Commitment Policy

XYence Capital SGR SpA has not adopted a Commitment Policy pursuant to Article 124-quinquies of the TUF, as the Management Regulations of the UCITS under management do not, in principle, provide for investments in companies with shares admitted to trading on a regulated market Italian or another member state of the European Union. It will be the SGR’s responsibility to draw up and publish a Commitment Policy should the conditions arise in the future (eg establishment of UCIs with a focus on companies listed on regulated markets or amendments to the Management Regulations of UCITS in place regarding investment in companies listed on regulated markets).

Arbitrator for Financial Disputes

XYence Capital SGR SpA adheres to the Arbitrator for Financial Disputes (ACF), established by CONSOB with resolution no. 19602.

The Arbitrator has jurisdiction over disputes relating to the violation by the Intermediary of the obligations of diligence, correctness, information and transparency in the exercise of the activity governed by part II of the Consolidated Law on Finance (TUF), including cross-border disputes. and the disputes covered by EU Regulation no. 524/2013.

On the other hand, disputes involving the request for sums of money for an amount exceeding Euro 500,000, those concerning damages that are not immediate and direct consequence of the non-fulfillment or violation by the intermediary, remain excluded from the competence of the ACF. the obligations of diligence, correctness, information and transparency envisaged for the exercise of the activities regulated in part II of the TUF, as well as those relating to damages that are not of a financial nature.

The right to appeal to the Arbitrator (ACF) cannot be waived by the customer and can always be exercised, even in the presence of clauses for the devolution of disputes to other out-of-court settlement bodies, contained in the investment contracts governing the relationship. between the customer and the Intermediary.

Any customer complaints will also be evaluated in light of the guidelines inferred by the Arbitrator (ACF). In the event of failure or partial acceptance of such complaints, the Customer will be provided with adequate information about the methods and times for submitting the appeal to the Arbitrator (ACF) at CONSOB.

For any further need for further information regarding the Arbitrator for Financial Disputes, please refer to the website www.acf.consob.it

ESG Policy

Disclosure pursuant to Article 3 of EU Regulation 2019/2088 (policies on the integration of sustainability risks)

According to the scope of application of the Regulation, “sustainability risk” means an event or condition of an environmental, social, or governance nature that, upon occurrence, could cause a significant negative impact on the value of the investment. XYence Capital SGR SpA

Privacy Policy

Information on the processing of personal data pursuant Art. 13 of the 2016/679 EU regulation and of the current national law.

XYence Capital SGR SpA (hereinafter “XYence”), as “Owner” of the data processing, provides some information about the use of personal data pursuant to art. 13 of Regulation (EU) 2016/679 (the “GDPR Regulation”) and of the current national legislation on the protection of personal data (together with the GDPR Regulation, the “Privacy Law”).

Identity and contact details of the Data Controller of personal data

The Data Controller of personal data is the company XYence, the contact details of the Data Controller are:

e-mail: privacy@xyence.vc

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