Your guide

to international

investment market

Alfa Asset Management
(Europe) S.A.

Luxembourg-based licensed portfolio
management company
servicing private and corporate customers
in Europe since 2015

Luxembourg, located in the very heart of Old Europe, is called the gateway to the international investment market. Luxembourg is widely regarded as a safe and comfortable place for carrying out financial transactions worldwide.

Political and social stability, compliance with regulations, competence of regulatory authorities and longstanding efforts of the government aimed at forming a favorable investment environment have made Luxembourg one of the centers of the trust management industry. Many transnational management companies have chosen it as their principal place of business.

Highly professional financial sector employees and multicultural traditions that have been formed in Luxembourg over decades create the best possible conditions for a long-term trustful cooperation between companies and their customers from different countries.

Classic

investment
services

Discretionary portfolio management

If you want to protect and multiply investments
with a reasonable risk level

Let your capital be managed by professional managers who will maximize your profit and guarantee absolute transparency of transactions.

Take advantage of the best investment ideas on the international markets, including those in Russia and CIS, not only to ensure reliable protection but also to multiply investments with a reasonable risk level.

Investment consulting

If you prefer to manage your funds
independently

Manage your capital independently using analytical support of transactions offered by Alfa Asset Management (Europe) S.A.

Get an optimal investment strategy, evaluation of prospects of certain markets, sectors and companies as well as clear recommendations as to formation of a securities portfolio and advice on your investments protection.

Discretionary
portfolio management

If you want to protect and multiply
investments with
a reasonable risk level

Investment
consulting

If you prefer to manage your
funds independently

A proven
way
to new
opportunities

Advantages of
Alfa Asset Management
(Europe) S.A.

Is part of Alfa-Group, one of the biggest private finance and investment consortiums in Russia. The company’s partners include leading international financial organizations.

Complies with the European regulations and provides a wide range of financial services, including investment consulting, development of trust management strategies and portfolio management.

Has a platform to access all markets and any classes of financial instruments, which allows offering the most advanced and efficient investment products and strategies.

Provides a tailor made approach to ensure investment results are in line with the investment strategy, risk appetite and expectations of each client.

Do business with us

Alfa Asset Management (Europe) S.A.
25 Rue du Puits Romain (Building Emporium)
| L-8070 Bertrange Luxembourg
Tel: +352 28 26 78
Fax: +352 28 26 78 28
info@aame.lu

Authorization to conduct financial activity 165 Kb

The Licenses for these activities have been issued to
Alfa Asset Management (Europe) S.A. by the Finance Minister of Luxembourg. Alfa Asset Management (Europe) S.A. is subject to the prudential supervision of the Commission for Surveillance over the Financial Sector of Luxembourg (Commission de Surveillance du Secteur Financier - CSSF).
Declaration Concerning the removal of control by designated shareholders of Alfa Asset Management (Eureo) S.A. 822 Kb

Corporate policies,
policies to prevent financial crime
and regulation

Alfa Asset Management (Europe) S.A. being a supervised and licensed institution within Luxembourg, the European Union and in one of the jurisdictions committed to prevent financial crime to occur, is bound to International Standards, therefore Alfa Asset Management (Europe) S.A. holds the following documents:

General Terms and Conditions 1.34 Mb
Conflict of interest
Alfa Asset Management (Europe) S.A. understands that conflicts of interest may arise in the course of performing its activities. A Conflict of Interest Policy has been put in place to illustrate the approach taken with respect to the potential conflicts of interest that may arise in the provision of these activities.

The policy sets out the main types of conflict of interest that could arise in the course of business activities of AAME and ensures that AAME takes all reasonable steps to prevent the risk of damage to client interests from these conflicts.

The guidelines are defined in conjunction with other policies issued by AAME in compliance with applicable laws and regulations. These integrate the rules of conduct that employees must observe and include but not limited to the following policies:
- Organizational and IT procedures to ensure that services are carried out properly, in full respect of the client interests;
- Counterparty onboarding policy;
- Remuneration Policy;
- Corporate Governance Policy;
- Best Execution Policy;
- Personal Transaction Policy;
- Complaint Handling Policy;
- Code of Corporate Ethics.
All conflicts of interest are recorded and reported appropriately.

For a copy of the Conflict of Interest Policy please contact Alfa Asset Management (Europe) S.A. directly.
Best Execution Policy
The Best Execution Policy of Alfa Asset Management (Europe) S.A. ensures that all investment decisions and orders received from Clients and on behalf of the funds that it manages, are executed with the aim of obtaining the best possible result for those clients and funds when transmitting an order to another entity for execution.

Subject to any specific instructions given by clients when transmitting orders on their behalf, the Company shall take all reasonable steps to obtain the best possible result for them by taking into account the following execution factors:
- price;
- costs;
- speed;
- likelihood of execution and settlement;
- order size and nature; and
- any other relevant consideration.
The relative importance of each of the execution factors will be determined by reference to the below mentioned characteristics (hereinafter referred to as the “Execution Criteria”).

For portfolio management on a discretionary basis and advisory mandates, the Execution Criteria shall be:
- the client and his classification, including whether the client is retail or professional;
- the client order;
- the financial instruments that are the subject of that order; and
- the execution venues to which that order can be directed.
When transmitting orders for clients, the Company shall ensure that financial intermediaries chosen for the execution have appropriate execution arrangements in place to satisfy the best execution obligations placed on them by AAME.

AAME has identified appropriate trading venues and counterparties and considers they will carry out effective and consistent best execution procedures.

AAME guarantees its clients transparency with regard to fees, commissions and monetary and/or non-monetary benefits paid or received in relation to the services provided.

A copy of the full Best Execution Policy is available from Alfa Asset Management (Europe) S.A. directly.
Code of Corporate Ethics
Alfa Asset Management (Europe) S.A. has implemented a Code of Ethics which is applicable to all members of staff and provides guidance on the standards aimed at raising the financial stability and efficiency of AAME as well as those standards which need to be applied to meet local regulatory and internal policies related to Anti-bribery and corruption.

The sphere of application of the Code of Corporate Ethics includes the following:
- The Code has been developed on the basis of universally accepted principles and norms of the CSSF Circular 07/307, the law of 13 July 2007 on markets in financial instruments and the Grand Ducal Regulation dated related to organisational requirements and conduct of business rules in the financial sector.
- The Code contains the mandatory rules of conduct which apply to all employees of AAME regardless of their level or position.
- All documents of AAME, including documents which formalise the relationship with clients, business partners, state and municipal bodies of power, competitors and Employees of AAME, are produced and approved with regard to the provisions of this Code.
- The provisions of this code are amended and supplemented by a resolution of the Board of Directors of AAME.
For a copy of the full Code of Corporate Ethics please contact Alfa Asset Management (Europe) S.A. directly.
Complaints Handling Policy
Clients are entitled to contact Alfa Asset Management (Europe) S.A. to lodge a complaint free of charge on every matter relating to their investment or potential investment whereby AAME will act as the investment firm on behalf of the client.

AAME defines a complaint as written communication expressing dissatisfaction with the services provided by AAME in general, with a particular interaction with AAME or with a specific policy or contract in place between the client and AAME.

AAME is required to comply with all applicable laws and regulations when dealing with the Client complaint and the Board of Directors and the Authorised Management of AAME will act in the best interest of the client when dealing with any such complaint.

AAME has designated a member of the Authorised Management to act as the Complaints Handling Officer, as required by regulations.

The Complaints Handling Policy allows investors to file complaints in English, French or Russian.

The Complaint Handling process:

Upon receipt of a Client Complaint via one of the authorised communication channels, the following process and responsibilities are allocated and to be followed:
- 1.Upon receipt of the complaint, the Complaints Handling Officer (CHO) will note the date of reception of the complaint in the Complaints Log and confirm reception of the complaint back to the client.
- 2.The CHO will inform the Authorised Management of the reception and the content of the complaint.
- 3.Within three days of acknowledgement of the complaint, the Authorised Management and the CHO will produce an action plan for the treatment of the complaint. The action plan is stored in the clients file.
- 4.Within 30 days of the first receipt of the client complaint, an official response should be produced to the client informing of actions and decisions taken with regards to this complaint.
- 5.The CHO will keep an up to date record of all client complaints, which will include the date of reception of the complaint, a summary of the complaint, persons and responsibilities defined to act in the Action Plan, final decision and date of the answer, remedial actions following the complaint and impacts noted at that point in time.
Reporting obligations:

On a quarterly basis, the CHO will report to the Authorised Management of AAME if any complaints have been received and the actions taken to resolve the complaint.

Authorised Management will report to the Board of Directors on a quarterly basis with regards to any complaints that have been received in the previous quarter.

On an annual basis, the Complaints Handling Officer, with the assistance of the Authorised Management, will report to the CSSF the number of complains received the nature and status of the complaints.

A copy of the full Complaints Handling Policy is available from Alfa Asset Management (Europe) S.A. directly.
Anti-Money Laundering and Know Your Customer Policies
Alfa Asset Management (Europe) S.A. has implemented a Code of Ethics which is applicable to all members of staff and provides guidance on the standards aimed at raising the financial stability and efficiency of AAME as well as those standards which need to be applied to meet local regulatory and internal policies related to Anti-bribery and corruption.

Framework and commitment

Luxembourg is a founding member of the European Union, the Financial Action Tax Force (FATF) and a member of the Organisation for Economic Cooperation and Development (OECD), therefore, a committed jurisdiction in regards to transparency, the fight against money laundering, corruption and financing of the terrorism.

Alfa Asset Management (Europe) S.A., being a supervised and licensed institution within Luxembourg, the European Union and in one of the jurisdictions committed to prevent financial crime to occur, is bound to International Standards, Local rules and Regulations and necessary and applicable circulars (for more details please follow this link https://www.cssf.lu/en).

As an investment firm, the activities of Alfa Asset Management (Europe) S.A. are described and to be executed within the framework of the relevant sections of the Luxembourgian Law of the financial sector “Law dated 5th April 1993” (as amended) and such activities are under the supervision of the Financial Sector Commission in Luxembourg (CSSF).

Additionally, Alfa Asset Management (Europe) S.A. is one of the market participants who has joined the International Capital Market Association ICMA charter https://www.icmagroup.org/Regulatory-Policy-and-Market-Practice/Asset-Management/icma-private-wealth-management-charter-of-quality/ to further commit with the fight against international crime and for transparency.

Compliance, anti-money laundering, counter terrorist financing, financial crime and other risks in our culture, our teams and our structure

Within the firm, all relevant International Standards, European Directives and Regulations as well as local rules and regulations have been included in our different procedures, and in specific in the measures taken to identify potential clients, third parties and the monitoring of the activities under the scope of our services.

In this sense, we identify and verify identity of clients and beneficial owners as well as their sources of funds and wealth on the basis of information and documents obtained from reliable sources and checking the reliability of such sources as applicable.

Such records are subject to updates in the terms of the applicable laws and regulations and to a document retention policy which allows its conservation for a period of five (5) years at least.

In more details, our Know Your Customer process and client acceptance and continuance procedures put special focus on:
- 1.Identification of the client(s) and its controlling person(s);
- 2.Understanding of the structure and beneficial ownership of the client(s);
- 3.Purpose of business and intended nature of the relationship;
- 4.Understanding of assets involved and their source as well as understanding of the global wealth of the clients and beneficial owners;
- 5.Profiling and monitoring of business activities;
- 6.Update of previously obtained information.
The compliance with our internal rules and procedures is entrusted to a five-layer process of control and subject to review on yearly basis.
- Layer 1: Alfa Asset Management (Europe) S.A. and network of cooperation sales team, acting as a first control point.
- Layer 2: Alfa Asset Management (Europe) S.A Compliance team / Alfa Asset Management (Europe) S.A Risk team perform real time controls and post facto reviews.
- Layer 3: A PSF has been selected as a service provider to facilitate some of the outsourcing of functions applicable to Alfa Asset Management (Europe) S.A, and being a well established PSF was chosen for its specific high quality and controlled services, including reporting.
- Layer 4. Internal Audit.
- Layer 5. External audit.
Furthermore, policies and procedures are reviewed and approved by Compliance, Authorised Management and the Board of Directors of Alfa Asset Management (Europe) S.A.

Every team member is provided with relevant training on an annual basis in accordance with legal standards and in particular with focus on matters relevant to the specific function, risk exposed and to understand responsibilities and actions on each case which comes to the attention of any staff member.

Some team members are provided with specific training and in all cases specific trainings are set whenever found appropriate or upon a regulatory or legal change.

Client onboarding and new business relationships

In order to ensure a four eyes principle and completeness of information, Alfa Asset Management (Europe) S.A. has set an internal distribution of tasks which is monitored by a system including a number of checkpoints and the approval required to onboard a client.

The process starts with a detailed questionnaire which covers several aspects of identification as well as the focus on Know Your Customer information. Based on the information collected and in accordance with the risk level, clients are subject to a risk-based approach in terms of verification of the information obtained and subject to screening in terms of sanctions, restrictions and political exposure.

Any match with a Politically Exposed Person (PEP) is analysed in order to take the necessary and appropriate measures including the enhanced due diligence measures set by local rules and regulations.

In a similar way, alerts triggered by potential matches with sanctions, restricted or other subjects of interest is subject to analysis and testing in order to take the respective measures.

The process of screening is performed on regular basis in order to ensure update of information, monitoring and further understanding of material changes.

Once the process of identification and verification of the information has been successfully collected and validated, each prospect is presented to the Client Acceptance Committee for final approval.

A similar process is in place for selection of counterparties and contractors, in accordance with existing rules, regulations and internal policies and procedures.

Any transaction which triggers an alert is treated by the Compliance and Risk department as appropriate.

Cooperation with authorities

Alfa Asset Management (Europe) S.A. actively cooperates with authorities and establishes fast and effective channels of communication in order to facilitate the track of potential risks and in order to protect the stability of Luxembourg as a jurisdiction and the financial system as a vital element of our social structure.

We have appointed our Chief Risk and Compliance Officer (CRCO) to act as Money Laundering Reporting Officer who performs Suspicions Activity Reports on behalf of the organisation in full independency.

The Chief Risk and Compliance Officer reports directly to Authorised Management and to the Board of Directors both upon request and proactively.

Our Compliance and Risk department is seen as an institution inside the institution; therefore, fully independent and granted with all necessary decision powers, autonomy, resources and tools necessary to comply with the entrusted functions.

Is to note that suspicious activity reports are part of the exclusive scope of the money laundering reporting officer (MLRO) and only selected members of authorised management receive reports in that sense.

Cooperation with authorities is not limited to money laundering reporting.
Remuneration Policy
AAME has established and implemented a remuneration policy that has been approved by the Board of Directors and has been drafted according to the regulations defined by CSSF circular 10/437 and its amendments introduced by regulatory or legal text.

The Remuneration Policy includes fixed and variable components of salaries and applies to all categories of staff, including senior management and all employees receiving total remuneration from AAME.

The guiding principles of the Remuneration Policy are as follows:
- The remuneration of AAME employees is structured in a way in which the fixed component represents a significant part of the total remuneration which ensures that employees do not base their income of the discretionary part of the remuneration.
- The variable payment (bonuses) are discretionary and subject to the approval of the Authorised Management / Board of Directors.
- The Board of Directors fixes the remuneration of AAME top management members and key officers, including the controlling functions. The authorised management fixes the remuneration of the other employees of AAME, avoiding any conflict of interest.
- The evaluation procedures and the Remuneration Policy are documented and transparent for all members of staff.
- Management is responsible for the effectiveness and application of the remuneration policy and for the annual update and approval by the Board of Directors.
A paper copy of the remuneration Policy is available upon request from Alfa Asset Management (Europe) S.A.
Data Protection
The new European Union General Data Protection Regulation (GDPR) is the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, coming into force on May 25, 2018.

GDPR sets new standards and compliance requirements for every company that holds or processes personal data. It replaces the 1995 EU Data Protection Directive (European Directive 95/46/EC), strengthening the rights that EU individuals have over their data.

Alfa Asset Management (Europe) S.A. (AAME) is committed to high standards of information security, data privacy, and transparency, and to managing data in accordance with legislation and regulation, including but not limited to GDPR.

What is personal data?

Personal data consists of details about you and/or data that is identifiable to you. It includes your contact details, social security number, ID information, bank account balance, TIN number, or other information obtained by Alfa Asset Management (Europe) S.A., when you complete a client questionnaire form, for the purpose of the provision of investment services.

Why does AAME process personal data?

AAME processes your personal data in various internal processes. This allows AAME to offer you its services as efficiently and effectively as possible. AAME processes personal data to enable its services and to execute agreements with its customers (e.g. provision of investment advisory and discretionary portfolio management services, account openings with third parties, maintaining customer relationships and processing of financial transactions for its customers). AAME processes personal data for internal analysis and for product development. This enables AAME to continuously improve its products and services. AAME processes personal data of customers for communication and reporting purposes. AAME maintains personal records in order to comply with (international) laws and regulations, with regard to customer identification and verification and in order to prevent from money laundering and terrorist financing. By doing so, AAME complies with Luxembourg laws and regulations regarding Anti- Money Laundering.

AAME uses personal data also for security purposes to prevent fraud and possible resulting damage in relation to its services as much as possible. AAME has the right to process personal data on the basis of one of the following legal grounds:
- for the execution of an agreement between AAME and a customer,
- on the basis of a legitimate interest of AAME, or
- to comply with a legal obligation that AAME is subject to.
Personal data received from third parties is used by AAME from various external sources to obtain additional information about its customers for customer identification and screening purposes, such as local trade registers, Thomson and Reuters, Spark Interfax, Bloomberg and others.

Who has access and where is personal data stored?

AAME takes all relevant measures to prevent unauthorized access to your personal data. Your personal data will only be provided to third parties upon your explicit consent, or on the basis of legal grounds, for example when information is requested by tax authorities, or for the purpose of common reporting standards (CRS), investigation or supervisory authorities, or if such is required for AAME to meet its obligations in the agreement concluded with you.

AAME may contract third parties to support the services to its clients. These parties may have (partial or the entire) access to your personal data, but only in those cases where these third parties comply with the same legal and security requirements as AAME and therefore you receive the same level of data protection. Your personal data will be stored in accordance with EU principles as included in the GDPR. This may be within the EU or countries with an adequate level of protection as established by the European Commission. In some cases, this is outside the EU, but in all cases in accordance with the established framework of the GDPR. The retention period of AAME storing your personal data is no longer than it is necessary. The period depends on the purpose for which AAME processes your personal data. Your personal data will be kept as long as you have an agreement with AAME or as long as is required for AAME to meet its fiscal and legal obligations. (5 years after the agreement has ended). Your personal data will be deleted or anonymized after the expiration of the retention period.

What are your rights?

Below are your rights in relation to the processing of your personal data by AAME:
- The right to review your personal data processed by AAME;
- The right to have your incorrect, inaccurate or incomplete personal data corrected;
- The right to have your personal data erased in certain cases (if no longer required or in the event that your personal data is not processed in accordance with applicable laws and regulations);
- The right to object that your personal data are processed for marketing purposes;
- The right to have the processing of your personal data limited in certain cases;
- The right of “data portability” by receiving your personal data in a machine-readable format that allows transferring your data to another controller;
- The right not to depend solely on automated processes in the case of profiling or automated decision - making with legal consequences.
In these cases, you have the right to express your opinion, to disagree with the outcome and you have the right to have the outcome of the process assessed by a natural person. You can make your request known by sending an email to the relevant person at AAME (compliance@aame.lu.). AAME will respond to your request within one week.

If, in spite of AAME’s efforts and the rights described above, you have a privacy-related question or complaint, please do not hesitate to contact us on the above indicated email.

For additional Information related to the protection of personal data, we herewith invite you to visit our homepage www.aame.lu and consult the General Terms & Conditions located on the bottom the page, under the section “Corporate policies”.

MIFID II – Suitability & Appropriateness Procedure

A. Definition

The suitability assessment is a process performed by Alfa Asset Management (Europe) S.A. (AAME) to ensure that investment services, such as investment advisory services or discretionary portfolio management services, match the client’s investment objectives, financial situation, knowledge and experience. This assessment obligation applies to all types of clients in respect of Markets in Financial Instruments Directive (MiFID), including those clients who would be classified as eligible counterparties, as well as for retail clients.

B. Suitability information capture

In order to make an assessment of the suitability, AAME needs to obtain the necessary information which is captured at the onboarding of the client via the Individual or Corporate client questionnaire. These questionnaires are mandatory for all clients and cover all types of investment services provided by AAME. Therefore, AAME expects to have sufficient information to perform its services within the defined investment universe of advisory recommendations or Discretionary Portfolio Management (DPM).

AAME has adopted a conservative approach considering that the ability to bear a loss is assessed in the Individual or Corporate client questionnaire for both Individuals and Legal Entities by means of specific questions. These questions are part of the client risk scoring process, regardless of the category (e.g. retail, professional or eligible counterparty) and cannot be separated from the risk scoring methodology. Therefore, when providing a DPM and Advisory service, the ability to bear a loss is part of the suitability assessment for all clients.

The suitability framework allows to assess the “Suitability Obligation” both at trade level and at portfolio level to cover both DPM and Advisory services within the same framework.

C. Suitability process description

The Individual and corporate client questionnaire is composed of mandatory questions completed by the client (e.g. suitability information capture section). Each answer is subject to a dedicated scoring leading to a consolidated result reflected in the client Risk profile calculation. The result is then taken as the investor risk profile and compared at each suitability testing to the risk level classification table of the financial instruments in order to identify instruments that are suitable for the client.

D. Clients investment profile and allocation of financial products

Investment profile	Financial products available	Investment profile description
Very Conservative	Instruments of 1 category: fixed income instruments of credit rating not lower than 5 notches below country celling. No equities. Market risk category up to 1.	Objective: capital preservation Income level: modest and stable capital appreciation Risk: extremely low probability of any financial losses and investing in secure assets only
Conservative	Instruments of 1-2 category: fixed income instruments. Credit rating not lower than 9 notches below country celling. Structured products with capital protection. Low risk equities. Market risk category up to 2.	Objective: capital preservation Income level: moderate growth of assets value in mid-term Risk: investing in conservative instruments with low probability of default and/or significant losses during market turbulence
Balanced	Instruments of 1-3 category: fixed income instruments and structured products. Credit rating not lower than 12 notches below country celling. Equities. Market risk category up to 3. Maximum weight of category 4 and 5 instruments is 20%.	Objective: generation of moderate and stable level of capital appreciation Income level: portfolio dynamics comparable to major market indices Risk: investing in financial instruments with moderate credit risk and assets value fluctuations comparable to average market moves
Aggressive	Instruments of 1-4 category: fixed income instruments and structured products. Credit rating not lower than 14 notches below country celling. Equities. Market risk category up to 4. Maximum weight of category 5 instruments is 20%.	Objective: capital appreciation Income level: more than market average Risk: investing in highly volatile instruments and high probability of significant losses in mid-term, as well as instruments with probability of default more than average
Very Aggressive	Any kind of financial instruments	Objective: capital appreciation Income level: capital growth maximization Risk: investing mostly in assets with high probability of losses not limited to any level or time period

Each instrument belonging to the investment universe of AAME will be risk-scored between 1 and 5 on a monthly basis. A risk evaluation is performed in accordance with the Company’s Product Risk Categorization Policy and include separate assessment of credit and market risk in accordance with the internal methodology. The general approach is presented in the table above.

E. Suitability result

Unsuitable result:

When providing DPM and Advisory services, AAME willl not recommend or decide to trade where any of the services or instruments are not suitable for the client.

Suitable result:

If the result of the suitability process is positive, then the order is processed and executed.

Appropriateness

A. Definition

The appropriateness assessment is a process performed by AAME to ensure that investment service of execution only is in line with the retail client’s knowledge and experience when a product is deemed to be classified as complex or even as non complex.

AAME assumes that a professional client as well as an eligible counterpart has the necessary knowledge and experience in order to understand the risks involved in relation to the particular products or services for which he has been classified as a professional client.

B. Appropriateness information capture

For Investment advisory and Discretionary Portfolio Management services, AAME requires all clients to provide information regarding their knowledge and experience in the investment field relevant to the specific type of product or services offered or demanded in order to enable AAME to assess whether the product or service envisaged is appropriate.

AAME expects to have sufficient information to perform the appropriateness test at trade level. Warnings, and consequently a refusal of the execution of a trade falling under the execution services will be only generated if the result of the assessment is negative.

C. Appropriateness process description

AAME will check the appropriateness at any moment and for any client when providing non-advised services, similar to DPM and IA services, regardless of the none obligation to test the appropriateness if the instrument is complex or non-complex and regardless of the client’s classification (Retail / Professional or Eligible). Consequently, the client is informed formally via email informing and warning the client about the inappropriate results.

Inappropriate result on a trade basis:

If the result of the assessment is negative, two outcomes are possible. If the security requested to be purchased is not appropriate in terms of risk, that will be rejected. The portfolio manager will provide the client with the communication. In the case the security is deemed appropriate in terms of risk, but the client has insufficient experience/knowledge about the complex product the Risk Officer will notify the Client by generating a warning via a communication channel approved for communication with that client.

Appropriate result:

If the appropriateness test is positive, then the Portfolio Manager will confirm by e-mail to the client the acknowledgement of the trade. Then the order is processed and executed.
Suitability & Appropriateness

Pre-control

A pre-control on Suitability and Appropriateness is performed at first instance each time a new trade order is received by a client based on the information provided within the onboarding stage.

Investment Advice

A control is made when AAME is providing investment advice to ensure such advice is relevant for that specific client.

Post-control

A post-control of Suitability & Appropriateness is performed on a regular basis for all clients.
Exception Treatment

A. Transfer of existing Securities

A client may transfer in securities at the onboarding stage, subject to investment services at AAME, which have a higher risk ranking and are considered as non-appropriate for his/her investment risk profile. The transfer will be treated on a case by case basis and AAME’s Risk officer will notify the client to explain that the security(ies) which the Client intends to transfer, is not appropriate for him based on his knowledge and that trading it may put the Client at a significant risk.

If a client is provided with a warning but still wishes to proceed, then the Risk Officer must receive the confirmation from the client that he is willing to transfer and confirm formally that the transfer can be done.

B. Deterioation of Financial Products through S & A Post-control

If a passive breach is detected by way of the Post-control suitability and appropriateness testing, then the Risk officer will notify the client and generate a warning to the client.

C. Purchase ban on certain securities / issuer

If a security’s risk score is below the Company’s risk appetite, a purchase ban on certain Issuer / securities, considered as too risky due to economical, market or political events can occur. These securities / issuer are normally communicated via email and on an ad-hoc basis and should be treated promptly in order to avoid any delay resulting in losses for investors or AAME.

D. Purchase of complex products without proper knowledge/experience

In the specific case of execution-only services, a client who wants to purchase a complex product without having the appropriate experience/knowledge will need to confirm his understanding of the situation by providing the requested confirmation to the Risk Officer’s warning.

The information contained and accessed on this website is provided by Alfa Asset Management (Europe) S.A. as a reference and for general guidance and is intended to offer the user general information of interest. The information provided is not intended to replace or serve as substitute for any legal, financial, regulatory, advisory, tax or other professional advice, consultation or service. You are to consult with your own professional advisors in their respective professional areas to obtain specific advice in any matter linked or connected with the information included herein. All investments in financial instruments, precious metals and currencies are subject to market movements and you may thus make profits but may also sustain losses. Good past performance is no guarantee of good future performance. You should only undertake investments with which you are or have made yourself familiar and which are suitable in the light of your circumstances and financial resources.

Alfa Asset Management (Europe) S.A. do not guarantee or warrant that this website will be accessible at all times, work uninterrupted, without delay, error-free, omission-free, or free of viruses. The information on this website is provided "AS-IS" without warranties of any kind, express or implied, including warranties of accuracy, timeliness and completeness. Under no condition Alfa Asset Management (Europe) S.A., network of cooperating companies, agents, business partners or personnel may hold any type of liability for any decision made, request presented or action taken in reliance or based on the information in this website in regard to any direct, indirect, incidental, special, exemplary, punitive, consequential or other damages whatsoever (including but not limited to, legal or financial liability for loss of use, data or profits) regardless of the type of action taken or the decision made including but not limited to negotiation or conclusion of contracts, requests, orders, or any communication or document which may give rise to any type of obligations.

Certain links in this website connect to other websites maintained or hosted by third and such links are not links to representatives or any type of relation or subordination, and therefore, no liability, responsibility or claim shall be made against Alfa Asset Management (Europe) S.A. or its personnel in relation to or connection with the content of any site or information received from a third party website or in connection with the links or the operational functioning of such websites.

Your guide to international investment market

Alfa Asset Management (Europe) S.A.

Classic investment services

Discretionary portfolio management

Investment consulting

Discretionary portfolio management

Investment consulting

Доверительное управление в компании Alfa Asset Management (Europe) S.A.

A proven way to new opportunities

Advantages of Alfa Asset Management (Europe) S.A.

Do business with us

Your guide

to international

investment market

Alfa Asset Management
(Europe) S.A.

Classic

investment
services

Discretionary
portfolio management

Investment
consulting

Доверительное управление
в компании Alfa Asset Management (Europe) S.A.

A proven
way
to new
opportunities

Advantages of
Alfa Asset Management
(Europe) S.A.