Our Policies

LEGAL POLICY

The access, navigation and use of this website are governed by and shall be construed in accordance with Luxembourg law. Any disputes arising out of the access or use of this website and/or the use of the information contained on this website shall be submitted to the competent courts of the district of Luxembourg City.

By entering into this website, you certify that you have read, understood and agreed to the terms set forth in this legal notice and warrant that you are  lawfully entitled under your jurisdiction to obtain the information regarding financial products which are available in this jurisdiction. If you consider that the information that follows can lawfully be supplied to you, please proceed.

COOKIES POLICY 

Effective as from 27/08/2021 

Generali Investments Partners S.p.A. Società di gestione del risparmio, Generali Insurance Asset Management S.p.A. Società di gestione del risparmio, Generali Investments Luxembourg S.A. and Generali Investments Holding S.p.A. (hereinafter “Generali Investments”) having its registered office in Via Machiavelli 4, Trieste, acting as data controller, intends to provide the users (hereinafter "you" or "your") of the website www.generali-investments.lu (hereinafter, the "Website") with the information on the use of cookies on the Website. 

Generali Investments may amend this Cookies Policy, from time to time, also as a consequence of any legal or regulatory changes. However, the updated version of this Cookies Policy will always be available on the Website, to be consulted by You. 

 

Definition 

Cookies are small text files (letters and/or numbers) containing groups of information stored in Your devices (e.g., computer, smartphone, tablet) every time they visit a website through a browser. At each subsequent visit the browser sends these cookies to the website which originated them or to another website. 

Cookies allow websites to store certain information in order to allow you to navigate online in a simple and fast way.  

Cookies are used for different purposes and have different characteristics. They can be distinguished according to the following criteria: 

a) on the basis of the entity which manages the cookie: 

(i) first-party cookies: these cookies are installed directly by the Company through the Website; 

(ii) third-party cookies: these cookies are installed through the Website by third parties other than the Company; 

b) on the basis of the time in which the cookie remains active: 

(i) session cookies: these cookies store the necessary information during the browsing session and are deleted immediately after the session expires, that is when the browser is closed; 

(ii) persistent cookies: these cookies are stored on your hard disk and the Website reads them each time you visit it again. A persistent cookie has a specific expiration date, after which it will cease to work. 

c) on the basis of the purposes pursued: 

(i) some cookies are necessary to allow you to use its features (so-called technical cookies). Other cookies are used to obtain statistical information, whether aggregate or not, on the number of users accessing the Website and on how the Website is used (so-called analytics cookies). Moreover, other cookies are used to track your profile in order to display on the Website advertisements that may be in line with your interests, as they are consistent with your tastes and consumption habits (so-called profiling cookies). 

Generali Investments can store cookies on your devices if they are essential to the operation of this Website, otherwise we need your prior consent to do so. 

Generali Investments Website uses technical cookies and both first-party and third-party analytics cookies. Therefore, the Website uses some non-essential cookies. Generali Investments do not do this to track individual users or to identify them, but mainly to gain useful knowledge about how the Website is used, so that we can keep improving it for our users. 

However, by changing the settings in the browser you use, you may prevent cookies installation. The setup of each browser is different and is explained in the relevant menu of the browser. To understand how to set cookies settings, you may consult the instructions of the providers of the most popular browsers, available at the following links: 

Alternatively, you may visit the website www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of desktop browsers. 

Types of cookies used on the Website 

  • Technical cookies 

Generali Investments uses first-party technical cookies for the sole purpose of allowing you to visit the Website and use its features. They can be further distinguished in: 

(i) navigation cookies: they guarantee the normal use of the Website and normally are session cookies, which are automatically deleted when the browser is closed; 

(ii) functionality cookies: they allow you to browse the Website on the basis of selected criteria (e.g., language or country of origin), in order to improve the services provided on the Website. These are persistent cookies, which remain on your computer even after the browser has been closed, until the expiration date of each cookie (typically from two months to two years) or until they are erased by you. 

Technical cookies are not used for purposes other than those described above. 

The Website uses the following technical cookies:

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  • Third Party Analytics cookies 

Google Analytics cookies are used on the Website. These cookies enable the collection of statistical information, only in an aggregated form, on the use of the Website, such as, for instance, the number of users accessing the Website and the pages visited more frequently. 

Google analytics cookies used do not allow the identification of individuals because the IP address associated to the cookie is anonymized before being sent to Google. The full IP address is never collected and stored on our and Google Systems.  

You can find below a list of the analytics cookies currently used on the Website: 

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  • Marketing Cookies 

Marketing cookies are used to track visitors to websites. The purpose is to present relevant and engaging advertisements to the individual user and therefore of greater value to third-party publishers and advertisers. 

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As provided by applicable laws, your prior consent is required for the installation of third-party analytics cookies. For this reason, when you access the Website a banner is displayed, informing that (i) third-party analytics cookies are used on the Website and (ii) by clicking on “Accept”, you consent to the use of such cookies.  

Should you give consent to the installation of cookies, we will keep track of such consent through a specific technical cookie. In this way, we will prevent you from visualizing the cookie banner during future visits of the Website. 

You may block the storage of analytics cookies at any time, without compromising your possibility to visit the Website. If you want to know how to block the storage of analytics cookies, you can read the information on third-party cookies by clicking on the links reported in the chart above. 

For more information also with regard to your rights and how to enforce them or how to contact us, please refer to our Privacy Policy

PRIVACY POLICY

IN ACCORDANCE WITH ARTICLES 13 AND 14 OF REGULATION (EU) 2016/679

1. Which company of the Generali Group will process Your personal data*?

Generali Investments Holding S.p.A., Generali Asset Management S.p.A. Società di gestione del risparmio and Generali Investments Luxembourg S.A. (hereinafter “Generali Investments” or “We”), with registered office in Trieste, Via Machiavelli n. 4, will process* Your personal data as Data Controller* in accordance with Regulation (EU) 2016/679 (hereinafter the “GDPR”).

If You wish to contact Us or exercise a right regarding the processing of Your personal data, You can use the following contact details:

  • Generali Investments Holding S.p.A., Via Machiavelli 4, 34132 Trieste or Piazza Tre Torri 1, 20145 Milan; Privacy.GIH@generali.com.

  • Generali Asset Management S.p.A. Società di gestione del risparmio, Via Machiavelli 4, 34132 Trieste or Piazza Tre Torri 1, 20145 Milan; Privacy.Genam@generali.com.

If You wish to submit any questions on the processing of your personal data to the Data Protection Officer or exercise a right, You can use the following contact details:

  • Generali Investments Holding S.p.A., Via Machiavelli 4, 34132 Trieste or Piazza Tre Torri 1, 20145 Milan, to the attention of the Data Protection Officer; DPO.GIH@generali.com.

  • Generali Asset Management S.p.A. Società di gestione del risparmio, Via Machiavelli 4, 34132 Trieste or Piazza Tre Torri 1, 20145 Milan, to the attention of the Data Protection Officer; DPO.Genam@generali.com.

Effective as from 01/01/2024 

This Privacy Policy provides users (hereinafter “You” or “Your”) of the website www.generali-investments.lu (hereinafter the “Website”) with the information on the processing of their personal data, collected by means of the Website, in the context of Your use of the Website and the services available on the Website, under Articles 13 and 14 of the GDPR.

Unless otherwise specified herein, this Privacy Policy does not apply to any other data referred to You, collected by Generali Investments by or through any other means, such as information collected offline and on other websites of the entities of the Generali group that You might access via any link found on the Website.

Generali Investments may provide You with further specific information on the processing of Your personal data, along with the relevant request of consent, if needed. This information may also be provided within other webpages of the Website, in case You should make specific requests to Generali Investments, by providing the latter with Your personal data. Those privacy information notices and consents will be respectively provided and obtained prior to the processing of these further categories of personal data. 

Generali Investments cares about the confidentiality, protection and safety of Your personal data. In order to help You in understanding this Privacy Policy, You can find a glossary on the last page of this Privacy Policy, which includes the definitions of the main terms used herein.

We strongly recommend You to carefully read this Privacy Policy before browsing through the pages of the Website.

We may amend this Privacy Policy, from time to time, also as a consequence of any legal or regulatory changes. However, the updated version of this Privacy Policy will always be available on the Website, to be consulted by You. 

2. How do We process Your personal data and what is the legal basis for the processing of this data?

Generali Investments will process Your personal data (as better identified in Section 4 below) to pursue the following purposes:

a) Ensuring the browsing of the Website, after having selected the criteria for navigation (e.g., investor typology and language) and accepted the relevant terms and conditions, and using the services offered through the Website, including the possibility of obtaining answers to the requests for information or assistance that You should submit to us (hereinafter "Contractual Purposes");

b) Complying with the obligations set forth by applicable laws, including responding to possible requests submitted to us by governmental authorities and supervisory bodies (hereinafter "Legal Purposes");

c) Based on legitimate interest, developing and improving the services offered through the Website, by carrying out statistics on the use of the Website (e.g., analyzing the most visited pages, etc.) and checking its functioning; and

d) Based on legitimate interest, establishing, exercising or defending of legal claims;

e) Based on legitimate interest, management and maintenance of the security of assets, also in order to prevent possible prejudices for Generali AM deriving from abusive access or illicit data processing, commission of crimes, etc., including checks, inspections and internal audits;

f) Based on legitimate interest, assessing the opportunity to proceed with any legal or structural changes to GenAM, mergers, demergers and other extraordinary transactions that may involve GenAM as a whole or partially (the purposes from let. c) to let. F) above are hereinafter jointly referred to as “Legitimate Interest Purposes”);

g) Based on your consent, inviting you to events, meetings, workshops, roundtables, congresses (including professional training), identified as of specific interest to you, organised and managed by the Italian entities of the Generali Investments Network, independently or in cooperation with other entities identified from time to time in the invitations (brochures and/or presentations) that will be previously mailed or delivered to you to allow you to register for the event (hereinafter, respectively, the “Event(s)” and the "Partner(s) in the Event”); executing complementary activities following your registration for the Event, such as, for example, activities related to the organisation and management of the Event itself; if you attend, using your personal images that may have been collected in the course of the Event for possible publication on different (paper, tape and/or digital) supports, or through other means of communication or media, including websites, portals and social networks present on the internet;

h) Based on your consent, sending you newsletters, publications, studies, survey results, market analyses or analyses of specific industries or businesses, and any other type of professional information material, identified as of specific interest to you, prepared or published by the Italian (and, in certain circumstances, foreign) entities of the Generali Investments Network, independently or in cooperation with other entities identified from time to time in the specific document (hereinafter, the “Publications” and “Publication Partners”, respectively).

Moreover, also on the basis of the legitimate interests, your personal data shall be processed for the following purposes:

i) carrying out customer relationship management, consisting mainly in tracing and managing the relationships and interactions that Italian and foreign legal entities of the Generali Investments Network, through the professionals belonging to it, develop with the ‘contacts’ of current and prospective clients, and any other persons/entities with whom/which Generali Investments Network professionals have developed business relationships, for the purpose of understanding their needs and expectations, improving services offered, developing new services based on the market’s requirements, as well as growing the business. For those purposes the personal information of ‘contacts’, including your personal information, will be entered into special data bases owned by or available to Generali Investments and will thus be made accessible to the other Italian and foreign entities of the Generali Investments Network. Where specific obligations of confidentiality or professional secrecy exist, as well as when there are particular reasons of expediency, your personal information will be made available, depending on the circumstances, solely to professionals of the Italian legal entities of the Generali Investments Network (excluding foreign entities), or solely to Generali Investments, i.e. solely to the members of the team of Generali Investments assigned to the specific professional engagement. In any case, it is agreed that you may be contacted, for customer relationship management purposes, only through the professionals who operate within the Italian legal entity of Generali Investments with which you have established the main relationship.

In case Generali Investments wishes to process Your personal data for purposes other than the ones listed above, Generali Investments will prior provide You with any required information under the GDPR, and collect Your consent, where needed. 

Generali Investments does not process Your personal data only based on automated decision-making processes. 

3. Why do We ask You to provide Your personal data?

a) The processing of Your personal data for Contractual Purposes (please see Section 2, let. a), above) is carried out to ensure your navigation, pursuant to art. 6.1, let. b) of the GDPR; it is mandatory, given that otherwise We would not be able to allow You to browse the Website or assist You in relation to Your requests. If you don’t want us to process Your Identification Data (as defined under Section 4, letter a), below), please do not send us a request of information.

b) The processing of Your personal data for Legal Purposes (please see Section 2, let. b) above) is performed to comply with legal and regulatory obligations to which Generali Investments is subject, pursuant to art. 6.1, let. c) of the GDPR; it is mandatory, as it is necessary to enable us to comply with applicable laws.

c) The processing of Your personal data for Legitimate Interest Purposes (please see Section 2, letters from c) to f) above) is based on our legitimate interests, pursuant to Article 6.1, let. f) of the GDPR, which have been adequately balanced with Your interests and rights, as the processing of Your personal data is carried out only to the extent it is strictly necessary to pursue such purposes. However, You may object to the processing of Your personal data, by following the instructions specified under Section 6 below, unless We have an overriding interest on further processing Your personal data or in case the processing of Your data is necessary to establish, exercise or defend of legal claims. 4. Categories of personal data processed

We will process Your personal data only to the extent necessary to achieve the above-mentioned purposes. In particular, We will process the following categories of personal data referred to You: 

a) Data voluntarily provided by You, by submitting to Us any requests for information or assistance by means of the Website or using Our contact details available on the Website. This data might include Your name, surname, address, occupation, job title, employer/associated company, phone number and email address, as well as any other information referred to You that You should provide to Us by requesting information or assistance; (hereinafter jointly referred to as “Identification Data”);

b) Browsing data relating to the use of the services on the Website made by You, such as Your IP addresses or domain names of Your devices, URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server and other parameters relating to Your operating system and computer environment (hereinafter jointly referred to as "Browsing Data"). This data is automatically collected by means of the cookies* installed on the Website, in accordance with Our cookie policy, which is available at the following link. The collection of the Browsing Data does not aim at matching this data with You and We process this data in aggregate form.

5. With whom do We share Your personal data?

Generali Investments will process Your personal data only to the extent that it is adequate, relevant and limited to what is necessary in relation to the purposes indicated under Section 2 above, by means of electronical and telematic tools as well as hard copies, in such a way as to ensure the security, protection and confidentiality of Your personal data.

In pursuing the purposes referred to in Section 2 above, We may disclose Your personal data to the following categories of recipients:

a) Third party suppliers and companies of the Generali group, to the extent that such entities provide assistance or consultancy services to Generali Investments, including but not limited to technological, accounting, administrative, legal and insurance services;

b) Governmental authorities and supervisory bodies whose right to access to Your personal data is set forth by applicable laws; and

c) To possible purchasers of Generali Investments and other entities resulting from mergers or any other operations affecting Generali Investments.

Your personal data will not be disseminated.

6. Where do We transfer Your personal data?

Where this is necessary to pursue the purposes indicated above (see Section 2 above), Your personal data may also be transferred abroad, both within and outside the European Economic Area.

In particular, Generali Investments’ activities may be supported by a computer network, cloud-based servers and other information infrastructures and technologies also provided by third parties.

In the event that, for technical and operational reasons, our suppliers are located in countries outside the European Economic Area which may not guarantee a level of protection of personal data equivalent to that provided within the European Economic Area, We will verify that the level of protection of personal data is adequately guaranteed through other measures, such as binding corporate rules, standard data protection clauses adopted by the European Commission or on the basis of specific exemptions provided for by the GDPR. Further information on the countries to which personal data are transferred and on the safeguards adopted can be requested by writing to DPO.GIH@generali.com.  

7. The rights You can exercise regarding the processing of Your personal data

According to Articles 15 et seq. of the GDPR, You have the following rights that You can exercise by contacting Our Data Protection Officer:

-        Right of access 

You may ask Generali Investments to access Your personal data in order to know, for example, which personal data referred to You Generali Investments is currently processing.

-        Right to rectification 

You may ask Generali Investments to rectify any personal data referred to You which should be inaccurate or incomplete. 

-        Right to erasure

You may ask Generali Investments to erase Your personal data when one of the following circumstances occurs:

  • Personal data is no longer necessary with respect to the purposes for which it was collected or otherwise processed;

  • You withdrew Your consent on the processing of Your personal data and Generali Investments cannot rely on other legal grounds to process Your data;

  • You have objected to automated decision-making and there are no overriding legitimate grounds for the processing of Your data, or You have objected to the processing of Your data for direct marketing purposes;

  • Personal data has been unlawfully processed by Generali Investments;

  • Personal data has to be erased for compliance with a legal obligation in Union or Member State law to which Generali Investments is subject; and

  • Personal data has been collected in connection with the provision of information society services, referred to in Article 8, paragraph 1, of the GDPR. 

-        Right to restriction 

You may ask Generali Investments to restrict how it processes Your personal data, and requesting only its storage, where one of the following applies:

·       You contest the accuracy of Your personal data, for a period enabling Generali Investments to verify the accuracy of Your personal data;

·       The processing is unlawful and You oppose the erasure of Your personal data and request the restriction of its use instead;

·       Generali Investments no longer needs Your personal data for the purposes of the processing, but this data is required by You for the establishment, exercise or defense of legal claims; 

·       You have objected to processing pursuant to the right to object and automated decision-making, pending the verification whether the legitimate grounds of Generali Investments override Yours. 

-        Right to data portability and Consent withdrawal

You may ask Generali Investments to transfer Your personal data to another company or organization and/or to receive Your personal data in a structured, commonly used and machine-readable format.

If You have granted your consent to the processing of Your data, You may withdraw such consent at any time, without prejudice to the validity of the processing carried out before the withdrawal of Your consent.

If Your personal data has been transferred outside the European Economic Area, You have also the right to obtain a copy of such data or the indication of where it has been made available.

Your rights can be exercised by contacting Generali Investments and/or the Data Protection Officer, by using the contact details indicated above (see Section 1 above). We will not charge You any cost for the tasks resulting from Your request, unless this request is manifestly unfounded or excessive, in which case We might charge you the related costs.

When You exercise Your rights, we might request personal information referred to You, in order to verify Your identity.

8. The right to object to the processing of Your personal data

You have the right to object to the processing of Your personal data and request the stop of the processing operations in relation to the processing of Your personal data that is based on Generali Investments’s legitimate interests (please see Section 2, letters from c) to f) above), by contacting Generali Investments and/or the Data Protection Officer.

9. The possibility to lodge a complaint with the competent Supervisory Authority

In case you noticed any irregularities in the processing of Your personal data, You have the right to lodge a complaint with the Garante per la Protezione dei Dati Personali, based on the modalities indicated at the following website:

https://www.garanteprivacy.it/home/diritti/come-agire-per-tutelare-i-tuoi-dati-personali.

You also have the right to lodge a complaint with the supervisory authority, of the Member State of Your habitual residence, place of work or place of the alleged infringements.

You can find Your national supervisory authority at the following website:*

 https://edpb.europa.eu/about-edpb/board/members_en

 10. How long do we retain Your personal data?

Your personal data will be retained only for the time necessary to pursue the specific purposes for which it was collected, as indicated within this Privacy Policy. In particular:

a) Your Browsing Data will be retained for no longer than seven days and will be erased immediately after being aggregated, except where governmental authorities and/or supervisory bodies should need such data to perform their duties;

b) Your user choices that allow you to browse the Website on the basis of selected criteria (e.g., language or country of origin), to improve the services provided on the Website, will be retained for no more than 2 years or until they are erased by you;

c) Your Identification Data will be retained for no more than 2 years, unless its retention for a longer period is required under applicable laws or to establish, exercise or defend legal claims.

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GLOSSARY

To help You in understanding our Privacy Policy, please find below the meaning of the main terms contained therein:

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, whether or not by automated means.

Personal data means any information relating, directly or indirectly, to a person (such as, for example, name, an identification number, location data, an online identifier, one or more elements able to identify the physical, physiological, genetic, mental, economic, cultural or social identity, etc.).

Special categories of data means the personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership as well as genetic data, biometric data where they uniquely identify a person, data concerning health or data concerning a person’s sex life or sexual orientation.

Data subject means the person whose personal data are processed.

Data Controller means the individual or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data (for example, the employer is the data controller in respect of its employees’ personal data since, with reference to the employment relationship, it decides the purposes and means of such processing). 

Data Processor means the individual or legal person, public authority, agency or other body which processes personal data on behalf of the data controller (for example, the company which provides the service of employees’ salaries calculation may be considered a data processor since it processes personal data on behalf of another company, the employer). 

Data Protection Officer means a person in charge for performing support activities for the company functions and control activities in respect of the processing of personal data. It is also in charge for cooperating with the Supervisory Authority and it represents the contact point, also for the data subjects, for any matters connected with the processing of personal data 

Garante per la Protezione dei Dati Personali is the Italian data protection supervisory authority.

Cookies are small text files that are sent to Your device (e.g. computer, smartphone, tablet), when You visit a website, where they are stored to be re-transmitted to the same website at Your next visit. If You wish to have more information about cookies, You can consult Our cookies policy.

TERMS AND CONDITIONS

You are connected to the website of Generali Investments Luxembourg S.A. (“Management Company”), a management company and alternative investment fund manager authorised, respectively, under Chapter 15 of the law of 17 December 2010 relating to undertakings for collective investment (the “2010 Law”) and the law of 12 July 2013, which manages undertakings for collective investment subject to Part I of the 2010 Law and other types of funds which qualify as alternative investment funds (together, the “Funds”).

Generali Investments Luxembourg S.A. is registered with the Luxembourg Trade and Companies Register under number B 188432 and is regulated by the Commission de Surveillance du Secteur Financier (CSSF).

Access to the Website

Before visiting this website, you shall carefully read the present notice. By visiting this website you agree to having read, understood and accepted the content of the present disclaimer. If you do not agree with the provisions contained in this disclaimer you must not use this website and refrain from accessing any pages of this website.

Applicable law and jurisdiction

The access to, visit to, and use of the website are governed by and shall be construed in accordance with Luxembourg law. Any disputes arising out of the access or use of this website and/or the use of the information contained on this website shall be submitted to the competent courts of the district of Luxembourg City.

By entering into this website, you certify that you have read, understood and agreed to the terms set forth in this legal notice and warrant that you are  lawfully entitled under your jurisdiction to obtain the information regarding financial products which are available in this jurisdiction. If you consider that the information that follows can lawfully be supplied to you, please proceed.

Information, Risks and Absence of Offer

All information disseminated on this website is provided solely for information purposes and does not constitute a recommendation or an advice. This information is published without any guarantee of completeness or accuracy and has no legal, accounting or fiscal value as such. The information contained on this website does not constitute in any manner an offer or solicitation to buy, sell or subscribe any financial instrument, product or service or an offer to subscribe or redeem units or shares of the Funds referred to on this website. The information contained on this website does not form part of any contract, nor can you rely on it for any contractual purpose.

Any investment in financial instruments or products that are mentioned on this website may involve risks and may therefore be unsuitable for certain investors. Any information provided on this website regarding investment risks shall not be construed as a complete and exhaustive presentation of existing and potential risks. Past performance is not 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.

Current tax reporting, levels and reliefs in respect of any investment made in the products mentioned on this website may vary and will depend on your personal circumstances.

Before investing in any of the Funds referred to on this website, it is imperative that you thoroughly read and understand the entire prospectus, the key investor information documents, if applicable, and that you review the latest financial report of the Fund. Investment in any of the Funds mentioned in this website should not be made without careful reference to such documents. Subscriptions will only be received and shares or units issued on the basis of a Fund’s current prospectus and latest audited annual report. Copies of each Fund’s current prospectus, latest audited annual report and, if applicable, key investor information documents are available on this website or may be obtained from the Management Company upon request.

Before investing in any of the Funds referred to on this website, you are requested to ensure that such Funds are authorized for trading in your own country of origin and you should inform yourself as to any foreign exchange restrictions or exchange control requirements that you might encounter under the laws of your country of citizenship, residence, or domicile and which might be relevant to the subscription, purchase, holding, redemption, conversion or disposal of the shares of the Funds referred to in this website.

You must rely on your own examination of the legal, taxation, financial and other consequences of an investment in any of the Funds referred to on this website including the merits of investing and the risk involved or consult your stockbroker, solicitor, accountant or other financial adviser in this regard. The Management Company does not provide investment advice.

Disclaimer of Warranty and Limitation of Liability

Although considerable care has been taken to ensure that the information contained on this website is accurate at the date of publication, all information disseminated on this website is provided solely for information purposes and is subject to change without notice. The Management Company makes no representation or warranty, express or implied as to the accuracy, completeness, timeliness and relevance of the information provided on this website. The Management Company therefore accepts no liability and shall not be held liable for any loss or damage of any kind , whether direct or indirect, arising out of or caused by the use of any part of the information provided on this website, including without limitation financial consequences that may arise from investments carried out on the basis of information provided on this website. All liability of the Management Company regarding omission or error contained on this website is also excluded. Moreover, the Management Company cannot be held liable for damages that result from information that is erroneous or illicit due, for example, to any dissemination of viruses, or to technical errors, connection interruptions, or fraudulent acts by third parties, notwithstanding the fact that the Management Company does everything necessary to ensure this website’s security and to control the information disseminated.

Links to Third-Party Websites

This website may have links to third party websites, which are not under the control of the Management Company. In this respect, the Management Company shall not be held liable for any content, service, product or material offered through any linked site. You will access to third party linked websites at your own risk.

COPYRIGHT

The information, layout, design, illustrations, trademarks and any other materials (the “Materials”) contained on this website are protected by intellectual property rights, which are the property of the Management Company, its affiliated entities or third parties. The Materials may be displayed and printed exclusively for your personal, non-commercial use, provided that you do not remove any intellectual property right or other notices therein. You agree not to transmit, alter, modify, reproduce, publish or sell the Materials contained on this website in whatever form, in whole or in part, and by whatever means  without the express prior written consent of the Management Company.

MIFID INVESTMENT PROFILES

For the purpose of this web-site, Institutional Investor indicates the MiFID category of Eligible Counterparties (ECP). This category receives the lowest level of protection under MiFID and it refers to an entity to which a credit institution or an investment firm provides the services of reception and transmission of orders on behalf of clients and/or execution of such orders and/or dealing on own account:

  1. Investment Firms or other investment firms;

  2. Credit institutions;

  3. Insurance companies;

  4. UCITS and UCITS management companies;

  5. Pension funds and their management companies;

  6. Other financial institutions authorized by a Member State or regulated under Community legislation or the national law of a Member State;

  7. Commodity dealers and ‘locals’ on exchanges;

  8. National governments and their corresponding offices, including public bodies that deal with public debt;

  9. Central banks and supranational institutions.

If such clients are provided with investment advice, they will be treated as Professional clients instead.

It is the responsibility to the subject that enters in the area of the web-site denominated “Institutional Investors” to verify its own quality and the belonging to such category.

For the purpose of this web-site, Professional Investor refers to the entities that are not classified as an Eligible counterparty according to MiFID but who possesses the experience, knowledge and expertise to make its own investment decisions and properly assess the risks.

In order to be considered as a Professional Investor, the client or prospective client shall be:

  • an entity authorized or regulated to operate in the financial markets, such as:

  • Credit institutions;

  • Investment Firms;

  • Other authorized or regulated financial institutions;

  • Insurance undertakings;

  • Collective investment schemes and management companies of such schemes;

  • Pension funds and management companies of such funds;

  • Commodity and commodity derivatives dealers;

  • Locals;

  • Other institutional

  • Large undertakings can also qualify as Professional Investors if they meet at least two of following size requirements on company basis:

  1. A balance sheet total of at least EUR 20 million;

  2. Net turnover of at least EUR 40 million;

  3. Own capital of at least EUR 2 million.

  • National and regional governments, public bodies that manage public debt, central banks, international and supranational institutions such as the World Bank, the International Monetary Fund, the European Central Bank, the European Investment Bank and other similar international organizations.

  • Other institutional investors whose main activity is to invest in financial instruments, including entities dedicated to the securitization of assets or other financial transactions. The entities mentioned above are considered to be professionals.

This category receives a lower level of protection than Retail clients

It is the responsibility to the subject that enters in the area of the web-site denominated “Professional Investors” to verify its own quality and the belonging to such category.

For the purpose of this web-site, Private Investor indicates the MiFID category of Retail clients. All the clients or prospective clients that do not fall under the classification of Professional Investors or Institutional Investors have to be considered as Private Investors according to this web-site.

This is the classification that offers the most protection and imposes the most requirements in terms of communication, disclosure and transparency.

It is the responsibility to the subject that enters in the area of the web-site denominated “Private Investor” to verify its own quality and the belonging to such category.

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