Kingdom by the

Financial Conduct Authority under section 264 of the Act.

Restrictions

The shares in HSBC ETFs plc have not been and will not be

offered for sale or sold in the United States of America, its

territories or possessions and all areas subject to its jurisdiction,

or to United States persons. Affiliated companies of HSBC Global

Asset Management (UK) Limited may make markets in HSBC

ETFs plc.

Index disclaimer

The EURO STOXX 50 is the intellectual property (including

registered trademarks) of Stoxx Limited, Zurich, Switzerland

and/or Dow Jones & Company, Inc., a Delaware corporation,

New York, USA, (the “Licensors”), which is used under license.

The securities based on the Index are in no way sponsored,

endorsed, sold or promoted by the Licensors and neither of the

Licensors shall have any liability with respect thereto.

All rights in the FTSE 100 and the FTSE 250 (the “Indices”)

vest in FTSE International Limited (“FTSE”). “FTSE®” is a

trademark of London Stock Exchange Group companies and is

used by FTSE under licence. The HSBC FTSE 100 UCITS ETF

and the HSBC FTSE 250 UCITS ETF (the “Products”) have

been developed solely by HSBC Global Asset Management

(UK) Limited. The Indices are calculated by FTSE or its agent.

FTSE and its licensors are not connected to and do not sponsor,

advise, recommend, endorse or promote the Products and do

not accept any liability whatsoever to any person arising out

of (a) the use of, reliance on or any error in the Indices or (b)

investment in or operation of the Products. FTSE makes no

claim, prediction, warranty or representation either as to the

results to be obtained from the Products or the suitability of the

Indices for the purpose to which they are being put by HSBC

Global Asset Management (UK) Limited.

Important Information

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“FTSE®” is a trade mark of the London Stock Exchange

Group companies, “NAREIT®” is a trade mark of the National

Association of Real Estate Investment Trusts (“NAREIT”) and

“EPRA®” is a trade mark of the European Public Real Estate

Association (“EPRA”) and all are used by FTSE International

Limited (“FTSE”) under licence). The FTSE EPRA/NAREIT

Developed® Index is calculated by FTSE. Neither FTSE,

Euronext N.V., NAREIT nor EPRA sponsor, endorse or promote

this product and are not in any way connected to it and do not

accept any liability.

The funds or securities referred to herein are not sponsored,

endorsed, or promoted by MSCI, and MSCI bears no liability

with respect to any such funds or securities or any index on

which such funds or securities are based. The Supplement to

the Prospectus contains a more detailed description of the

limited relationship MSCI has with HSBC ETFs plc and any

related funds.

Standard & Poor’s and S&P are registered trademarks of

Standard & Poor’s Financial Services LLC (“S&P”) and Dow

Jones is a registered trademark of Dow Jones Trademark

Holdings LLC (“Dow Jones”) and have been licensed for use

by S&P Dow Jones Indices LLC and sublicensed for certain

purposes by HSBC Global Asset Management (UK) Limited.

The S&P 500 and the S&P BRIC 40 are products of S&P Dow

Jones Indices LLC, and have been licensed for use by HSBC

Global Asset Management (UK) Limited. HSBC Global Asset

Management (UK) Limited‘s HSBC S&P 500 UCITS ETF and

HSBC S&P BRIC 40 UCITS ETF are not sponsored, endorsed,

sold or promoted by S&P Dow Jones Indices LLC, Dow Jones,

S&P, their respective affiliates, and neither S&P Dow Jones

Indices LLC, Dow Jones, S&P, their respective affiliates make

any representation regarding the advisability of investing in

such product(s).

HSBC Global Asset Management Ltd is the Sponsor for HSBC

Economic Scale Index - Worldwide and HSBC Worldwide Index.

As such, it maintains a segregation of duties from entities

acting as the calculation agent for the Index, and investment

manager for any products linked to this Index. HSBC Global

Asset Management Ltd maintains a Conflicts of Interest policy

to manage any conflicts of interest between HSBC Global Asset

Management Ltd and other members of the HSBC Group

or other affiliates. As the Index Sponsor, HSBC Global Asset

Management Ltd has policies and procedures in place to ensure

that it operates with transparency and accuracy in the Index

creation and management process.

This document is approved for issue in the UK by HSBC Global

Asset Management (UK) Limited who are authorised and

regulated by the Financial Conduct Authority. Copyright HSBC

Global Asset Management (UK) Limited 2014. All rights reserved.

www.assetmanagement.hsbc.com/uk

To help improve our services and in the interests of security, we

may record and/or monitor your communications with us.

HSBC Global Asset Management (UK) Limited provides

information to institutions, professional advisers and their clients

on the investment products and services of the HSBC Group.

26032/AS/1014/FP14-1573. Expiry 10/10/2015.

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ContactFor more information, please contact us:

Email: [email protected]

Telephone: +44 (0) 207 024 0435

Website: www.assetmanagement.hsbc.com/passive

26032 10/14