BRIEF DESCRIPTION ABOUT CONFLICTS OF INTEREST POLICY

In accordance with the provisions of art. 177 of CONSOB Resolution No. 20307 of February 15, 2018, CFI Independent Financial Advice by Fabio Pioli applies a policy of avoiding conflicts of interest between itself and the Client, of which it provides a brief description.

The Customer may at any time request a more detailed description of his choice on paper, other durable medium or via the website.

The circumstances potentially giving rise to conflicts of interest are identified, on the basis of the current and foreseeable dimensions of the activity carried out and the characteristics of the latter, in the following:

1) CONFLICTS GENERABLE BY OPERATIONS ON FINANCIAL INSTRUMENTS BY THE AUTONOMOUS FINANCIAL CONSULTANT

To prevent potential or actual damage to the Client from such circumstances, CFI establishes the following measures:

1) in the selection of recommendable financial instruments, only recommendable financial instruments that correspond to the liquidity criterion are selected

2) the financial advisor refrains from carrying out financial transactions on the same financial instrument recommended by the client / clients

3) a separation is established between the function of generating and sending recommendations, pertaining to the staff for which the generation and sending are not known in advance by the staff

4) it is forbidden for personnel to carry out financial transactions on their own account and to give prior notice in the event of an intention to derogate from this prohibition.

2) CONFLICTS GENERABLE FROM PROVIDING INFORMATION TO CUSTOMERS IN THE CUSTOMER CARE FUNCTION

To prevent potential or actual damage to the Client from such circumstances, CFI establishes the following measures:

1) the continuous supervision by the independent financial advisor on every communication made by the staff assigned to the Customer Service, does not allow any unsupervised communication to be made

2) any form of relationship of any nature with financial intermediaries or other subjects that could jeopardize the independence of the relevant subject is prohibited

3) specific provision is made to refrain, in the communication, from formulating recommendations and personal opinions on the adequacy of a recommendation or a financial instrument, or financial index, on the suitability to generate a profit or a loss and any forecast regarding the future performance of indices or financial instruments or any other element connected to them.

4) it is specifically forbidden to entertain any type of relationship that could generate a conflict of interest towards customers and the activity of the independent financial consultant.

5) there is no form of remuneration to relevant persons linked to the economic results of the independent financial consultant or to the increase in the business or in the number of customers or the greater / lesser operations of the same.

6) the staff is precluded from knowing the methods that the consultant uses for the purposes of analyzing and controlling the risk related to the production of the recommendations or the selection criteria of the recommended values,

7) the staff is barred from accessing the PC through protection with a specific password. where the software that conveys and records the recommendations is installed

8) personnel are prevented from accessing company e-mail boxes through protection with a special password.

9) Should any unlawful communication occur, the financial advisor would act on the spot, in his role of controller, to intervene in the communication with the client and remove the confusion in the communication.

If any damage had been caused or there was a risk that damage was caused to the client by any illicit behavior referred to in the previous points, the financial advisor would take steps to repair or mitigate it by providing appropriate recommendations to the client and at the same time informing the client that the mechanisms for protecting the ACF (Arbitrator for Financial Disputes) and his right to submit complaints and reports to the OCF (Supervisory Body and keeping the single register of Financial Advisors) are at his disposal.

3) CONFLICTS GENERABLE BY COMMERCIAL OR OUTSOURCING AGREEMENTS OF SERVICES STIPULATED BY THE AUTONOMOUS FINANCIAL ADVISER

To prevent potential or actual damage to the Client from such circumstances, CFI establishes the following measures:

1) the independent financial advisor does not enter into any agreement that could potentially be harmful to the interests of clients.

4) CONFLICTS GENERABLE BY THE MARKETING FUNCTION OR THE PROMOTION OF THE SERVICE

To prevent potential or actual damage to the Client from such circumstances, CFI establishes the following measures:

1) the staff to be assigned to marketing is adequately trained