Browse our recent blogs, articles and papers below and sign up here for our regular newsletter. 

Win The Future | Why Asset Managers Need An ETF Strategy

Future is spelled with e-t-f

European ETF assets grew by an unprecedented 40% over 2017, accelerating significantly faster than the U.S. market for the first time on record. By the start of 2018, there were more than~$4.8 Trillion[1] of institutional and retail assets invested in ETF, much of that market share won from traditional mutual funds across the world.

Lipper data [2] underscores the scale of this subtle revolution, revealing that ETFs contributed an incredible €23.1 Billion to the overall €35 Billion of European fund flows in February, 2018. This land grab is all the more impressive considering that ETFs are dwarfed by the $47.4 Trillion of global assets that ICI [3] estimates are held in mutual funds– funds which have benefited from over 100 years of promotion and distribution in a market with historically high sales incentives, poorly informed consumers and few competitors.

European ETF AUM $US Bn

European ETF Asset Growth: Source ETFGI

Double-digit growth in the European ETF market is likely to be the ‘new normal’ as, after just 20 years of existence, ETFs find themselves superbly positioned to take advantage of a convergence of mega-trends that are driving changes in investor behaviour and the delivery of investment and wealth management solutions.

Smart asset managers are remodelling their businesses to adapt to these trends, recognising the important role that ETFs will play in determining future success and driving growth.

Trend 1 – Self Directed Investment / Empowered Investors

The first trend is the global shift towards self-directed saving and investing. In the UK alone, an estimated 1.8 million people have invested over £250 Billion in a Self Invested Personal Pensions (SIPP), many of which are ETF users as are investors in other personal savings products such as ISAs which can also include ETFs.

In yesteryear, investment products in Europe were predominantly distributed through banks and advisors who received kick-backs from fund providers. This incentivised the sale of high cost/ high commission products and put the interests of investors after the compensation of the salesperson. With less reliance on intermediated sales processes and greater autonomy in terms of fund selection, self-directed investors are looking at ETFs and liking what they see.

ETFs have characteristics that make them extremely appealing to self-directed investors and highly competitive compared to traditional mutual funds. ETFs are transparent and the underlying strategy and daily holdings can be easily understood and compared. 

This is in contrast to many mutual funds that only tend to reveal their top 10 holdings - and then often on a delayed basis. ETFs are often referred to as “democratic” investment products – the individual investor gets the same fund, the same information and the same trading optionality as an institution – so no special share classes, no special treatment, no information imbalances, just a level playing field.  

ETFs are also cost efficient and generally have low minimum investment thresholds, making them an accessible option for even small retail investors. As retail platforms and brokerages widen the availability of fractional trading – buying a portion of a share of an ETF to ensure all sums are invested at all times - barriers to participation are lowered even further. This inherent flexibility is further enhanced when trading is considered – ETFs are able to be traded intra-day enabling investors to quickly enter or exit positions without the hassle and delay of once a day pricing and a T+1 or T+2 settlement cycle.

Trend 2 - Regulation, Transparency & Icebergs

Regulators in Europe are keeping pace with increased ETF investor participation by improving the quality, timeliness and transparency of information available. For example, MiFID II reporting requirements enable investors to better understand the level of trading activity in European ETFs – for despite the ‘E’ in its name, the European ETF markets had seen about 2/3rds of trading occur in opaque, bilateral over-the-counter transactions.

Prior to MiFID II there was no requirement for European ETF trades to be reported, meaning investors could only view the tip of the iceberg relative to the real level of underlying activity. Under MiFID II European ETF new trade reporting requirements investors can finally gain a complete view of the breadth of ETF trading activity across all European venues.

This is an important development because liquidity begets liquidity. In this case, the comparative lack of transparency is often cited as a reason why some European investors had not participated in ETF markets on the scale they otherwise would.

It was a case of ‘information under load’. Deprived of an aggregated view of trading volumes, European investors perceived a far less vibrant, far smaller, less energized market than really exists. Unimpressed with the view, some looked across the Atlantic for the liquidity they could not see in Europe.

Revealing the breadth of European ETF market activity and volumes should mean that European investors have less incentive to look abroad for trading efficiency and can begin to repatriate liquidity back to domestic markets. Add to this the convenience of local trading hours and European-listed UCITS ETFs should stack up well versus their US cousins which don’t start trading until the European afternoon.

Trend 3 - Fees & Value

As individual investors take more responsibility for their own portfolios, they are understandably focussed on costs, fees and value. The move towards “all-in” fee disclosure under MiFID II is predicted to make it easier for both institutional and retail investors to understand and compare fund charges. This is likely to be a boon for ETFs that are typically priced at far lower levels than traditional funds with equivalent exposures. For example, according to Hargreaves Lansdown, the Virgin FTSE All-Share Tracker Fund has a net ongoing charge of 1%, in contrast the Vanguard FTSE UK All Share Index ETF, which provides exactly the same exposure, at an ongoing charge of just 0.08% [4].

With the information to compare the costs of core portfolio exposures such as FTSE 100, MSCI Emerging Markets or S&P 500 on an applesto-apples basis, investors can judge the most cost-effective means to obtain the exposure they want and switch to the option that provides the greatest value for money.

Why buy an apple for £1 when you can buy one from the next stall for 10p?

Intense media coverage of asset management fees has led many investors to examine the attritional impact of high fees on long-term portfolio returns – a few extra basis points in fees can cost £100,000’s over an individual’s lifetime investment journey and £1,000,000’s of assets to an institutional portfolio. If investors were confident that these fees represented good value, there wouldn’t be an issue, but more awareness of active under performance and benchmark hugging has meant that many investors are declining to pay for consistent failure or expensive tracking. To paraphrase Churchill, “Never has so much been paid to so few by so many for so little result.”

Industries like telecoms, utilities, media, airlines and fashion are already easy to cost compare - it’s fast and straightforward to find the best price for a broadband package, set of golf clubs or a LHR-JFK flight. All things being equal apart from price, do you care if you fly BA or Virgin? Many travellers say no – just get me there safely, on time and at the best price. Investment products will increasingly be judged and selected in a similar way. This is great news for managers with unique IP and strong track records, worse news for the closet trackers and performance laggards. 

With more product choice than ever, European ETFs provide a range of low-cost core building blocks, thematic twists and active strategies to build a huge range of portfolios. ETFs are superbly positioned to be big winners in an age where value-for-money is under the spotlight and comparisons between investment products are straightforward to perform.

Trend 4 - Technology & The Distribution Revolution

“Etfs Continue To Take Market Share Away From Other Products, And Firms Will Either Have To Launch Etfs Or Create Other Investment Vehicles Which Are Competitive With The Performance, Tax Efficiency, And Costs Of Etfs”

Pwc, Etf 2020: Preparing For A New Horizon. 

Across Europe and the majority of the developed world, Millennial's are poised to be the recipients of the largest generational wealth shift in history - inheriting the assets of their baby boomer parents. With trillions of dollars preparing to change hands within the next generation, asset managers who seek to remain competitive will need to understand the expectations of Millennial investors.

The Millennial generation do not shop like their parents did, they do not consume media like their parents did and they will not invest like their parents did. They are used to a personalised ‘on-demand’ world where immediacy and responsiveness are valued and where purchasing decisions are informed and influenced by online peer reviews and a broad range of expert voices. Intermediated products from high-cost, low-service providers are ill-suited to the browsing and selection behaviours of this demographic - this may be why in 2017, more than 50% of Millennial investors said ETFs were their investment of choice [5]. 

As a new generation emerges that values simplicity, ease of use and immediacy, technological advancements are bringing ETFs to a wider audience in a way that aligns with their needs. ETFs are now widely available on European retail brokerage platforms, bank D2C platforms and mobile trading apps. ETF model portfolios and fractional trading have made it easier for investors to begin building a diversified portfolio – often at a very competitive cost compared to traditional funds and portfolio services. 

New companies are also emerging to provide packaged ETF-based solutions for a new generation of investors. Retail brokerages, ROBO [6] advisors and round-up payment cards are increasingly providing ETF-based model portfolios and wealth management services. These next generation asset allocators are growing in importance - there are now close to 100 ROBO advisors in Europe and many are now ETF-only, leveraging the inherent tradability, transparency and cost-effective exposure that ETFs offer. 

Not "Should I Launch?", But "How Do I Launch?"

This convergence of trends means that asset managers adopting a ‘business as usual’ frame of mind stand to lose the future. Without an ETF offering their products risk becoming irrelevant to the next generation of investors and unfit for use in modern distribution technologies – the Wall Street equivalent of the VHS rental store in the age of Netflix. The end result of such lack of vision will be watching their asset base drained off by more forward-looking and nimble competitors. 

The largest asset managers understood the ETF opportunity early on- 17 out of the top 20 largest asset managers in the 2017 IPE survey already offer ETFs with others preparing to launch products in the near future. The 2017 EY Global ETF survey gave further reason to expect a more diverse and competitive ETF industry, reporting that 67% of respondents believed that most asset managers will provide some type of ETF offering by 2022 [8].


 Ipe Rank Company  Offers ETFs? Offers Active ETFs? 
 1  Blackrock  Yes Yes
 2 Vanguard Yes Yes 
 3 State Street Global Advisors Yes Yes
 4 Fidelity Yes Yes
 5 BNY Mellon    
 6 JP Morgan Yes  Yes
 7  PIMCO Yes Yes
 8 Capital Group    
 9 Prudential Financial Yes Yes
 10 Goldman Sachs Asset Management Yes  
 11 Amundi Yes  
 12 Legal & General Yes (via Canvas)  
 13 Wellington Management  Yes (via Virtus)  
 14 Northern Trust Yes (via Flexshares) Yes
 15 Nuveen Yes  
 16 Natixis Yes Yes
 17 Invesco Yes Yes
 18 T Rowe Price
 19 Deutsche Asset Management  Yes  
 20 AXA Investment Management Yes  


There are fewer and fewer active strategies that cannot be replicated in an ETF format and all but the most illiquid asset classes such as physical real estate are within reach of ETF issuers. This means we are likely to see more active ETFs, including non-transparent ETFs, come to market with ‘active-like’ fee structures that include performance fees or high water marks. Asset managers need to develop their ETF strategy rapidly as it’s not far-fetched to imagine that almost all mutual fund strategies will have been translated into an ETF format within the next 15 years.

Active Managers & ETFs

The scale and rapidity of ETF growth is such that they have become a factor that fewer and fewer asset managers can afford to ignore. The question in many boardrooms has changed from “Should we launch ETFs?” to “How do we launch ETFs and what do we launch?” 

Asset managers considering launching ETFs may view ETFs as synonymous with ‘passive’ (index-tracking) investing. There is some justification for this idea as the majority of assets today still sit in plain-vanilla, market capitalization weighted equity ETFs - this is great for investors who want low-cost core beta and great for the funds who got to market early and gathered assets.

But perceptions are evolving and active managers are less likely to view ETFs as competitors, instead viewing them as a valuable technology for distributing investment ideas in a market characterised by changing regulation, technology and investor expectations. Active ETFs are nothing new - they have been available in the U.S. for over a decade and the European market is starting to move in the same direction with a flurry of active equity and fixed income strategies, previously available as mutual funds or separately managed accounts coming to market in an additional ETF format. 

It’s worth pointing out that many of the largest ETF issuers on both sides of the Atlantic have well-established active asset management businesses too. The lessons of the U.S. show that traditional active fund managers can be extremely successful in leveraging their existing research and product development capabilities to provide ETFs that sit alongside their active fund ranges and act as alternative distribution mechanisms for key strategies. 

These developments have helped ETFs to be re-understood as a universal fund distribution proposition, relevant to active and systematic asset managers, as opposed to a proxy for index investment. Indeed, asset managers increasingly see ETFs as way to extend and modernise their distribution strategy, breathing new life and extending accessibility of existing funds or flagship strategies in the modern digital fund distribution landscape. 

Three Routes to Market

For the asset managers asking “How do I launch ETFs?”, there are three options: 1) build their own business from the ground up 2) acquire an existing business or, 3) partner with a white-label platform. There are pro’s and con’s to each approach: 

Building a European ETF business from scratch can be a time consuming and expensive exercise –24 months or more are needed to establish a team, build a fund platform, perform product R&D, develop marketing strategies and formulate sales plans. There are also significant overheads to consider in terms of staff, office space and legal fees. All in, an asset manager could spend between £5-£10 Million before a penny of assets are raised. 

Asset managers that want to build their own business also face a steep learning curve in terms of a building a specialist ETF architecture and expertise required in capital markets, product management and distribution strategies – all of which function in a very different way to mutual funds. While companies with large scale and extensive resources may be able to commit to this level of investment, this route may not make sense for firms with fewer internal resources or those that want to launch a smaller ETF product range.

Many companies have launched ETFs in Europe and then failed to raise assets as they did not fully appreciate the specific complexities of European ETF distribution or believed they could sell ETFs in the same way as mutual funds – these often proved to be expensive and embarrassing mistakes. For these reasons, build-your-own is a high commitment, high risk and high cost approach that is open only to large companies with significant time and resources to commit.

Buying entry to the market is also likely to be a high commitment and high cost approach – on the assumption that a suitable target can be found. In Europe, there are few takeover targets remaining to make this route to market seem appealing or possible. Buying up a third-party fund range also comes with the potential difficulty of buying up products that could conflict with a managers’ core offering or future strategy. Reliant on chance and opportunity, this approach cannot be utilised by the majority of asset managers and does not provide capacity for many new entrants. 

If building is too expensive and buying too difficult then asset managers can look at a third option – full service white-label ETF platforms.

A white-label platform, like HANetf, can enable any asset manager to launch an ETF without having to build their own ETF business from scratch. By providing the complete regulatory, technological and distribution infrastructure necessary to bring funds to market, white-label platforms make it faster, more cost effective and simpler to launch ETFs, whilst retaining the brand identity and investment skills of the underlying asset manager. 

Almost any asset manager – indexed, systematic or active – can bring their investment IP to a white-label ETF platform to get a product launched, but it is important to note that not all white-label platforms provide the same combination of services. Some platforms merely provide the regulatory and operational infrastructure to manage ETFs. 

Other platforms, like HANetf, take a different approach, providing a comprehensive service that goes beyond launch to provide ongoing sales, distribution and marketing programs. With a full-service offering, asset managers do not need to establish their own platform, expert sales teams, capital markets relationships, service provider relationships or marketing programs and can focus on what they do best – developing and refining investment ideas.

Three Routes to European ETF Market Entry Compared

  Build-Your-Own  Buy  White-Label 
 Cost High - €10’s Millions High Cost-efficient
 Speed-to-market 1-2 years Variable 2-3 months
 Complexity High High Low
 Product Range Need to launch many ETFs to justify investment  Product range may not reflect purchase's core strategies Launch just one ETF or full suite
 Overheads Staff, office space, marketing Staff, office space, marketing Low annual fees


Embracing The Future

Asset managers who dismiss ETFs because “We are active and don’t do passive” are missing the point. The ETF is just a distribution technology for any investment style or strategy. ETF growth continues to be propelled by strong regulatory, demographic and structural tailwinds, with the European ETF market predicted to triple to $3 Trillion by 2020 [9]. Clearly, there is a significant fee-base for asset managers to win, retain or lose. 

Asset managers positioning themselves to compete for this growing fee base recognise that ETFs will be a core part of their future growth strategy, but understand the challenge is not just launching an ETF but creating a sustainable long-term and successful ETF business. 

Only the largest firms will be able to approach the complexity of the European ETF marketplace with their own in-house ETF offering and team. Some firms will lack the internal resources to create their own business while others may only want to launch a smaller number of ETFs for flagship strategies and funds and not have the scale to warrant the development of a standalone platform. The ETF opportunity is not just limited to the largest companies who can dedicate years of time and millions of dollars of investment in starting an ETF business. ETFs are democratic investment products and companies like HANetf are making it easier for asset and wealth managers of all shapes and sizes to participate in the growth of the market and better serve their clients by removing the structural, commercial and operational barriers to entry that they have encountered. 

As trillions of dollars of assets migrate towards ETFs, we believe that every asset manager needs an ETF strategy – now. 

Download the full whitepaper "Win The Future - Why Asset Managers Need an ETF Strategy" here

Tell us how we can help

Select Investor Type Please Choose one of the Following options to enter the site:

Individual Investor
Institutional Investor

Welcome to HANetf

To start your visit, you have read and accepted our terms and conditions:

HANetf Limited (“HANetf”), is an appointed representative of Mirabella Advisers LLP, which is authorised and regulated by the Financial Conduct Authority (“FCA”).

Our corporate website (referred to as the “Site”) is owned by HANetf. By accessing and using the Site you agree to be bound by all terms and conditions which are set out on the Site from time to time, which govern such access and use (the "Terms and Conditions").

Our company number is 10697042. Our registered address is City Tower,  40 Basinghall St, London EC2V 5DE.

This website is for information only. It does not provide investment, tax or legal advice or recommendations.

Use of this Website shall be governed by and construed in accordance with English law and any dispute arising in relation to this Website is subject to the jurisdiction of the English courts.

Distribution of Information:

The distribution of the information and material on this website may be restricted by law in certain countries. None of the information is directed at, or is intended for distribution to, or use by, any person or entity in any jurisdiction (by virtue of nationality, place of residence, domicile or registered office) where publication, distribution or use of such information would be contrary to local law or regulation, or would subject HANetf or any funds it markets to any registration or licensing requirements in such jurisdiction.

You must inform yourself about, and observe any such restrictions in your jurisdiction and by accessing this website you represent that you have done so. The information on this website is not for distribution and does not constitute an offer to sell or the solicitation of any offer to buy any securities in the United States to or for the benefit of any United States person (being residents of the United States or partnerships or corporations organised under the laws thereof). The funds on this Website have not been registered in the United States under the Investment Company Act of 1940 and interests therein are not registered in the United States under the Securities Act of 1933.

Liability & Indemnity:

HANetf is not responsible for the accuracy, completeness or reliability of any data, statistics, commentary or content in any media format on HANetf will not be held responsible for any financial losses incurred as a result of believing the content of materials on this website; or materials and content linked to from this website. Investors should read the Prospectus and KIID and take independent legal, tax and investment advice before investing in any fund.

If you do not comply with the terms and conditions of this website, you may not hold HANetf responsible for any liabilities, losses or damages derived from use of this website.

Risk Warnings:

Never forget that:

  • * The value of securities and funds and the income from them may go up and down and are not guaranteed
  • * You may not get back the amount you invested
  • * Don’t invest in anything based on past performance
  • * Exchange rate changes may impact investment performance
  • * Political actions may impact investment performance
  • * Changes in credit rating may impact investment performance
  • * Changes in tax policies may impact investment performance
  • * Applications to invest should be made on the basis of the relevant prospectus
  • * No materials available on constitute investment advice

Specific risk warnings are set out in the prospectus and the supplement for the relevant sub-fund:

Website user categorisation


The professional investor section of the website and its content is restricted to “Professional Investors” only (as defined below) and is not intended for retail or private investors.

By entering this website, you agree that you are an “Institutional Investor” as defined here: have read, understood and accepted the conditions.

In accessing the website as a Professional Investor you will be undertaking, warranting and representing to HANetf that you are a Professional Investor. Please note that HANetf will be acting in reliance upon your undertaking, warranty and representation and you shall indemnify us and hold us harmless against all claims liabilities, losses, damages, costs and expenses incurred or suffered by us by reason of any breach of such undertaking, warranty and representation.

As a matter of general policy HANetf will not conduct regulated investment activities with any person as a result of their receiving information from the website, unless agreed otherwise with a professional investor.


* Past performance is meaningless and should not be used to judge future performance of any security or fund. Opinions, commentary and estimates reflect a judgement at the date of publication and may not be accurate at the date of reading. Publication of content on does not mean the content piece reflects the opinions of HANetf, or its employees, directors or shareholders. HANetf opinions and estimates can change at any time, without notice.

* HANetf does not guarantee the accuracy, consistency, availability, believability or completeness of any data or materials on this website. HANetf may change any data or materials at any time, for any reason without notice.

* The price, value, yield and liquidity of any security or fund can go up and down and may be impacted by Currency Risks, Liquidity Risks, Political Risks, Credit Risks, Tax Risks and Market Risks. Professional advice should be taken before investing in any security or fund.

* HANetf does not guarantee the security of this website. You use this website at your own risk.

* HANetf may change the terms of use for at any time, for any reason, without notice.

Cookie Policy:

HANetf will use Cookies to collect data about your computer including browser type, IP address and operating system. HANetf will also monitor your use of , including what links you have clicked, what files you download and your behaviour on website pages. We do this to improve our services and serve you materials we believe are relevant to you, and to comply with local regulations. By clicking through, you agree to HANetf using cookies as described here. Please note that you can change your browser settings to delete cookies, but this may impact your experience on

Intellectual Property: All content on is the intellectual property of HANetf is subject to copyright with all rights reserved and may not be copied, shared, sold, licensed, posted, reproduced or changed without permission of HANetf.

HANetf has the right to change anything on this website without notice or reason.

This website contains numerous registered and unregistered trademarks belonging to the HANetf or our partners. If you are in doubt as to whether an item is a trademark of the HANetf or our partners, please contact us for clarification at the registered office.

Unless otherwise specified, this website and its content are owned by the HANetf, and may contain information, text, graphics, video, software, logos, and other materials ("Content") that are protected by copyright, trademarks, or other proprietary rights. No permission is granted to upload, copy, modify, post, frame, amend or distribute Content in any way without obtaining the prior written permission of HANetf. All intellectual property rights in any part of the world which subsist in the contents of this Website and which belong to HANetf save as expressly granted, hereby reserved Any third party licensor trademarks referenced herein are trademarks of such third party licensor and have been licensed for use by HANetf. The securities incorporating third party indexes are not created, sponsored, endorsed, recommended or promoted by such third party licensors and the licensors shall have any no liability in connection with the securities.

Linked Websites: HANetf may provide links to external websites on or in newsletters, publications, content or email communications.

Content on external websites is not controlled by HANetf and users access external Websites at their own risk. A link to a website does not mean HANetf believes, endorses or supports any opinions or information contained on that website.


Your use of this website may be monitored by HANetf or its service providers, and the resultant information may be used by HANetf for its internal business purposes or in accordance with the rules of any applicable regulatory or self-regulatory organisation.

Governing Law & Jurisdiction:

This legal notice and all issues regarding our Site are governed by English law and are exclusively subject to the English courts.


We will keep your information confidential and only use it within our group (which means our affiliated companies, successors and assigns), and only transfer it to third parties in the manner described in the below section labelled “Use of third parties”, unless we are under a duty to disclose or share your personal data in order to comply with a court order or other legal or regulatory requirement.

2.Personal Data

HANetf will use your personal data only for the purposes and in the manner set forth in this Privacy Policy which describes the steps taken to ensure our processing of your personal data is in compliance with the General Data Protection Regulation ((EU) 2016/679) ("GDPR") and any implementing legislation ("Data Protection Legislation").

How and why we collect personal data

HANetf will use your personal data only for the purposes and in the manner set forth in this Privacy Policy which describes the steps taken to ensure our processing of your personal data is in compliance with the General Data Protection Regulation ((EU) 2016/679) ("GDPR") and any implementing legislation ("Data Protection Legislation").

We will keep your information confidential and only use it within our group (which means our affiliated companies, successors and assigns), unless we are forced to share your personal data to comply with a court order or other legal or regulatory requirement.

The personal information we may collect might include your name, address, email address, company details and any other relevant information that may be included within correspondence. In addition, details of your visits to our website including (but not limited to) IP address, cookies, traffic data, location data, weblogs and other information related to what pages are accessed and when may be collected. Also, for legal reasons, in order to access our website, details of your investor type, and location will be collected, with such collection being carried out in compliance with the Privacy and Electronic Communications Regulations (“PECR”). This data would be collected to customise our users’ visits to our website.

If you are accessing sections of our website that are password protected or have entered the website through a link in an email, our website will identify you as an individual and may collect data including information about the pages you visit, the documents you download or other information to enhance and personalise your future interaction with our website.

Any information collected about you may be associated with other identifying information we hold.

HANetf will retain and process your personal data only when this is necessary to achieve our commercial or business objectives and to comply with our regulatory obligations. After careful consideration, HANetf has concluded the processing of personal data for the reasons mentioned shall be considered necessary, as there would not be another way of achieving the identified interest of the firm.

All information you provide to us is stored on secure servers. Information may be transferred, stored and processed by third parties. It may also be processed by staff operating outside the European Union (“EU”) who work for us or for one of our suppliers of services, such as data processors or providers of back up services. You should be aware that in territories outside the European Economic Area (“EEA”), laws and practices relating to the protection of personal data are likely to be different and, in some cases, may be weaker than those within the EEA. By submitting your personal data, you are agreeing to this transfer, storing or processing.

Such transfers outside the EU will only take place where either (i) the Commission has decided that such third country ensures an adequate level of protection; or (ii) we have provided appropriate safeguards, and on the condition that enforceable rights and effective legal remedies are available for you. If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services. By submitting your personal data, you agree to the potential transfer, storing and other processing described above. We will take all steps reasonably necessary to ensure that your personal data are treated securely and in accordance with this Privacy Policy.

3.Use of third parties

Communicating via the internet and sending information to you by other means necessarily involves your personal information passing through or being handled by third parties, but we do not sell or distribute without your permission your personal information to third parties for purposes of allowing them to market products and services to you.

We have also reviewed all key third party agreements where EU personal data is being processed to ensure they are GDPR compliant and that your rights described herein are being protected.

4.What safeguards we have in place

HANetf has security measures in place to protect the loss, misuse and alteration of the information under our control. As no data transmission over the internet can be guaranteed as 100% secure, we cannot ensure or warrant the security of any information you transmit to us and you transfer the data at your own risk. We endeavour to use appropriate security measures, including systems security, backups, business recovery and breach notification procedures, monitoring and testing procedures.

Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Site and accordingly any transmission is at your own risk. However, once we have received your information, we will use all appropriate procedures and security measures to try to prevent unauthorised access to or disclosure of your personal data.

5.What rights you have with regards to your personal data we process

You have the right to access your personal data and request a copy of the information held by us about you. You also have the right to ask for your information to be transferred to another organisation or to yourself. Where such requests are manifestly unfounded or excessive, we will inform you and we may charge a reasonable fee or refuse to respond to such a request.

You have the right to ask us not to process your personal data for marketing purposes. We will inform you if we intend to use your personal data for such purposes. You can exercise your right to prevent such processing by contacting us directly. You can also exercise the right and change your marketing preferences or restrict any specific uses of your personal data at any time by contacting us.

The accuracy of your information is important to us. We review the information we hold to ensure it is up to date and accurate. You have the right to correct any inaccuracies in the details we hold about you – if you change your email address or notice any other information we hold is inaccurate or out of date, please contact us. You have the right to obtain without undue delay the rectification of any inaccurate personal data concerning you.Your rights to access, rectify, erase or restrict your personal data stated above will be processed by HANetf usually within 30 days of receiving your request. However, HANetf may notify you within such timeframe of an increased time period to process your request and its reason. Where HANetf believes the request is unreasonable it shall notify you and refuse to process your request.


If you have any questions regarding this Privacy Policy and our privacy practices you can contact us via email at [email protected] or in writing to Compliance, HANetf, City Tower, 40 Basinghall St, London EC2V 5DE.

7.Contact information

If you believe your personal data has been processed by HANetf in a way that does not comply with GDPR, you have the right to lodge a complaint with us directly [email protected] or with a supervisory authority.

If you believe HANetf did not take action on a request you have sent; or informed you without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy, you have the right to lodge a complaint with a supervisory authority.