Pursuant to Article 165 of the Regulations adopted by Consob Resolution No. 20307/2018 (the “Intermediary Regulations”), the following information is provided about Mr. Flavio Moretto (henceforth the “ADVISOR”) and the services performed by him.

The information contained in this Document must be provided to the client or prospective client before the client is bound by an agreement for the provision of investment advisory services or otherwise prior to the provision of such services.

The recipient of this document is urged to read the following before making any decision about entering into an investment advisory agreement.

The ADVISOR is available to provide further information about the nature and characteristics of the investment advisory service.

1. INFORMATION ABOUT THE ADVISOR

First and Last Name: Flavio Moretto

Domicile: Via Piave, 7 – 72024 Oria (Brindisi)

Office: Via Piave, 7 – 72024 Oria (Brindisi)

Website: www.fmorettoconsulting.com

E-mail: info@fmorettoconsulting.com

PEC: flavio.moretto@legalmail.it

Phone and fax: +39.0831.8456861 mobile: +39.320.3308159 / +44.7871.190311

Registered by resolution No. 1918 of 04.05.2022 in the CFA section of the Single Register of Independent Financial Advisors

2. LANGUAGE USED

The Client may communicate with and receive documents and information from the ADVISOR in the Italian language.

3. METHODS OF COMMUNICATION USED

The sending of letters, information notes, statements, any notifications and any other written statements or communications, including changes in the information contained in this Document, where not otherwise provided for by law or by the contract, will be made to the Client with full effect at the address indicated at the time of signing the contract or communicated subsequently in writing.

The Client may elect, at the time of signing the contract relating to the advisory service or by subsequent communication in writing, to receive the information by means of non-paper durable medium and, in particular, by e-mail. To this end, the Client will indicate a valid e-mail address accessible only to him/her and agrees to keep it active (or communicate in writing a different valid e-mail address) until 14 months after the termination of the contract.

Communications and/or any notifications to the ADVISOR shall be made by the Client to the ADVISOR’s home address or by certified mail to the above addresses.

Sending of recommendations by the ADVISOR and confirmation of the execution of transactions by the Client may be made by the following means:

– mail (registered letter A/R)

– hand delivery

– communication platforms via the Internet with a user specifically designated by the ADVISOR

– ordinary electronic mail, to the address indicated in the contract

– certified electronic mail (PEC), at the address indicated in the contract

– fax

4. REGISTRATION IN THE REGISTER PROVIDED FOR IN ART. 18 BIS OF LEGISLATIVE DECREE 24.2.1998, NO. 58

It is hereby declared that the ADVISOR is registered in the section of the register provided for in Article 18 bis of Legislative Decree 24.2.1998 (TUF) maintained by the Supervisory Board provided for in Article 31, paragraph 4 of the aforementioned Decree, by resolution of 1/12/2018 n 962

The name and contact address of the Body are: Organismo di vigilanza e tenuta dell’albo unico

of Financial Advisers (OCF) via Tomacelli 146 – 00186 Rome

Tel: 0645556111 Fax: 0645556107

Website: www.organismocf.it

5. REPORTS ON THE PERFORMANCE OF THE ADVISORY SERVICE

The ADVISOR shall send to the Client the following reports on the performance of the consulting service:

– within 30 days after the end of each calendar quarter/semester a report containing the composition and performance of the Portfolio;

– within 60 days after the end of the calendar year, a statement containing (a) an updated statement indicating the reasons according to which the Portfolio corresponds to the Client’s preferences, objectives and other characteristics, (b) the recommendations provided during the reporting period (c) in aggregate form, the costs and charges of the Service provided and the Financial Products and services recommended.

6. POLICY ON CONFLICTS OF INTEREST

Pursuant to Article 177 of the Intermediary Regulations, the ADVISOR has adopted a Conflicts of Interest Policy aimed at:

– identify, with reference to the investment advisory service, the circumstances that generate or could generate a conflict of interest that could harm the interests of one or more clients;

– define the procedures to be followed and the measures to be taken to prevent or manage such conflicts.

The procedures and measures adopted shall be designed to identify and prevent conflicts of interest that may arise between the ADVISOR the Client or between the Client and other clients of the ADVISOR at the time of the provision of the Service that is the subject of this Agreement, in order to prevent such conflicts of interest from adversely affecting the Client.

The ADVISOR where the measures taken are not sufficient to avoid, with reasonable certainty, the risk of harming the Client’s interests, will clearly inform the Client in a durable medium of the general nature and/or sources of potential conflicts of interest arising from the recommendations provided, as well as the measures taken to mitigate the associated risks, so that the Client can make an informed investment decision.

The Client may request further analytical details on the conflict of interest management policy from THE ADVISOR at the contact details given above

7. ACTIVITY PROVIDED AND MANNER OF PERFORMANCE.

The ADVISOR performs the investment advisory service referred to in Article 1, paragraph 5, letter f) of the TUF, consisting of “the provision of personalized recommendations to a client, at his or her request or at the initiative of the service provider, regarding one or more transactions relating to financial instruments.”

Specifically, the service provided by the ADVISOR has as its object:

1. the analysis of the allocation of the client’s overall Portfolio and the assessment of the efficiency of the products held;
2. the possible reformulation of the asset allocation of the portfolio and the financial instruments and products held on the basis of the information provided by the client;
3. the periodic assessment, on an annual basis, of the adequacy of the Portfolio

The personalized recommendations provided to the Client in the execution of the service may relate to a wide range of financial instruments that can be traced to the following categories listed in Annex 1, Section C of the TUF

1. Securities.
2. Units and shares of CIUs.

Personalized recommendations may also cover financial products other than financial instruments, such as financial products issued by insurance companies and financial products issued by banks. It may also recommend portfolio management and order receipt and transmission services.

At the Client’s request, recommendations may relate to the ancillary services referred to in Article 1(6) of the TUF.

The provision of non-personalized recommendations is not envisaged.

The aforementioned advisory activity is aimed at both retail and professional clients

In the performance of the activity, the ADVISOR has no obligation to update the recommendations given to the Client and to notify the Client of losses incurred on the instruments recommended.

The Client is free not to execute the investment/disinvestment transactions recommended in execution of this contract.

The Service may also be provided by the ADVISOR at a location other than his/her domicile.

The ADVISOR is not authorized to execute the transactions recommended to the client, who may execute them through the intermediaries qualified (banks, SIM, SGR) within the scope of investment services and activities provided by them.

As remuneration for the performance of the advisory service, the Client is required to pay the ADVISOR and a fee commensurate with the content and value of the service.

In the absence of an unambiguous way of quantifying the fee it may vary depending on the complexity and size of the assets under advice, the objectives and risk profile of the client and in general by the time the ADVISOR will devote to the analysis and study on the concrete case. Therefore, the ADVISOR undertakes to submit to the prospective Client, after the latter has provided him with the necessary information summarized above, in good time before he is bound by an agreement for the provision of the advisory service, a customized fee estimate. Method and timing of payment will be indicated in the said estimate

The fee paid by the Client constitutes, by legal provision and by contractual obligation, the ADVISOR’s sole form of remuneration for services rendered to the Client; the ADVISOR is prohibited from receiving fees (incentives) from third parties.

The ADVISOR is required by professional ethics to be independent with respect to the issuers of the recommended financial products, as well as with respect to intermediaries licensed to perform investment services within the scope of which the Client performs the recommendations.

In the provision of the advisory service, the ADVISOR may not hold funds or securities belonging to clients.

The Client and the ADVISOR may possibly agree that the ADVISOR has a proxy to view the Client’s investments at banks or financial intermediaries or asset management companies that the Client uses, without any authorization to operate. They may also possibly agree that the said investment firms send directly to the ADVISOR the information on the transactions executed by the Client.

For more information on the contents of the advisory service and the obligations of the ADVISOR and the Client, please refer to the investment advisory agreement that must be signed prior to the performance of the service.

8. PERIODIC ASSESSMENT OF SUITABILITY

In the performance of the investment advisory service, the ADVISOR shall provide the Client with recommendations in relation to investment or divestment transactions that, if executed, would allow the suitability of the Portfolio with respect to the Client’s profile reconstructed on the basis of the information provided through completion of the Questionnaire submitted to him/her prior to the conclusion of this contract or on the occasion of any subsequent updates.

In particular, the ADVISOR verifies that the recommended transaction:

– corresponds to the Client’s investment objectives, including the Client’s risk tolerance;

– is of such a nature that the Client is financially capable of bearing the risks associated with the investment consistent with the Client’s investment objectives;

– is of such a nature that the Client possesses the necessary knowledge to understand the risks involved in managing his/her portfolio.

The ADVISOR shall conduct a periodic assessment of the adequacy of the Portfolio on an ANNUAL basis.

The adequacy assessment is conducted to enable the advisor to act in the best interest of the client. It is therefore essential that the Client, by completing the Questionnaire submitted to him/her by the ADVISOR, provide correct and up-to-date information concerning:

– his investment knowledge and experience regarding the specific type of product or service;

– his financial situation, including his ability to sustain losses;

– his investment objectives, including his risk tolerance;

– his sustainability preferences.

The Client is required to notify the ADVISOR of any updates to the information.

The above information enables the ADVISOR to understand the essential characteristics of the Client and to recommend to the Client financial products and investment services that are appropriate with particular reference to the Client’s risk tolerance, ability to sustain losses, and sustainability preferences; in the event that the Client fails to provide the information stipulated in the Questionnaire, the advisory service cannot be provided.

The Client should make himself aware that incorrect or untrue answers may compromise the reliability of the suitability assessment and decrease his level of protection.

The ADVISOR is required to refrain from making recommendations if none of the financial products and investment services are suitable for the Client.

9. INTEGRATION OF SUSTAINABILITY FACTORS.

Pursuant to Article 165 paragraph 1 letter h-bis of the Intermediary Regulations, in the process of selecting the financial instruments subject to the investment advisory service, the ADVISOR shall integrate an assessment regarding environmental, social and governance sustainability factors in order to ensure that the various products and instruments can only be recommended to clients who express sustainability preferences compatible with the characteristics of the instruments themselves.

Since the advice given by the ADVISOR concerns the financial portfolio as a whole, the assessment of sustainability factors is carried out at the portfolio level. This means that, as a whole, the portfolio should be aligned with the client’s sustainability preferences, although it is possible that, for reasons of risk management or achieving the client’s objectives, some individual instruments used may not be individually aligned with the client’s preferences.

The assessment of environmental, social and governance sustainability characteristics is carried out, depending on the type of instrument/product according to the information declared by the issuer under current regulations or using external assessment models (ratings) and/or analyses carried out internally.

10. OTHER PROFESSIONAL ACTIVITIES PERFORMED BY FLAVIO MORETTO

Flavio Moretto performs the following activities in addition to investment advisory services:

– Advising on the assessment and coverage of pension integration needs.

– Advice on identifying and quantifying household risks

– Counseling for personal and family financial planning

– Counseling for family succession planning

The above activities while personalized do not have specific financial instruments or financial products as their subject matter.

The performance of the above-mentioned activities is governed by a specific contract, separate from that relating to the investment advisory service, which provides for the payment of a fixed or variable fee agreed from time to time with the client, commensurate with the content and value of the activity provided.

The above activities are not subject to the supervision of Consob and the Body, nor to the supervision of other Authorities.

11. PROPOSED INVESTMENT STRATEGIES

In performing the advisory service, the ADVISOR is not oriented to certain categories or a specific range of financial instruments.

The ADVISOR does not propose standardized investment strategies but evaluates for each Client the most appropriate strategy, taking into account the Client’s investment objectives, risk tolerance, and financial situation, including the Client’s ability to sustain losses.

ACF DISCLOSURE

The Client may appeal to the Arbitrator for Financial Disputes (ACF), established at CONSOB, for the out-of-court settlement of disputes between investors (other than professional clients) and autonomous financial advisors and financial advisory firms referred to, respectively, in Articles 18-bis and 18-ter of the TUF, , relating to the latter’s breach of the obligations of diligence, fairness, information and transparency in the exercise of the activity regulated by Part II of the TUF, including disputes covered by Regulation (EU) No. 524/2013. Disputes involving the request for sums of money in an amount exceeding five hundred thousand euros do not fall within the scope of the Arbitrator’s operations. Excluded from the Arbitrator’s cognizance are damages that are not an immediate and direct consequence of the intermediary’s breach or violation of the obligations described above and those that are not pecuniary in nature.  The right to appeal to the ACF is indispensable and always exercisable, even in the presence of clauses in the contract devolving disputes to other out-of-court settlement bodies.

For more information refer to the website – https://www.acf.consob.it/