AML Policy

1. Introduction

This summarized Conflict of Interest Policy ("the Policy") is provided to you (our Client or Potential Client) in accordance with the Law on Investment Services, Exercise of Investment Activities, Operation of Regulated Markets and Others Related Matters Law 144 (I) / 2007, as subsequently amended from time to time (“the Law”), according to which Scala Capital (“the Company”) must take all reasonable measures to detect and avoid conflicts of interest.

The Company undertakes to act honestly, fairly and professionally and in the best interest of its Clients and comply, in particular, with the principles established in the previous legislation when providing investment services and other ancillary services related to said investment services.

The purpose of this document is to establish the Company's approach to identifying and managing conflicts of interest that may arise during the course of its normal business activities. Additionally, this document identifies circumstances that may give rise to a conflict of interest.

2. Scope

The Policy applies to all its directors, employees, any person directly or indirectly linked to the Company (hereinafter, Related Persons) and refers to all interactions with all Clients.

3. Identification of Conflicts of Interest

When the Company deals with the Client, the Company, an associate or other person related to the Company may have an interest, relationship or agreement that is material in relation to the Transaction in question or that conflicts with the interests of the Customer.

While it is not feasible to precisely define or create an exhaustive list of all relevant conflicts of interest that may arise, based on the current nature, scale and complexity of the Company's business, the following list includes circumstances that constitute or may give rise to a conflict of interest that carries a material risk of damage to the interests of one or more clients, as a result of the provision of investment services:

Identify the different types of conflicts that may arise in the course of the provision of its Services, and whose existence may damage or damage one or more interests of the Clients, takes into account, as minimum criteria, the question of if the Company itself or a Related Person or a person directly or indirectly linked by control to the Company, is in any of the following situations, as a result of the provision of investment services or otherwise:

4. Procedures and controls to manage conflicts of interest

In general, the procedures and controls that the Company follows to manage identified conflicts of interest include the following measures (the list is not exhaustive):

5. Customer consent

In the event that the Company cannot face a conflict of interest situation, it must revert to the Client.

6. Disclosure of information

If during the course of a business relationship with a Client or group of Clients, the current organizational or administrative arrangements / measures are not sufficient to avoid or manage a conflict of interest related to that Client or group of Clients, the Company will disclose conflicts of interest before undertaking new business with the Client or group of Clients.

7. Modification of the Policy and Additional Information

The Company reserves the right to revise and / or amend its Policy and arrangements whenever it deems it appropriate without prior notice to the Client. If you need more information and / or have any questions about conflicts of interest, send your request and / or questions to info@scalacp.com.