TERMS AND CONDITIONS

You are connected to the website of Generali Investments Europe S.p.A. Società di gestione del risparmio, the Asset Management company of Generali Group with its registered office at 34132, Trieste, 4, via Machiavelli, Italy, registered at the Albo delle Società di Gestione del Risparmio in the UCITS Section, under no. 18 and in the AIF section, under no. 22 and subject to the direction and coordination of Generali Investments Holding S.p.A..

ACCESS TO THE WEBSITE

Visitors of this website shall read carefully the present notice before going any further. Visitors consulting Generali Investments Europe S.p.A. Società di gestione del risparmio Internet website pages agree having read, understood and accepted the content of the present disclaimer. Visitors that do not agree with this disclaimer are required to leave this website.

By accessing this website, Visitors acknowledge having the skills and competence to use this website. The site is available in several languages, however English is the official language.

It is the responsibility of any person connecting to this website to comply with the law of the country in which he/she is resident. That person will bear any direct or indirect consequences resulting from non-compliance with the legal and regulatory requirement. Generali Investments Europe S.p.A. Società di gestione del risparmio cannot under any circumstances be held liable for such violation.

INFORMATION

All material information disseminated on this website is provided solely for purposes of information. This information is published without any guarantee of completeness or accuracy and has no legal, accounting or fiscal value as such.

This website aims to present the activity of asset management of Generali Investments Europe S.p.A. Società di gestione del risparmio. The information provided herein does not constitute in any manner an offer or solicitation to buy or sell any financial instrument.

The various information available on this website, particularly in relation to undertakings for collective investment in transferable securities (UCITS) managed by Generali Investments Europe S.p.A. Società di gestione del risparmio, shall in no way constitute an offer to subscribe or redeem Units of UCITS.

The information available on this website stems from sources considered reliable by Generali Investments Europe S.p.A. Società di gestione del risparmio. However, Generali Investments Europe S.p.A. Società di gestione del risparmio cannot be held responsible for the use of this information and any financial consequences that would arise therefrom.

In no way does this website claim to be a substitute neither for the reader’s personal deliberations nor for his technical and professional knowledge. Hyperlinks to other Internet resources are used at the visitor’s own risk.

PRIVACY AND COOKIES POLICY

Generali Investments Europe S.p.A. Società di gestione del risparmio (hereafter ‘Generali Investments’) have always attached utmost importance to confidentiality, protection and safety of information, particularly personal data concerning their customers and people who get in touch with Generali Investments.

This section outlines the methods used to administer this site with regard to the processing of users’ personal data. Pursuant to Art. 13 of Legislative Decree 196/2003 (Personal Data Protection Code), this information is also provided to subjects interacting with the services provided over the Internet by Generali Investments (Data Controller).

Information is provided for and applies to Generali Investments Web sites only (www.generali-investments.com). It is not applicable to any other Web site linked to the Generali site.

Visitors to the website are not required to provide any personal data. Data Users are required to provide personal data only if they want to get in contact with us or ask for advice. In such cases -totally voluntary – Data Users are required to read the Information as established by the Law and to provide only data strictly necessary to handle their requests.

In compliance with the existing privacy legislation, Generali Investments have adopted a specific policy, as described below.

We are pleased to provide useful information on the methods of active and passive collection of information concerning subjects/means interacting with this Web site, as well as on the security measures taken by Generali Investments.

While browsing an Internet site, collection of information without a user’s explicit registration or active role is technically viable. This type of collection is referred to as “passive collection”. A description is given in particular of the methods of use of IP addresses, permanent or session cookies, Internet tags, navigation information, including the possibility to opt out of them and the relevant implications.

With regard to passive collection of information, the services provided on this Web site:

• Do not use IP address (Internet Protocol Addresses) to collect information. However, IP addresses are stored in navigation information.
• Use navigation data as aggregate data for statistical purposes only.
• Use Session and Permanent Cookies only to improve browsing, not for statistical purposes. It is possible to disable the use of cookies. This depends on the browser. In this case surfing may not be equally easy.
• Do not use Internet tags.

With regard to active collection of information, the services offered on www.generali-investments.com apply the following policy:

• E-Mail: Data received by e-mails sent to the Web site are used to reply requests only. This data are stored for statistical purposes only and to check whether there are any precedents. Names may be included in specific Mailing List only if expressly requested by Data Users wishing to receive certain documents (press releases, financial statements, etc.) on a periodical basis.
• Registration: To access a number of services, Data Users are required to fill in a specific form. This information is used to reply to the sender’s request and to provide requested services only.
• Forums: If the site includes forums, specific conduct rules will be set out. Data will not be used for any other purpose.

According to applicable law, all Data Users can at any time exercise their rights of access in order to know what personal data are held by Generali Investments, their sources, how they are used and where they are stored. Data Users shall also be entitled to request Generali Investments to update, correct any inaccuracy or delete the data and object to the use of personal data for the purposes of marketing or market or opinion research by contacting the Data Processor under Section 7 of Legislative Decree 196/2003: Organization Structure, Viale Silvio d’Amico 40, 00144 Roma, fax 06.50573400 – privacySGR@generali.com .

Privacy Data Processors

This website is available in several languages, however English is the official one. Then visitors accept the delivery of this website in English if other languages are not available.

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:

a. Investment Firms or other investment firms;
b. Credit institutions;
c. Insurance companies;
d. UCITS and UCITS management companies;
e. Pension funds and their management companies;
f. Other financial institutions authorized by a Member State or regulated under Community legislation or the national law of a Member State;
g. Commodity dealers and ‘locals’ on exchanges;
h. National governments and their corresponding offices, including public bodies that deal with public debt;
i. 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:

(i) an entity authorized or regulated to operate in the financial markets, such as:

(a) Credit institutions;
(b) Investment Firms;
(c) Other authorized or regulated financial institutions;
(d) Insurance undertakings;
(e) Collective investment schemes and management companies of such schemes;
(f) Pension funds and management companies of such funds;
(g) Commodity and commodity derivatives dealers;
(h) Locals;
(i) Other institutional investors.

(ii) 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.

(iii) 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.

(iv) 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.