Impressum - Finanz Konzept AG

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FINANZ KONZEPT AG
Fraumünsterstrasse 27
8001 Zürich
Switzerland

Tel.: 0041 44 204 34 64
Fax.: 0041 44 204 34 60

UID: CHE‑115.511.830
CH-ID: CH02030349042

Disclaimer

By accessing this website and its pages and the products, services, information, tools and materials contained or described therein (“Website”), you acknowledge that you understand and agree to be bound by the following terms of use:
-Ownership of the website, trademark rights and copyrights
Finanz Konzept AG and other brand names on this website are trademarks and/or service marks. Unless otherwise indicated, all content on this website is copyrighted by Finanz Konzept AG. Finanz Konzept AG reserves all rights (in particular copyright and trademark rights) to all content on this website and will use all legal means to enforce such rights. Nothing on the website may be construed as granting any permission or right to use any images, registered trademarks or logos. Downloading, copying or printing individual pages and/or parts of the website is only permitted for personal use. However, this does not transfer any rights to the contents of the website to you. However, this does not transfer any rights to the contents of the website to you.

-Offer, solicitation and distribution restrictions
Nothing contained on this website constitutes an offer or solicitation to buy or sell products and services such as, without limitation, securities, financial instruments, other investment products or investment advisory services. The services, securities and financial instruments described herein may not be appropriate for you or in the country in which you reside. The fact that users access this website does not make them customers of Finanz Konzept AG. Users of this website should consult their own independent financial advisors before making any investment decision based on the information published herein, and none of the information published herein constitutes investment, legal, tax or business advice of a general or specific nature.

-Disclaimer and cautionary note regarding forward-looking statements
The opinions and estimates expressed on this website reflect our views at the time of publication and do not constitute investment, legal, tax or business advice of a general or specific nature. The information on this website may contain statements about future developments. Furthermore, we and third parties on our behalf may make statements in the future that include statements about future developments.

By their nature, statements about future developments involve general and specific risks and uncertainties; and there is a risk that predictions, forecasts, projections and results described or implied in forward-looking statements will not occur. We caution you that several important factors could cause results to differ materially from the plans, objectives, expectations, estimates and intentions expressed in such statements. These factors include (1) market and interest rate fluctuations, (2) global economic strength in general and that of the countries in which we operate in particular, (3) the ability of counterparties to meet their obligations to us, (4) the effects of and changes in fiscal, monetary, commercial and tax policies and currency fluctuations, (5) political and social developments, including war, public unrest, terrorist activities, (6) the possibility of exchange controls, expropriation, nationalization or seizure of assets in the countries in which we operate, (7) the ability to maintain sufficient liquidity and access to capital markets, (8) operational factors such as system failures, human error or improper implementation of procedures, (9) actions taken by regulators in connection with our business and practices in one or more countries in which we operate, (10) the impact of changes in laws, regulations or accounting standards or methods, (11) competition in geographic and business areas in which we operate, (12) the ability to recruit and retain qualified personnel, (13) the ability to maintain our reputation and promote our brands, (14) the ability to increase market share and control costs, (15) technological changes, (16) the timely development and acceptance of our new products and services and users’ perception of the overall value of those products and services, (17) acquisitions and the ability to successfully integrate the acquired businesses, (18) the adverse resolution of litigation and other events, and (19) our success in managing the risks associated with the foregoing.

As a precaution, we would like to point out that the above list of material factors is not exhaustive.

-Risk information
Past performance is not indicative of, and does not provide any guarantee of, future performance, and no representation or warranty, express or implied, is made as to future performance. Investments are associated with risks, including the potential loss of the capital invested. The price, value and yield of securities or financial instruments may fall as well as rise. Certain investments are subject to high price fluctuations and may lose value suddenly and to a considerable extent. The loss can be as high as the original invested capital or even higher. Securities and financial instruments denominated in foreign currencies are also exposed to exchange rate fluctuations, which may have a positive or negative effect on the value, price or income of these securities or financial instruments. Some investments may not be immediately realizable, which means that selling or liquidating these investments may prove difficult. Similarly, it may prove difficult to obtain reliable information about the value of the investment or the risks to which the investment is exposed. International or global investments (namely in emerging markets), investments in smaller companies, investments in funds or investment strategies that focus on one industry, country or region, and other special, aggressive or concentrated investments that involve the use of debt or derivative instruments involve special risks. The risks of such investments are ultimately borne by the investors.

-Links to other websites / external content
If you click on certain links on this website, you will leave this website. Such links, addresses or hyperlinks are provided for convenience and informational purposes only. Finanz Konzept AG has not reviewed any of these websites, which are linked to our website or contain links to our website, and disclaims any liability for their content, products and services or any other offers. The use of links from this website to third party websites is at your own risk.

Legal information fund

1. Binding nature of the terms of use

By accessing the FINANZ KONZEPT AG website (hereinafter referred to as “ FINANZ KONZEPT AG website”), you acknowledge the legally binding effect of the following terms of use and legal information for the funds of FINANZ KONZEPT AG (hereinafter referred to as “Terms of Use”). If you do not agree to this or are subject to access restrictions, you must refrain from using the FINANZ KONZEPT AG website.

FINANZ KONZEPT AG reserves the right to change these terms of use from time to time. You should therefore check these terms of use regularly or each time you access the FINANZ KONZEPT AG website to see whether they have changed and, if necessary, whether you accept the new version. The respective update date can be found on the respective Oberst pages in the text.

2. Access Restrictions

When accessing the FINANZ KONZEPT AG website, you must comply with applicable legal regulations and observe any local restrictions. The information, texts, images, data, video clips, graphics and other publications (hereinafter referred to as “information”) on the FINANZ KONZEPT AG website are in particular not intended for persons from countries in which access to and distribution of such information or websites is a would require prior registration, approval or approval from FINANZ KONZEPT AG . Among other things, access to the FINANZ KONZEPT AG website and the retrieval of information on the FINANZ KONZEPT AG website is not authorized by persons who, due to their domicile, their nationality or for other reasons, are subject to a legal system under which access to such information or websites are illegal.

Persons to whom such restrictions apply are not permitted to access the FINANZ KONZEPT AG website. Please inform yourself in advance about the relevant laws and restrictions that apply to your domicile or that may apply to you.

3. No recommendation

All information provided on the FINANZ KONZEPT AG website is for informational purposes only. In particular, the information does not constitute a recommendation, an offer or a solicitation to purchase or sell securities, financial instruments or other investment products (hereinafter referred to as “investments”), to carry out transactions or to conclude transactions (hereinafter referred to as “transactions”) nor does it constitute advertising for products or services. The information is neither a decision-making aid for economic, legal, tax or other advisory questions nor is it suitable as a sufficient basis for decisions on investments, investments or other transactions to be made. This does not replace advice from qualified specialists.

Unless expressly stated or agreed otherwise, FINANZ KONZEPT AG does not tolerate any orders placed via the message window or by email.

4. No guarantee that the information is up-to-date, correct or complete

Market and investment reports as well as other publications on the FINANZ KONZEPT AG website are based on information sources that FINANZ KONZEPT AG considers to be reliable. Nevertheless, FINANZ KONZEPT AG does not guarantee the content of the information, nor can the information be viewed as a complete treatise or conclusion of the investments, transactions, markets or developments mentioned therein. The content may constantly change or be based on incorrect information provided by third parties. A guarantee or liability of FINANZ KONZEPT AG for the correctness, completeness or topicality of the information is therefore excluded.

5. Investment performance

The investment value can rise or fall at any time. A positive performance in the past is therefore no guarantee for positive price developments in the future. Investments in foreign currencies are also exposed to exchange rate fluctuations. It is possible that investors will no longer get back the amount they invested or will no longer get it back in full. Potential investors should also inform themselves about the tax consequences that may arise when acquiring, holding and selling investments at their domicile and, if necessary, seek advice at their place of residence.

6. Linked websites (links)

FINANZ KONZEPT AG has no influence on the design and content of the websites of other operators (hereinafter referred to as “third-party websites”), which may be linked to the FINANZ KONZEPT AG website or contain links to the FINANZ KONZEPT AG website. Therefore, FINANZ KONZEPT AG cannot assume any responsibility for the correctness, completeness, timeliness and legality of the content of third-party websites or for any information, offers or services contained therein. Responsibility and liability for linked third-party websites lies with the respective operators.

For links that lead from a third-party website to a FINANZ KONZEPT AG website, the written consent of FINANZ KONZEPT AG must be obtained in advance.

7. Adjustments to Information

FINANZ KONZEPT AG reserves the right to adapt or supplement the information provided at any time without notice or to eliminate information in whole or in part. However, FINANZ KONZEPT AG is not obliged to remove information that is no longer current or to expressly mark it as such.

8. Property Rights

All rights, titles and claims to the FINANZ KONZEPT AG website and the information and programs contained therein (copyrights, copyrights, trademarks, logos, patents, other intellectual property rights and other rights) are the property of FINANZ KONZEPT AG or the respective rights holder . Saving or printing individual pages and/or parts of the FINANZ KONZEPT AG website is only permitted for private and internal purposes, and provided that neither the copyright notices nor other legally protected designations are removed. Even after information or programs have been saved, printed or otherwise used, all rights remain with FINANZ KONZEPT AG or the respective rights holder. The (full or partial) reproduction, in particular the use of texts, parts of texts or images, the transmission (electronically or by other means), modification, linking or use of the FINANZ KONZEPT AG website for public or commercial purposes requires the prior written consent of FINANZ KONZEPT AG .

The content and rights of third parties are marked as such. Their copyrights, patents, trademarks, property rights or other protective rights must also be retained. In order to use content from third parties, their consent or corresponding usage rights are usually required.

9. No liability (disclaimer)

Any liability of FINANZ KONZEPT AG for direct or indirect losses (including lost profits), damages, liability claims, demands, costs or consequential damages arising from the use of or access to the FINANZ KONZEPT AG website or due to links to third-party websites The retrieval of information on the FINANZ KONZEPT AG website is expressly rejected. This also applies to liability due to negligence and even if FINANZ KONZEPT AG was aware of the possibility of such consequences.

In addition FINANZ KONZEPT AG declines any liability for manipulation of the user’s IT system, regardless of the manner. We expressly warn against the dangers of viruses or other harmful programs and the possibility of hacking attacks. The use of current browser versions and anti-virus software is therefore strongly recommended.

10. Data protection and security in data transmissions

Please read the data protection declaration, which informs you about how FINANZ KONZEPT AG handles personal data and data security on the Internet.

11. Severability clause

The invalidity, illegality or ineffectiveness of one or more provisions of these terms of use does not prevent the binding nature of the entire work.

12. Conflicting regulations

Certain websites or areas of the FINANZ KONZEPT AG website may contain additional notices, declarations, conditions or provisions (hereinafter referred to as “Terms”). In the event of any conflict between these Terms of Use and the Terms, the Terms applicable to the relevant website or area shall prevail.

13. Applicable Law and Place of Jurisdiction

The user’s access to the FINANZ KONZEPT AG website and the use of the FINANZ KONZEPT AG website as well as these terms of use are subject to Swiss law. The exclusive place of jurisdiction is Zurich.

Privacy policy

1. Privacy policy

FINANZ KONZEPT AG appreciates your visit and your interest in this website (hereinafter referred to as “FINANZ KONZEPT AG Website”). This data protection declaration (hereinafter referred to as the “declaration”) describes the processing of personal data in connection with the FINANZ KONZEPT AG website and the directly related data processing. The legal provisions applicable in Switzerland shall apply.

FINANZ KONZEPT AG reserves the right to change or adapt this statement from time to time. You should therefore review this Statement regularly, or whenever you access the FINANZ KONZEPT AG Web site, to determine whether it has changed and, if so, whether you accept any such revisions. At the beginning of this clarification letter you will find the update date.

By accessing the FINANZ KONZEPT AG website, you signify your acknowledgement of this statement. If you do not agree with this statement, please do not access the FINANZ KONZEPT AG website.

Please also read the Terms of Use and Legal Notices as well as the Special Legal Notices, which inform you about the conditions under which the FINANZ KONZEPT AG website may be used.

2. What is personal data?

Personal data are all statements and information that relate to an identified or identifiable person. In the context of websites, this includes name, e-mail address, telephone number and IP address.

3. What data is stored and for what purpose is it used in each case?

The FINANZ KONZEPT AG website uses cookies to obtain information about its use. Cookies are small files that are saved on your computer. You save settings made by you on the FINANZ KONZEPT AG website (e.g. domicile country selection). This means that certain information does not have to be entered again when you visit the FINANZ KONZEPT AG website. You may refuse the use of cookies by selecting the appropriate settings on your browser, and remove any cookies that are already set by the FINANZ KONZEPT AG website. By not taking these measures, you consent to the use of cookies when using the FINANZ KONZEPT AG website.

When using the FINANZ KONZEPT AG website, access data (e.g. log files, IP address, date and time of access, name of file accessed, access status, page from which access was made, top-level domain, web browser used, operating system used) is saved. FINANZ KONZEPT AG uses this data for statistical purposes, for technical evaluations, for optimizing the server infrastructure, to determine the frequency of access and to be able to draw conclusions for improving user-friendliness and functionality.

If the collection and processing of personal data (e.g. name, address or e-mail address, in connection with a contact form or the ordering of publications) is required in connection with the use of the FINANZ KONZEPT AG website, the data will be used for the purpose of authentication and secured on a data carrier in Switzerland. Furthermore, the data that you enter in the corresponding text or search fields on the FINANZ KONZEPT AG website is processed and saved. This data is used according to the purpose intended in each case.

If, in special cases, your express declaration of consent to data processing is required, you will find an adequate note at the relevant point.

The FINANZ KONZEPT AG website may be linked to the websites of other operators or to content on the websites of other operators. FINANZ KONZEPT AG has no influence on the websites of other operators (hereinafter referred to as “third-party websites”) and can therefore accept no responsibility or liability for the accuracy, completeness, up-to-dateness or legality of the content of third-party websites or for their data processing practices. Therefore, please also note the privacy statements of the respective third-party websites mentioned.

Data transmission on the Internet may contain security gaps. Therefore, absolute data protection (e.g. from access by third parties) cannot be guaranteed.

4. To whom will your personal data be disclosed?

Personal data collected on the FINANZ KONZEPT AG website will not be disclosed to third parties, unless

You expressly accept disclosure at the relevant point of data entry;
FINANZ KONZEPT AG is required by law to disclose the data (e.g. to government institutions, authorities, courts); or
the data processing is carried out on behalf of FINANZ KONZEPT AG by a service provider who has been contractually obligated to treat the data confidentially.

5. How is your personal data protected?

Within the framework of the FINANZ KONZEPT AG website and the directly related internal data processing, appropriate technical and organizational measures are taken to protect the recorded data from loss, unauthorized access or misuse.

Notwithstanding the data protection measures implemented by FINANZ KONZEPT AG, you must be aware that the transmission of data via the Internet – this applies to websites as well as e-mail activities – is uncontrolled and cross-border. Even if the sender and receiver are located in the same country, cross-border data transmission may occur. FINANZ KONZEPT AG can therefore not guarantee the confidential treatment of data transferred via the Internet. When you disclose personal information over the Internet, you must be aware that third parties may access, read, modify, falsify, monitor, destroy or misuse the information. The data transmission may also be delayed or the data may be lost during transmission. Furthermore, third parties could draw conclusions about existing business relationships. Therefore, FINANZ KONZEPT AG cannot assume any responsibility for the security of your data during transmission via the Internet and disclaims any liability for direct or indirect damages. For data protection and security reasons, we recommend that you contact FINANZ KONZEPT AG via other or secure means of communication.

6. Where and how long is personal data stored?

The systems required for data processing are located in Switzerland. The data entered by you will be kept for as long as the intended purpose requires.

7. What rights do you have?

Information

You have the right to request in writing and free of charge information about the data processed about you. A request for information, together with proof of identity, should be sent to the Data Protection Officer at the address given in Section 8.

Upon receipt of your request for information, you will be provided with information within the statutory period of 30 days. The information may be refused, restricted or postponed, insofar as this is provided for by law or is necessary due to overriding personal or third-party interests.

The request for information may be combined with a request for correction or deletion of data.

Correction or deletion

You have the right to request, in writing and free of charge, the rectification or deletion of data processed about you, insofar as they are not correct or are processed incorrectly. A request for rectification or cancellation, together with proof of identity and justification, must be submitted to the Data Protection Officer at the address indicated in point 8.

Your request for correction or deletion will be processed within a reasonable period of time after receipt and subsequently you will receive confirmation of completion.

Under certain circumstances, legal regulations on data processing may prevent deletion. In such a case, FINANZ KONZEPT AG will continue to process the data concerning you only to the extent necessary to fulfill its legal data processing obligations.

Objection or revocation

You have the right to object in writing and free of charge to the processing of data concerning you, in whole or in part, or to withdraw your consent to data processing. An objection or revocation must be sent in writing to the data protection officer at the address given in section 8.

Your objection or revocation will be confirmed upon receipt and subsequently the data concerned will no longer be processed.

Under certain circumstances, an objection or revocation may conflict with legal regulations on data processing. In such a case, FINANZ KONZEPT AG will continue to process the data concerning you only to the extent necessary to fulfill its legal data processing obligations.

Blocking

You have the right to have the data concerning you blocked from being passed on to third parties. A request for blocking, together with proof of identity, must be submitted in writing to the Privacy Officer at the address listed in Section 8.

Your request for blocking will be settled within a reasonable period of time after receipt and subsequently you will receive confirmation of the settlement.

Under certain circumstances, a blocking may conflict with legal regulations on data disclosure. In such a case, FINANZ KONZEPT AG will disclose the data concerning you to third parties only to the extent necessary to fulfill its legal data processing obligations.

8. How can you contact FINANZ KONZEPT AG regarding data protection?

If you have any questions regarding data protection and data processing, please write to:

FINANZ KONZEPT AG

Fraumünsterstrasse 27

8001 Zürich

Switzerland

Telefon: +41 (0)44 204 34 64

Email: info@finanz-konzept.ch

Special legal information

1. General

By using the FINANZ KONZEPT AG web pages, you confirm that you have read, understood and accepted both the General Legal Notice and this Special Legal Notice. These legal terms apply to all information provided electronically by FINANZ KONZEPT AG and may be adapted at any time without notice. If you do not wish to agree to the general legal notices and these specific legal notices, please refrain from any access to the websites. Any special agreements regarding individual services or products of FINANZ KONZEPT AG are in addition to these legal provisions; in case of contradiction, the special agreements take precedence. User access, use of the pages, the General Legal Notice and this Special Legal Notice are governed by Swiss law. The exclusive place of jurisdiction is Zurich.

2. No recommendation, no offer

The information, opinions, products, data, services, tools and documents contained or described on the Websites (“Website Content”) are for informational purposes only and do not constitute an advertisement or recommendation, nor an offer or solicitation to subscribe (or purchase) or redeem (or sell) any Shares, to effect any transaction or to conclude any legal act.

The collective investment schemes mentioned on this website are not suitable for all investors. The information provided on the website does not constitute financial, legal, tax and/or other advice. Investment or other decisions should not be made solely on the basis of this document. In particular, you should not make any investment until you have read the relevant fund contract or legal prospectus, the annual and semi-annual reports, the articles of incorporation or bylaws (as applicable), and any other documents required by local law or regulation in the jurisdictions or countries in which the relevant collective investment scheme is authorized or permitted for public distribution, offer or sale.
To determine whether investing in shares of a particular mutual fund meets your specific needs and risk objectives, we recommend that you contact an independent financial advisor. In addition, we recommend that you consult with an independent tax advisor to learn about the tax rules in your jurisdiction associated with a specific investment in light of your personal circumstances.

3. No warranty

The contents of the web pages may be changed at any time and without prior notice. FINANZ KONZEPT AG does not warrant or make any representations (including to third parties) as to the accuracy, correctness, completeness, or timeliness of the content of the Web sites. In particular, FINANZ KONZEPT AG is not obligated to remove any outdated information from its web pages or to expressly mark it as such. The redistribution of the contents of the web pages and their reproduction in whole or in part are not permitted.
All data available through this website, including but not limited to financial market data, price data, news, research or other financial information, is based on sources that are deemed reliable and have been carefully selected. All available information is provided to the user “as is” and without express or implied warranties or representations as to quality, originality, infringement of intellectual property or fitness for a particular purpose.

The fact that a user accesses the web pages does not make him a customer of FINANZ KONZEPT AG.

Opinions, estimates and forecasts contained in the websites are those of their authors and as of the date of writing and do not necessarily reflect the views of FINANZ KONZEPT AG. They may be subject to change at any time without notice. FINANZ KONZEPT AG and its contractual partners have the right to withdraw or change information, data and documents as well as the products or services described herein at any time and without prior notice. All information marked with a date is published exclusively for this date. There is no obligation or responsibility to update or correct such information.

4. The FINANZ KONZEPT AG investment products are not authorized for public distribution in all countries of the world

The information contained on the FINANZ KONZEPT AG web pages is not directed at specific persons; it is generally intended for readers interested in FINANZ KONZEPT AG investment products. In any case, investment products should only be purchased after a detailed study of the current sales prospectuses including the investment regulations as well as the annual and semi-annual reports. FINANZ KONZEPT AG investment products are not authorized for sale in all countries of the world. The FINANZ KONZEPT AG websites are not directed to any person in any jurisdiction where (by reason of that person’s nationality, residence or otherwise) the publication or availability of the FINANZ KONZEPT AG websites is prohibited. Persons in respect of whom such prohibitions apply must not access the FINANZ KONZEPT AG Web Sites.

In particular, the FINANZ KONZEPT AG Investment Products have not been registered in accordance with investment companies under the United States Investment Company Act of 1940 (as amended) and these securities have not been registered under the United States Securities Act of 1933 (the “Act”). The FINANZ KONZEPT AG investment products are not being offered, sold or delivered in the United States or to U.S. persons (as defined in Regulation S under the Act). Nothing herein constitutes an offer or solicitation to invest in such investment products in the U.S. or to U.S. persons.

For the purposes of this document, the term “United States” shall include the United States of America, all of its constituent states, territories and possessions, and all territories under its jurisdiction.

5. Warning of risks

Positive performance in the past is no guarantee of positive performance in the future. The risk of exchange rate and foreign currency losses as well as fluctuations in returns due to an unfavorable development of exchange rates for the investor cannot be excluded. There is a possibility that investors may not get back the full amount they invested. The commissions and costs charged on the issue and redemption of units are charged to the investor individually and are therefore not reflected in the performance shown.

We expressly point out that certain investments are highly volatile. Such investments, e.g. derivatives, may be subject to high price fluctuations, the extent of which may correspond to or even exceed the amount invested.
Certain special facilities may not be immediately feasible. It may therefore be difficult for investors to sell an investment, realize the gain, or obtain reliable information about its value or the extent of the risk to which the investment is exposed.

When you buy or sell investments with a contingent liability, you may not only lose the amount you invested, but you may face being ordered to pay an additional amount.

Regulation

1. Information obligations according to FinSA/FINIG

The following information serves to fulfill the information obligations of financial service providers towards their customers in accordance with Article 8 et seq. of the Financial Services Act (FinSA). This information is provided without any advertising background and does not constitute an offer for financial services or financial instruments.

2. Approval status

Finanz Konzept AG (“Company”) is a financial service provider in accordance with FinSA and FinIG with its registered office at Fraumünsterstrasse 27, 8001 Zurich. Its main activity is commercial asset management for individual clients.

The company was granted a license as an asset manager in accordance with Article 17 paragraph 1 of the Financial Institutions Act (FINIG) by the Swiss Financial Market Supervisory Authority FINMA.

FINcontrol Suisse AG is responsible for prudential supervision of the company.

3. Ombudsman office

The company has joined the Financial Service Providers Ombudsman Association (OFD) and has thus fulfilled the obligation to join in accordance with Article 77 FinSA. Customers have the option of initiating mediation proceedings through the ombudsman’s office in the event of disagreements with the company.

4. Management of business

The company is managed by two qualified managing directors in accordance with Article 20 paragraph 1 FinIA.

5. Business area

The company commercially operates discretionary asset management and execution mandates in accordance with Article 3 lit. c FinLeg. Asset management is carried out through written contracts (the “Contract”) with customers, which contain comprehensive information on the characteristics, functionality, rights and obligations of the customers as well as the risks of the financial service provided. The customers authorize the company to carry out the mandates with the respective custodian banks.

6. Financial Services Risks

The risks associated with the financial services provided are explained to customers before contracts are concluded. Customers are asked to read the information provided carefully, in particular the brochure “Risks in Trading in Financial Instruments” from the Swiss Bankers Association ( https://www.swissbanking.ch/de/downloads ), and to contact the company if they have any questions turn around.

7. Cost information

There are costs and fees associated with the services provided. These are disclosed to the customer in detail before the contract is concluded.

8. Participation in and economic ties to third parties

The company is currently not affiliated with third parties and has neither parent nor subsidiaries. There are no economic ties to third parties that could lead to a conflict of interest to the detriment of the company’s customers.