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Dear client,

In compliance with the terms established by the The Swiss Financial Services Act (LSerFi) which entered into force on January 1, 2020; Veco Invest SA will implement from January 1, 2022, all the behavioral and organizational measures necessary to comply with the requirements.  These measures aim to imaximise the investors' protection and aim to establish a common standard for all financial service providers in the provision of their services. To this end, in compliance with art. 8 LSerfi, we summarize the information required by law below.

Name, address and purpose of institute (hereafter referred to as ”the operator")
Veco Invest SA
Via Lavizzari 4
6900 Lugano, Svizzera
+41 (0)91 911 71 11
Veco Invest SA is a financial trust company that deals with asset management and financial advice.

Supervisory authorities
Our Institute is subject to the Financial Institutions law and the Financial Services law and is subject to the supervision of the Supervisory Body:
AOOS - Supervisory limited company
Via Landriani 3
6900 Lugano, Switzerland
+41 (0)91 940 40 00

Mediation procedure
For complaints against the Financial Intermediary and if it is not possible to find a solution by mutual agreement, you can contact the Ombudsman. This is the competent mediation body for our Institute, as well as a neutral information, conciliation body and free proc
Financial Services Ombudsman OFS
16 Boulevard des Tranchées 1206 Ginevra, Switzerland
Phone: +41 22 808 04 51

As a rule, the mediator is only activated following a written complaint from the client and the corresponding position taken by the bank.

Clients' classification (Art. 4 and 5 LSerFi)
The LSerFi requires clients to be divided into the following categories: private clients, professional clients and institutional clients. The classification is based on the client's individual financial situation, respectively on their knowledge level, experience and financial competence, or on the size of the company legally defined or by the presence of a professional treasury. Individuals and small and medium-sized enterprises are generally classified as private clients, while large companies, pension funds and financial intermediaries as professional clients. If the necessary conditions are met, the customer can submit a request to change the initial classification as a private customer. For this change, please contact your customer advisor. In fact, on the basis of the information in our possession, we can deduce that, except for written communications to the contrary, you have in any case been considered private customers pursuant to art. 4, para. 2, LSerFi, thus benefiting from the increased protection provided for private customers. It is hereby emphasized that, if you wish to be classified as professional clients pursuant to the LSerFi, you can subscribe to the opting out pursuant to art. 5 LSerFi [1]

[1]Private clients can be considered wealthy if the following conditions are met: having, through personal training and professional experience or comparable experience in the financial sector, the knowledge necessary to understand the risks of investments, as well as personal assets of at least 500,000 francs or have personal assets of at least 2 million francs.

Information on risks
Transactions with financial instruments are associated with opportunities and risks. It is therefore important to know and understand these risks before resorting to a financial service.   Following the introduction of the Financial Services Law and the Financial Institutions law, all asset managers and Trustees have been subjected to obligations that have highlighted and implemented greater investor protection. At the earliest opportunity, therefore, it will be our responsibility to review current risk profiles with customers and update your file if necessary.

Information on products
Con l’introduzione della LSerFi, nell’ambito dei rapporti contrattuali di gestione patrimoniale discrezionale il Gestore è With the introduction of the LSerFi, as part of the contractual relationships of discretionary asset management, the Operator is required to carry out a preventive analysis of the client's entire assets, as well as their propensity for risk; all in order to identify the most suitable investment strategy (Adequacy Test pursuant to art. 12 LSerFi). As part of the strategy identified, the Operator has full operational autonomy  If, on the other hand, financial instruments are recommended to private clients pursuant to the LSerFi on the basis of a contractual consultancy relationship, which are not shares or obligations, the Operator must carry out a prior analysis regarding the customer's knowledge of the individual product, as well as full knowledge of the risks associated with it, going so far as to actively advise against the product if the analysis were to give a negative result (Appropriateness test pursuant to art. 11 LSerFi). In these cases, the Operator must provide the private customer with the basic information sheet or any other possible document. Indeed, the basic information sheet contains simplified information on the characteristics, risks and costs of the product and allows for a comparison between the various financial instruments. In such cases and/or upon request it is possible to obtain the documents in paper format also through your customer advisor.

Conflicts of interest and economic constraints
The Company takes the necessary organizational measures to avoid that the interests of its collaborators [2] conflict with those of the customer and that those of its customers do not conflict with each other. In this regard, the customer acknowledges that the Company is part of Veco Group SA, to which the companies listed on the website belong. Veco Group SA encourages the sale of services between the different companies of the group, always in the  protection of the client's interests and for the satisfaction of their needs. This incentive is internal to the group and has no impact on the total expenses that the client pays to Veco Invest SA or other group companies.

In order to mitigate conflicts of interest, the following measures were taken:
The companies belonging to Veco Group SA are distinct from each other and totally autonomous with their own employees, local, bodies and distinct functions.The remuneration policy of the collaborators assigned to the management and the private choices of transactions on their behalf by all our employees and bodies do not influence the investment choices in the context of asset management.Compliance with the aforementioned measures is subject to verification by the internal and external control systems of our company.The selection of products is carried out in a preventive and impartial manner by a special Internal Committee with high technical skills and many years of experience in the sector. All third-party counterparties (in particular banks, offerers of investment funds or structured products, etc.) are selected on the basis of both quantitative (performance, volatility, liquidity, etc.) and qualitative (rating, investment process, reputation, etc.) criteria. Monitoring is constant both in the selection phase and throughout the entire duration of the investment. For this reason, the Operator signs agreements, conventions and contracts with the counterparties that exist upstream, regardless of the contract concluded with the customer. These agreements are one of the building blocks of our infrastructure and business model. The Operator would like to point out from now on that, among the counterparties, there is the company Bluestar Investment Managers SA which is partially owned by Veco Invest SA, with which the same aforementioned measures are applied.[2]These are the members of the top management, supervision and control body, members of the management body, shareholders with unlimited liability and persons with similar functions (art. 30 OSerFi).

Information on costs and retrocessions
From the foregoing, it emerges that the service has high quality standard, which certainly benefits the customer, but of course also has a cost proportionate to the same, which the operator has decided not to take over entirely to the customer. The price of the service, in fact, is determined on the basis of two elements: on the one hand the management fee agreed in the contract with the Customer which reflects very competitive levels of the market and, on the other hand, indemnities of various kinds that the Operator receives from part of third party counter-parties. These indemnities are the exclusive responsibility of the Operator until the maximum percentage indicated in the Management Mandate is reached. This parameter is based on the right to the agreed fee and regardless of the actual collection of the same. Generally, these benefits are recurring and are paid on a specified date, on a monthly, quarterly or annual basis.

The total of the indemnities received, therefore, whatever their nature, will never exceed as a whole the percentage agreed in the mandate, the calculation of which is based on the closing data as of 31.12 or on the closing data at the time of revocation of the mandate.

The allowances to date are:
- Bank retrocessions
- Investment funds retrocessions
- Structured products retrocessions
- Retrocessions on other types of products

All customers can at any time ask their consultant for a summary of the costs and retrocessions, pursuant to art. 16 LSerFi.

Data storage
Pursuant to art. 15 LSerFI financial service providers keep adequate documentation relating to the financial services agreed with clients and the information collected on the latter; the information referred to in art. 13 paragraph 2 LSerFi or the fact of having advised against a customer to use a service in accordance with art. 14 LSerFi; In addition, in the case of investment advice, financial service providers keep records of customer needs and the reasons for each recommendation that leads to the purchase or sale of a financial instrument. At any time, pursuant to art. 72 LSerFi, the Clients may request the delivery of a copy of their dossier and all other documents concerning them and that the financial services provider has drawn up as part of the business relationship.

Market offer considered for the choice of financial instruments
The financial institution selects the financial instruments for the Client from an unlimited range, without the obligation to favor those of some issuers.

Lugano, November 2021

Valid without signature

This model was developed on the basis of the Financial Services Law and the related Financial Services Ordinance known as at June 30, 2021. The judicial and regulatory practices that will be developed by the judicial authorities, FINMA, OV and mediation bodies remain reserved . Therefore, no responsibility is assumed for the content of the model, developed only to facilitate the organizational tasks of the supervised persons, but not in substitution of the obligations of the supervised parties of concrete analysis and definition of the needs and contents, to be carried out with professionals of their choice.