FINSA DISCLOSURES

Graian Capital Management SA

In accordance with art. 8 et seq. of the Swiss Financial Services Act (“FinSA”), the following summary regarding Graian Capital Management SA and its activities is provided:

A. Company Information

Name: Graian Capital Management SA
Address: Via Ferruccio Pelli 1, 6900 Lugano, Switzerland
Phone: +41916301490
E-mail: info@graian.ch
Website: www.graian.ch

Supervisory Authority

Graian Capital Management SA is licensed as a manager of collective assets by the Swiss Financial Market Supervisory Authority (“FINMA”), which also acts as its supervisory authority.

Name: Eidgenössische Finanzmarktaufsicht FINMA
Address: Laupenstrasse 27, 3003 Bern, Switzerland
Phone: +41313279100
E-mail: info@finma.ch
Website: https://www.finma.ch/en/

Audit Firm

Graian Capital Management SA is audited and reviewed by the auditing company PKF Certifica SA both in terms of supervisory law and in terms of obligations.

Name: PKF Certifica SA
Address: Piazza dell’Indipendenza 3, 6900 Lugano
Phone: +41919111111
E-mail: gianluca.ambrogini@pkfcertifica.ch
Website: www.pkfcertifica.ch

Ombudsman

Graian Capital Management SA is affiliated with the independent ombudsman of the Ombud Finanza Svizzera, which is recognized by the Federal Department of Finance. Disputes concerning legal claims between the customer and the financial services provider should be settled by an ombudsman’s office, if possible, within the framework of a mediation procedure.

Name Ombudsman: Ombud Finanza Svizzera
Address: Boulevard des Tranchées 16, 1206 Geneva
Phone: +41228080451
E-mail: contact@ombudfinance.ch
Website: www.ombudfinance.ch

B. Information on the Offered Financial Services

Graian Capital Management SA provides portfolio management, management of collective investment schemes and investment advice services for institutional and professional investors as defined in the FinSA.

For further information on the various investment strategies, the managed collective investment schemes, the investment process, general risks, specifications, and operating procedures, please refer to the relevant information on this Website or reach out to Graian Capital Management SA. Graian Capital Management SA does not guarantee any yield nor performance of investment activities. The investment activity can therefore lead to an appreciation or a depreciation in value.

C. Client Segmentation

Financial service providers are required to classify their customers into a client segmentation according to the law and adhere to the respective code-of-conduct. FinSA provides for «retail customers», «professional customers» and «institutional customers» segments. For each customer, a customer classification is determined within the framework of the cooperation with Graian Capital Management SA. Subject to certain conditions, the customer may change the customer classification by opting in or opting out.

D. Information on General Risks Associated with Financial Instrument Transactions

The portfolio management, management of collective investment schemes and investment advisory services involve financial risks. Graian Capital Management SA shall provide all clients with the «Risks associated with Financial Instruments Transactions» brochure prior to the execution of the contract. This brochure can also be found at www.swissbanking.org.

Clients of the Graian Capital Management SA may contact their Account Manager at any time if they have any further questions.

E. Performance Disclosure

Past performance is not
indicative of future results. No representation or warranty, expressed or
implied, is made that the investment objectives will be achieved or that
similar performance will be attained in the future. The value of investments
may fall as well as rise, and investors may not recover the full amount
invested. The performance data does not take account of the commissions and
costs incurred on the issue and redemption of fund units. Graian Capital Management
SA has not taken any steps to ensure that the financial instruments eventually
referred to herein are suitable for any particular investor.

As a delegate Investment
Manager, we focus on investing in a very liquid portfolio of stocks. Our
liquidity guidelines imply that we will never hold a material stake in any
company, which leads us to determine that implementing an engagement policy
would not be proportionate to our role and mandate as Delegate Investment
Manager. We therefore provide this explanation in lieu of an engagement policy.

F. Further Disclosures

Further disclosures and information on the risks associated with offered services, costs, relationships with third parties and the market offer considered will be outlined in the course of the client onboarding process to the extent the right to receive such additional information has not been waived.