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3rd Floor  |  23 King Street
London SW1Y 6QY  |  UK
T  +44 (0)20 7864 6400
F  +44 (0)20 7864 6401

COMAC Capital LLP is a London-based discretionary global macro fund manager.  The team, led by Founding Partner and CIO Colm O'Shea, focuses on directional market movements that commonly have a strong fundamental reasoning based upon economic and political analysis.




1. About COMAC

The COMAC Capital LLP website “www.comaccapital.com” (“our site”) is a website operated by COMAC Capital LLP (“us” (and the expression “we” and “our” shall be construed accordingly)) and the information on our site is issued by us both inside and outside the United Kingdom. We are registered in England and Wales registration number OC316831 and have our registered office and main trading address at 3rd Floor, 23 King Street, London, SW1Y 6QY. Our VAT number is GB877633085. We are an investment company and we are authorised and regulated by the Financial Conduct Authority (“FCA”) (FCA Register number: 446250).

2. Important Information

This site may contain information or documents which constitute a financial promotion for the purposes of the Financial Services and Markets Act 2000 and the handbook of rules and guidance issued from time to time by the FCA (the "FCA Rules"). The information on this site is issued by us only to and/or is directed only at persons who are professional clients or eligible counterparties for the purposes of the FCA Rules. To the extent that investments and/or investment services are referred to on this site, they are only available to such persons and other persons should not act or rely on information available on this site. In particular, any investments and investment services are not intended for persons who are retail clients and will not be made available to retail clients.

The information on this site is exempt from the scheme promotion restriction on the communication of invitations or inducements to participate in unrecognised collective investment schemes on the grounds that it is being issued to and/or directed at only the types of person referred to above.

This site is not intended to constitute, and should not be construed as, investment advice. Potential investors in any investment fund managed by us should seek their own independent financial advice. This site has been provided for informational purposes only and may not be relied upon by you in evaluating the merits of investing in any securities or interests referred to on this site. This site is not intended as and is not to be taken as an offer or solicitation with respect to the purchase or sale of any security or interest or any investment service, nor does it constitute an offer or solicitation in any jurisdiction, including those in which such an offer or solicitation is not authorised or to any person to whom it is unlawful to make such a solicitation or offer. The distribution of information contained on this site in certain countries may be restricted by law and persons who access it are required to inform themselves and to comply with any such restrictions. Persons interested in receiving further information about any investment or service should inform themselves as to: (i) the legal requirements within the countries of their nationality, residence, ordinary residence or domicile; (ii) any foreign exchange control requirement which they might encounter; and (iii) the income tax and other tax consequences which might be relevant.

Any decision to purchase securities or interests with respect to any investment fund described on this site must be based solely upon the information contained in the relevant prospectus or confidential private offering memorandum for that investment fund, including any supplements thereto, which must be received and reviewed prior to any investment decision. Any person subscribing for an investment must be able to bear the risks involved and must meet the suitability requirements relating to such investments. Some or all alternative investment programs may not be suitable for certain investors.

3. Risk factors and other information

Nothing contained on this site constitutes investment, legal, tax or other advice, nor is it to be relied upon when making investment or other decisions. The information on this site is provided solely on the basis that you make your own investment decisions. You should obtain relevant and specific professional advice before making any decision to enter into an investment transaction.

Past performance may not be repeated and should not be seen as a guide to future performance. The value of investments and the income from them may go down as well as up and investors may not get back the amount originally invested. Because of this, you are not certain to make a profit on your investments and you may lose money.

Exchange rates may cause the value of overseas investments and the income arising from them to rise or fall. The levels and bases of and reliefs from taxation may change. Any tax reliefs referred to are those currently available and their value depends on the circumstances of the individual investor. Investors should consult their own tax adviser in order to understand any applicable tax consequences.

4. Your use of our site

These terms of use set out the terms on which you may make use of our site, whether as a guest or a registered user, and apply to every page on our site, whether or not such pages are individually disclaimed. Please read these terms of use carefully before you start to use our site. By using our site, you have indicated that you accept these terms of use and that you agree to abide by them. If you do not agree to these terms of use, please refrain from using our site.

You must NOT use our site (or permit or procure others to use it) as follows:

(A) for any unlawful, improper or illegal purpose or activity;

(B) to communicate or receive information that is obscene, indecent, pornographic, sadistic, cruel, or racist in content, of a sexually explicit or graphic nature, which promotes or incites discrimination, hatred or racism or which might be legally actionable for any reason;

(C) in a manner intended to threaten, harass, or intimidate;

(D) to violate our or any third party’s copyright, trademark, proprietary or other intellectual property rights;

(E) to damage our name or reputation or that of our affiliated companies or any third parties;

(F) to impersonate any of our employees or other person or use a false name while using our site or implying an association with us;

(G) to penetrate our security measures or other entities’ systems (“hacking”);

(H) to transmit unsolicited voluminous emails (for example, spamming) or to intercept, interfere with or redirect email intended for others using our site;

(I) to generate excessive amounts of internet traffic, to interfere with our network or other’s use of our site or to engage in activities designed to or having the effect of degrading or denying service to users of our site or others;

(J) to introduce viruses, worms, harmful code and/or Trojan horses onto the internet or into our site or any other entity’s systems and it is your responsibility to ensure that whatever you download or select for your use from our site is free from such items;

(K) to post or transmit information that is defamatory, fraudulent or deceptive, including but not limited to scams such as “make-money-fast” schemes or “pyramid/chain” letters; and/or

(L) to transmit confidential or proprietary information, except solely at your own risk.

Our site has been created for use in the United Kingdom only. When using our site, you must comply with all applicable local, national and international laws and regulations, including those related to data privacy, international communications and exportation of technical or personal data. It may be illegal to download the information contained on our site in certain countries and we and our affiliated companies disclaim all responsibility if you download any information from our site in breach of any law or regulation of the country in which you reside.

5. User identification code

You will be provided with a user name and password to access our site. You must treat this information as confidential and you must not disclose it to any third party or allow any third party to access our site using your user name or password. You agree to notify us immediately if you suspect any unauthorised use of our site or of your user name or password.

6. Termination and suspension of access to our site

We reserve the right to deny you access to our site, or immediately to suspend or terminate your access to our site, or to disable any user name or password (whether chosen by you or allocated by us) at any time (in our sole discretion).

7. Liability for use of our site

Access to our site is permitted on a temporary basis and we reserve the right to withdraw or amend the service we provide on our site without notice. We do not accept any liability if for any reason our site is unavailable at any time or for any period.

The information and any opinions contained on the site are subject to change, are for background purposes only and are not to be relied upon as advice or interpreted as a recommendation. The information and opinions contained in our site have been compiled, or arrived at, by us from sources believed by us to be reliable as at the date of publication. However, we, our affiliated companies and other third parties connected to us do not accept any responsibility for any reliance which is placed by any visitor to our site, or by anyone who may be informed of any of its contents, on any information or opinions which are expressed herein and, to the extent permitted by law, expressly exclude all conditions, warranties, representations, undertakings and other terms which might otherwise be implied by statute, common law or in equity.

We, our affiliated companies and other third parties connected to us hereby expressly exclude any liability and responsibility arising from any reliance placed on such materials and information by any visitor to our site, or by anyone who may be informed of any of its contents, for (i) the accuracy, validity, timeliness, merchantability or completeness of, any information or data (whether prepared by us or by any third party) for any particular purpose or use or that the information or data will be free from error and (ii) any direct, indirect or consequential loss or damage of any kind incurred by any visitor to our site, or by anyone who may be informed of any of its contents, in connection with our site or in reliance on the information or opinions contained in it, or in connection with the use, inability to use, or results of the use of our site or any websites linked to it or materials posted on it. This does not affect our liability for any loss or damage which cannot be excluded or limited under applicable law and does not exclude or restrict any duty or liability that we have to our customers under the regulatory system in the United Kingdom.

The internet is not a completely reliable transmission medium and neither we nor any of our affiliated companies accept any liability for any data transmission errors such as data loss or damage or alteration of any kind or for the security or confidentiality of information transmitted across the internet to or from us or any of our affiliated companies. Any such transmission of information is entirely at your own risk. This does not exclude or restrict any duty or liability that we have to our customers under the regulatory system in the United Kingdom.

Should you leave our site via a link contained within our site and view content that is not provided by us, you do so at your own risk. We provide links only as a convenience and without liability. In particular, and without limitation, you understand and agree that the ability to link to another web site and the fact that a link exists does not mean that we endorse or guarantee such site, the site sponsor or the site contents. The content which you access via such links will not have been developed, checked for accuracy, or otherwise reviewed by us. We make no guarantees or representations as to, and shall have no liability for, any electronic content delivered by any third party, including, without limitation, the accuracy, subject matter, quality, sequence or timeliness of any electronic content. Your reliance on any information contained on any site reached through a link shall be your own responsibility. When you leave our site, unless otherwise indicated, you will be subject to the terms of use and privacy policies of the new web site which you are visiting. If you reached our site via a link, please be advised that the ability to link to our site and the fact that a link exists does not mean that we necessarily endorse, support, sanction, encourage, verify, or agree with the comments, opinions, or statements posted on the web site from which you linked to our site (the “Linking Site”). We are not responsible for any damages or losses arising from any delays, defects or omissions that may exist in the services, information or other content provided in the Linking Site. We make no guarantee or representation as to, and shall have no liability for, any content on any Linking Site, including, without limitation, the accuracy, subject matter, quality, sequence or timeliness of any such content.

8. Indemnity

You agree to indemnify, defend, and hold harmless us, our affiliates and our officers, partners, employees, and agents 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 breach of the terms of use and/or access to or use of this site.

9. Intellectual property rights

We are the owner or the licensee of all intellectual property rights in our site, and in the materials published on it. Those works are protected by laws and treaties around the world. All such rights are reserved. You may use the materials on our site and download and reproduce them in hard copy for your own reference only. Such materials may not otherwise be reproduced, distributed, stored in a data retrieval system or transmitted, in any form or by any means (electronic, mechanical, photocopying, recording or otherwise) without our prior written consent. Nothing on our site should be construed as granting any licence or right in relation to any of our trademarks or those of our affiliated companies or any third party.

10. Severability

If any specific term or condition of these terms of use is determined by a court of competent jurisdiction to be invalid, void or unenforceable, that determination shall not affect the validity of the remaining provisions of these terms of use. Headings used in these terms of use are for convenience, are not substantive and shall not be used to interpret or construe any of the provisions contained in these terms of use. When used in these terms of use the words “includes”, and “including” shall be deemed to be followed by the phrase “without limitation”.

11. Material Interests

We and our partners, officers and/or employees may have holdings in the investment funds referred to on this site and may otherwise be interested in transactions that you effect in those funds.

12. Your personal data

We may collect and process the following data about you in accordance with the terms of use:

(A) information that you provide by filling in forms on our site, including information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services;

(B) if you contact us, we may keep a record of that correspondence;

(C) we may ask you to complete surveys that we use for research purposes, although you do not have to respond to them; and

(D) details of your visits to our site and the materials and information that you access, for the following purposes:

a. to ensure that content from our site is presented in the most effective manner for you and for your computer;

b. to provide you with information, products or services that you request from us or which we consider may interest you, where you have consented to be contacted for such purposes;

c. to allow you to participate in interactive features of our service, when you choose to do so;

d. to determine your suitability to be granted access to our site; and

e. to notify you about changes to our services.

13. Disclosure of your personal data

We may disclose your personal data to our affiliated companies, agents and contractors (including to parties located outside the European Economic Area) for the purposes stated above. We may also disclose your personal data to third parties (including to parties located outside the European Economic Area):

(A) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

(B) if COMAC Capital LLP or its assets are acquired by a third party, in which case personal data held by it about its clients may be one of the transferred assets;

(C) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or

(D) in order to enforce or apply our terms of use and other agreements or to protect the rights of COMAC Capital LLP, our customers, or others.

By using this site, you consent to processing of your personal data in accordance with our terms of use and you warrant that all data provided by you is accurate.

14. Cookies

Cookies are small text files which are placed on the computer of a website user to provide the website operator with information about use of the site. We use Google Analytics cookies to collect information, in an anonymous form, about how visitors use our site and to prepare reports for statistical analysis. The information collected includes the number of visitors to the site, where visitors have come to the site from and the pages that they have visited. We use the information to help us improve the site and users’ experience of it.

By accepting these website terms of use you consent to the use of these cookies for these purposes.

15. Law and variation

These terms of use and any non-contractual obligations arising from or connected with them shall be governed by and shall be construed in accordance with English law. English courts will have exclusive jurisdiction over any dispute arising from, or related to, use of our site (whether arising out of or in connection with contractual or non-contractual obligations) (“proceedings”) and it is a condition of using our site that you waive any objection to proceedings in such courts on the grounds of venue or that proceedings have been brought in an inconvenient forum, although we retain the right to bring proceedings against you for breach of these terms of use in your country of residence or any other relevant country.

We may revise these terms of use at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we made, as by using our site you acknowledge that you have accepted any such amendments.

16. Entire agreement

These terms of use shall form the entire agreement between you and us in relation to your use of our site.

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