Pre-contractual
disclosure.

Pursuant to Article 165 of the Regulation adopted by Consob Resolution no. 20307/2018 (the “Intermediaries Regulation”), the following information is provided about Mr Massimiliano Silla (hereinafter the “adviser”) and the services he provides.

The information contained in this document must be provided to the client or potential client before they are bound by an agreement for the provision of the investment advisory service, or in any case before that service is provided.

The recipient of this document is invited to read the following before taking any decision regarding entering into an investment advisory contract.

The adviser is available to provide further information on the nature and characteristics of the investment advisory service.

1. Information about the adviser

• Name and surname: Massimiliano Silla
• Address: Viale dell’Arte 25 – 00144 Rome
• Website: www.massimilianosilla.com
• Email: info@massimilianosilla.com
• PEC (certified email): massimiliano.silla@pec.it
• Telephone: +39 06 9670 1880
• Mobile: +39 334 221 81 09
• Registered by OCF Resolution no. 2425 of 19/03/2024 in the CFA section of the single register of financial advisers.

2. Language used

The client may communicate with the adviser and receive documents and information from him in Italian.

3. Methods of communication used

The sending of letters, information notes, statements, any notifications and any other written declaration or communication — including amendments to the information contained in this document — will, unless otherwise provided by law or by the contract, be made to the client at the address indicated upon signing the contract or subsequently communicated in writing.

At the time of signing the advisory service contract, or by subsequent written communication, the client may choose to receive information on a durable medium other than paper and, in particular, by email. For this purpose, the client will indicate a valid email address accessible solely to them and undertakes to keep it active (or to communicate in writing a different valid email address) until 14 months after the termination of the contract.

Communications and/or any notifications to the adviser must be made by the client to the adviser’s address, or by certified email (PEC) to the addresses indicated above.

The sending of recommendations by the adviser and the confirmation of the execution of transactions by the client may be carried out by the following means:

• Post (registered letter with return receipt)
• Hand delivery
• Internet communication platforms with an account specifically indicated by the adviser
• Ordinary email, to the address indicated in the contract
• Certified email (PEC), to the address indicated in the contract

4. Registration on the register provided for by Art. 18-bis of Legislative Decree 58 of 24/2/1998

It is declared that the adviser is registered in the section of the register referred to in Art. 18-bis of the Legislative Decree of 24/2/1998 (TUF), kept by the Supervisory Body (ODV) provided for by Art. 31(4) of that decree, by resolution of 19/03/2024 no. 2425. The name and contact address of the Body are: OCF – Ufficio Albo Consulenti Finanziari UACF, Via Tomacelli 146, Staircase B – Floor 4, 00186 Rome.

5. Reports on the provision of advisory services

The adviser sends the client the following reports concerning the provision of the advisory service:

• Within 30 days of the end of each calendar year, a report containing the composition and performance of the portfolio.
• Within 60 days of the end of the calendar year, a report containing: an updated statement indicating the reasons why the portfolio matches the client’s preferences, objectives and other characteristics; the recommendations provided during the reference period; and, in aggregate form, the costs and charges of the service provided and of the financial products and services recommended.

6. Conflicts of interest policy

Pursuant to Article 177 of the Intermediaries Regulation, the adviser has adopted a conflicts of interest policy aimed at identifying the circumstances that generate, or might generate, a conflict of interest capable of harming the interests of one or more clients — including their sustainability preferences — and at defining the procedures to follow and the measures to adopt in order to prevent or manage such conflicts.

The procedures and measures adopted are designed to identify and prevent conflicts of interest that might arise between the adviser and the client, or between the client and other clients of the adviser, when the service is provided, so as to prevent such conflicts from adversely affecting the client. Where the measures adopted are not sufficient to ensure, with reasonable certainty, that the risk of harming the client’s interests is avoided, the adviser will clearly inform the client, on a durable medium, of the general nature and/or sources of the potential conflicts of interest, as well as of the measures adopted to mitigate the related risks. The client may request further analytical detail on the conflicts of interest management policy at the contact details indicated.

7. Service provided and how it is carried out

The adviser provides the investment advisory service referred to in Art. 1(5)(f) of the TUF, consisting of the “provision of personalised recommendations to a client, either at their request or on the initiative of the service provider, regarding one or more transactions relating to financial instruments”. In particular, the service covers the analysis of the allocation of the client’s overall portfolio and the assessment of the efficiency of the products held, any reformulation of the asset allocation, and the periodic assessment, on an annual basis, of the suitability of the portfolio.

The fee paid by the client constitutes, by law and by contractual obligation, the adviser’s only form of remuneration for the services provided to the client; the adviser is prohibited from receiving compensation (incentives) from third parties. The adviser is required, by professional ethics, to be independent of the issuers of the financial products recommended, as well as of the authorised intermediaries. In providing the service, the adviser may not hold funds or securities belonging to clients.

8. Periodic suitability assessment

In carrying out the service, the adviser provides recommendations regarding investment or divestment transactions which, if executed, ensure the suitability of the portfolio in relation to the client’s profile, reconstructed on the basis of the information provided through the questionnaire. The adviser verifies that the recommended transaction matches the client’s investment objectives, including their risk tolerance; that the client can financially bear the related risks; and that the client has the necessary knowledge to understand its risks. The suitability assessment is carried out on an annual basis. Should the client not provide the required information, the advisory service cannot be provided.

9. Integration of sustainability factors

Pursuant to Article 165(1)(h-bis) of the Intermediaries Regulation, in the process of selecting financial instruments the adviser incorporates an assessment of environmental, social and governance sustainability factors, so that products can be recommended only to clients with compatible sustainability preferences. The assessment is carried out at portfolio level: as a whole, the portfolio must be aligned with the client’s preferences, it being understood that individual instruments may not be, for reasons of risk management or of achieving the objectives.

10. Other professional activities carried out

Massimiliano Silla provides the following further activities in addition to the investment advisory service:

• Advice on assessing and covering supplementary pension needs
• Advice on identifying and quantifying the risks of the family unit
• Advice on personal and family financial planning
• Advice on family succession planning

These activities, although personalised, do not concern specific financial instruments or financial products, are governed by a separate dedicated contract, and are not subject to the supervision of Consob and the Body, nor of any other authority.

11. Proposed investment strategies

In carrying out the service, the adviser is not oriented towards particular categories or a specific range of financial instruments and does not propose standardised strategies, but assesses for each client the most suitable strategy, taking into account the investment objectives, the risk tolerance and the financial situation, including the ability to bear losses.