Information under the Swiss Financial Services Act

Please note that Spring Equity Partners SA ("SEP") is subject to the Swiss Financial Services Act (“FinSA") when providing financial services to you. Accordingly, this information is provided to you so as to meet the information requirements set out under FinSA.

General information and regulatory status

SEP is registered in Switzerland under the number CHE-348.049.957 and has its registered office at Place du Molard 3, 1204 Geneva, Switzerland.

SEP is a Financial Services Provider pursuant to FinSA. SEP is not prudentially supervised by the Swiss Financial Market Supervisory Authority (“FINMA”).

Financial Services offered, including market offer taken into account

The financial services provided to you by SEP can be either categorized as:

1. acquisition or disposal of financial instruments according to Art. 3 lit. c ch. 1 FinSA. Provided SEP does not, in that context, provide you with personal recommendations on transactions with financial instruments (investment advice), SEP is not required to assess the appropriateness and suitability under FinSA;
2. receipt and transmission of orders in relation to financial instruments according to Art. 3 lit. c ch. 2 FinSA. Provided SEP does not, in that context, provide you with personal recommendations on transactions with financial instruments (investment advice), SEP is not required to assess the appropriateness and suitability under FinSA; or
3. provision of personal recommendations on transactions with financial instruments (investment advice) according to Art. 3 lit. c No. 4 FinSA.

Risk Information

Dealings with financial instruments involve opportunities and risks, including the risk of loss of principal. It is important to know and understand these risks before availing yourself of a financial service. For further information, please consult the brochure Risks Involved in Trading Financial Instruments of the Swiss Bankers Association at www.swissbanking.ch.

Fee Information

The provision of financial services may attract fees payable to SEP or a third party. SEP will inform you about any such fees before concluding a contract.

Remunerations from third parties

SEP does not receive any third-party remunerations (i.e., retrocessions or rebates). No fee distribution agreements nor agreements governing non-cash benefits (retrocessions in the form of soft commissions) are in place. SEP ensures that all soft commissions and all services remunerated through soft commissions directly or indirectly benefit the Client.

Ombudsman office

You always have the option to initiate mediation proceedings before an independent Ombudsman office to seek to settle any issue with SEP. SEP is affiliated with ("[FINSOM]"), a free and neutral information and mediation agency. In general, the Ombudsman office only gets actively involved after SEP received and has had an opportunity to respond to a written client complaint.

FINSOM may be contacted at:

Client Advisers Register

SEP's Client Advisers are registered in the Client Advisers Register managed by Association Romande des intermédiaires financiers, Rue de Rive 8, CH-1204 Geneva (https://arif.ch/registre-des-conseillers-a-la-clientele/) authorized by FINMA in accordance with Art. 31 para. 1 FinSA.

Rules of conduct / conflicts of interest

SEP complies with the applicable FinSA rules of conduct, namely, the duties of information, care, loyalty, documentation and accountability. It takes all necessary measures to prevent conflicts of interests in its business dealings and protect you from disadvantages potentially arising thereof. Where a conflict of interests cannot be avoided, this will be communicated openly to you, and any further measures will only be carried out with your consent. Nevertheless, please be aware that, SEP being a boutique Financial Services Provider, some of its Officers or Employees may fulfil various duties within the company.

Data protection

SEP is acting as a data controller as under the Swiss Federal Act on Data Protection ("FADP"). As such, SEP is collecting and processing personal data according to the FADP in order to provide the Financial Services agreed upon and listed under section 3 of this letter. Data collected and processed by SEP may be disclosed to third party providers of SEP, which are located in Switzerland. Such providers may include, but are not limited to: service providers, , financial institutions and other professional services providers relevant to the Financial Services listed under section 3 of this letter.

If you wish to obtain further information on the means and purpose of data processing related to the Financial Services under section 3, please do not hesitate to contact us under the following email address: info@spring-equity.com

Contact Details

In case of questions, kindly contact info@spring-equity.com or call +41 22 577 66 51.