This Legal Information represents the framework for the relations between the User of the Internet Service (hereinafter referred to as the User) and FIDENTIIS EQUITIES SOCIEDAD DE VALORES, S.A. (hereinafter referred to as FIDENTIIS EQUITIES), via the Web page: http://www.fidentiis.com

The User should read this Legal Information carefully. By entering FIDENTIIS EQUITIES' Web page the User undertakes to abide by the terms and conditions of this Legal Notice, the content whereof may change from time to time, without prior notice. We therefore suggest that you reread these Clauses regularly. Continuous access or use of the Web page by the User shall mean that the User accepts any changes that are made. If the User does not agree with these Clauses, the User may exit the Web page.

As the User has specifically accepted these Clauses, the User shall be bound by any change that may be made in the future in these Clauses. Therefore, we would like to remind the User that it is important to reread the contents hereof regularly.

Applicable law and jurisdiction.

FIDENTIIS EQUITIES, corporate address in Calle Velázquez 140, 2º Dcha., 28006 MADRID, and with Tax Identification Number A-83563767, is the owner of the web page http://www.fidentiis.com/

As a general rule, the relations between FIDENTIIS EQUITIES and its Users arising from the use of the Web page are governed by Spanish law and come under Spanish jurisdiction.

Users of FIDENTIIS EQUITIES' Web page must comply with the applicable terms of Spanish law and jurisdiction regarding the access and usage of the Web-page data content.

Any enquiries regarding the services provided by FIDENTIIS EQUITIES should be made to the Customer Service at the following address, calle Velázquez 140, 2º Dcha., 28006 MADRID, or by e-mail to the following address: info@fidentiis.com.

In accordance with the terms of the Information Society and Electronic Commerce Services Act, Law 34/2002, dated 11 July, we hereby provide you with the following information:

Terms and Conditions.

Accessing this Web site implies that you know and accept the following general terms and conditions that govern access to and the use of the site http://www.fidentiis.com/ (hereinafter The Web Site), that FIDENTIIS EQUITIES makes available to its customers free of charge. Accessing the Web Site implies that you accept these terms and conditions without reservation. The use of certain services offered in this site shall, moreover, be governed by the particular conditions laid down for each case. Merely using said services shall imply acceptance of said particular conditions.

  • The content and services included in this Web Site are not designed for or aimed at persons who reside in jurisdictions where said content has not been authorised or is contrary to legal provisions or to habits and customs.
  • Users access this Web Site entirely under their own responsibility.
  • Accessing this Web Site does not entail any relationship of a commercial nature between FIDENTIIS EQUITIES and the User. The Internet service offered through its Web page is solely for information purposes and does not constitute either an offer to sell or an application to purchase any investment product or investment service.
  • Displaying, printing and partial downloading of the content of the Web Site is permitted solely and exclusively when the following conditions are complied with:
    1. That it is compatible with the purposes of the Web Site.
    2. That it is made solely for the purpose of obtaining the information content for personal and private use. Its use for commercial purposes, distribution, public disclosure, transformation or decompiling is specifically prohibited.
    3. That none of the content set out in the Web Site may be modified in any way.
    4. That no graphic, icon or image available on the Web may be used, copied or distributed separately from all the other images that accompany it.

     

    Content.

    FIDENTIIS EQUITIES shall reasonably ensure that the information and material set out on its Web page is checked and updated and to evaluate that its sources are reliable and honourable.

    The above notwithstanding, the information, analysis, opinions and recommendations published in or through this Web page are provided solely for information purposes and are to be taken as guidelines. FIDENTIIS EQUITIES, its officers and employees, therefore, assume no liability therefor and neither guarantee nor assure that the content thereof is reasonable, accurate, complete, precise, appropriate, reliable or up-to-date.

    FIDENTIIS EQUITIES therefore shall be considered exempt of responsibility with regard to the content, accuracy, reliability and truthfulness of the Information, regardless of the form in which it is presented and the Users of the Web page, when taking their investment decisions, must assume the risks arising from using said information or recommendations and FIDENTIIS EQUITIES, its officers and employees, shall not be held liable therefor. Users are aware that they are responsible for their own investment decisions and that they should get their own professional advice about the suitability of any investment or investment strategy mentioned on the Web page.

    Any information or analysis included on the Web page has been drawn up solely for information purposes and FIDENTIIS EQUITIES is under no obligation to update said information or analysis. It is therefore possible that said information or analysis fails to reflect events that have taken place after the publication date.

    Access, surfing and security.

    Accessing and surfing on FIDENTIIS EQUITIES' Web page entails acceptance and knowledge of the legal warnings, terms and conditions of use set out therein.

    Users must specifically apply to access this Web Site. FIDENTIIS EQUITIES has exclusive rights to accept or reject such applications. In the event that FIDENTIIS EQUITIES accepts a User's request, access shall be activated using a system of passwords and codes provided by the Company to ensure that Users are identified and that the passwords and codes provided are secure and confidential.

    The code or password is confidential. If a User thinks that someone has had access to his code or password, he should notify FIDENTIIS EQUITIES accordingly, and FIDENTIIS EQUITIES shall proceed to modify said code or password forthwith.

    FIDENTIIS EQUITIES shall not be held responsible for nor shall it guarantee that access to this web site shall not be interrupted or that it is error-free or might cause damage. Under no circumstances shall it be held liable for any damages or losses of any kind resulting from accessing and using the Web page, including but not restricted to any damage to the computer systems or caused by computer viruses.

    FIDENTIIS EQUITIES shall, whenever nothing occurs that makes it impossible or difficult to do so, and as soon as it finds out about any errors or disconnections, do everything it can to remedy said errors and restore the connection.

    Whoever accesses or uses the Web Site shall be held solely liable for the access to the Web Site or any improper use of the information set out on the Web Site. FIDENTIIS EQUITIES shall not be held liable for any consequence, damage or loss that may result from such access or use. FIDENTIIS EQUITIES shall not be held liable for any security errors that may arise or for any damage that may be caused to the user's computer system (hardware and software), or to the files or documents stored therein, as a result of:

  • any virus that may be in the user's computer that is used for connecting to the services and content of the Web Site;
  • the browser not working properly;
  • failing to use the latest versions thereof;

     

    Any downloads of any material including software, or any computer file, shall be made entirely at the User's discretion and the User shall take full responsibility therefore. Users take sole responsibility for any damage to the User's computer system or any loss of data that results from downloading, installing or running any of this material.

    FIDENTIIS EQUITIES may modify unilaterally, without prior notice, whenever it deems appropriate, the Web Site's structure and design, and modify or remove any services, content and conditions for accessing and using the Web Site.

    When a User surfs the FIDENTIIS EQUITIES Web page, the User leaves a "trail" of the IP address assigned to the User for that session by the User's Access Supplier. The record of this IP address is used solely for internal purposes, such as the record of accesses to FIDENTIIS EQUITIES' Web Site.

    The IP address for the same User is different for each Internet connection, so there is no way of finding out about any particular User's browsing "habits" on FIDENTIIS EQUITIES' Web Site.

    FIDENTIIS EQUITIES shall not be held liable in any way for the content of links in the Web Site, whenever such content is outside the Web Site, nor does it guarantee that there are no viruses or other elements thereon that may alter the computer system (hardware and software), in the user's documents and files, excluding any liability for any damage of any kind caused to the user for this reason.

    Should any user, customer or third party consider that the content of the services provided by the linked pages are illegal or damage assets or rights of the user himself, a customer or a third party, that can be indemnified, they should send a notification form to the address Info@fidentiis.com and, in particular, whenever they consist of:

  • Activities or content that are likely to be deemed illegal under Spanish criminal law.
  • Activities or content that breach intellectual or industrial property rights.
  • Activities or content that cause a breach of the peace, criminal investigation, public safety or national defence.
  • Activities or content that endanger public health, do not respect public dignity and the principle of non-discrimination, the protection of health and children.

     

    Exchanging or disclosing information.

    FIDENTIIS EQUITIES shall not be held liable for any exchange between Users of information obtained through its Web page.

    Third-party information.

    Part of the content of the Web page is information provided by REUTERS. FIDENTIIS EQUITIES does not ensure or guarantee that this content or the information or the results obtained by using this information are accurate, up-to-date, suitable, complete or available.

    Data Protection.

    Before a User may use the Web page, FIDENTIIS EQUITIES shall ask the User to provide certain personal particulars (e-mail address, name, Company, etc.).

    FIDENTIIS EQUITIES informs the users that it abides by current law on the protection of personal data, the privacy of users and the secret and security of personal data, and for said purpose uses the technical and organisational resources needed to prevent the personal data provided from being lose, improperly used, altered, accessed by unauthorised persons or robbed, bearing in mind the state of technology, the nature of the data and the risks to which they are exposed.

    Accordingly FIDENTIIS EQUITIES shall treat the data in accordance with the principles of quality laid down by the Data Protection Act, Law 15/1999, dated 13 December, confidentially and using the security measures required by the Regulations developing the Data Protectin Act enacted by Royal Decree 1720/2007, dated 21 December.

    The data of a personal nature that is provided is recorded in a FIDENTIIS EQUITIES file, for the purpose of maintaining and managing the commercial relationships with the users of the web site and to promote the activities and services that it provides.

    By simply sending in their personal data to FIDENTIIS EQUITIES, Users shall be giving their consent for said data to be included in the file and processed.

    Users may revoke the consent given, albeit not retroactively, and use the rights to access, rectify, cancel and object, by sending a letter to the following mail address: Calle Velázquez 140, 2º Dcha., 28006 MADRID, or to the e-mail address: info@fidentiis.com.

    Users guarantee that the personal particulars provided to FIDENTIIS EQUITIES are true and shall take responsibility for giving notice of any change to said data so that they be up to date at all times.

    FIDENTIIS EQUITIES does not use cookies, these being deemed to be the physical files of personal information located in the user's own terminal, used for gathering information regarding the user's preferences. However, it reserves the right to change its criterion regarding the use of cookies. Users are able to configure their browser so as to prevent such files from being created.

    Intellectual and Industrial Property.

    The intellectual property rights of the content of the web page http://www.fidentiis.com/ its source code, graphic design, browsing structure, data bases and different elements that are contained therein belong to FIDENTIIS EQUITIES, who has the sole title to use the rights to operate them in any way and, in particular, the rights to reproduce, distribute, disclose to the public and transform.

    Therefore, they may not be reproduced, distributed, publicly disclosed or transformed, except for personal, private use. Likewise all the trade names, trademarks and distinguishing signs of any kind set out on the FIDENTIIS EQUITIES Web page are protected by Law.

    Any third-party link to the Web must be made to its home page. "Deep links" and "framing" are specifically prohibited, as is any other use of the content of the Web Site, for unauthorised third parties.

    Any unauthorised use or resale of the information content of the Web Site, or any damage to the intellectual property rights of FIDENTIIS EQUITIES, shall give rise to the liabilities laid down by law.

    FIDENTIIS EQUITIES acknowledges, as regards any third-party quotations or products or services the appropriate intellectual and industrial property rights. The mere fact that they are mentioned or appear on the Web page does not imply that FIDENTIIS EQUITIES has any right or liability whatsoever with regard thereto.

    The above notwithstanding, FIDENTIIS EQUITIES reserve all the rights to copyright, registered trademarks, patents, intellectual property and other property rights with regard to the content and design of the Web page.


    Fidentiis Equities S.V.S.A. provides independent advice, is regulated and supervised by the Spanish Exchange Regulator Authority "Comisión Nacional del Mercado de Valores (C.N.M.V.)" with Registration number 205.

    With respect to this any publication prepared by FIDENTIIS EQUITIES on investment recommendations, please refer for relevant information and disclosure to www.fidentiis.com/legal/disclaimer.asp?lang=EN


    FIDENTIIS EQUITIES S.V., S.A. and the User specifically waive any right they may have to any other jurisdiction and submit to the jurisdiction of the courts and tribunals of the city of Madrid (Spain), to settle any dispute that may arise with regard to the access to or use of the Web page: http://www.fidentiis.com

    CONFLICTS OF INTEREST POLICY

    European Markets in Financial Instruments Directive, (MIFID), and Spanish COMISIÓN NACIONAL DEL MERCADO DE VALORES (CNMV) local regulation, require companies acting in the financial services sector, to document and implement the handling of potential conflicts of interest which may arise in the normal exercise of their activities.

    We, as a registered Spanish Investment Company, have developed and implemented a set of measures to:

     

  • Identify the possibilities of having conflicts of interest,
  • Try to avoid them,
  • And, if necessary, solve them.

     

    Fidentiis provides research, institutional sales and securities trading services related to the Spanish, Portuguese and Italian Stock Markets. Fidentiis also provides securities trading in the German, French, Belgium, Swiss and Dutch markets.

    Therefore, the main possibilities of incurring a conflict of interest are identified as follows:

    a) Financial Analysis.

    We have taken a set of measures for the disclosure of possible conflicts of interest when preparing our reports.

  • An internal commission is responsible for reviewing and guaranteeing the independence of our opinions. An independent Board Member makes part of the commission.
  • When we have received any incentive or benefit from the analysed company during the past twelve months, it is stated in the report. The disclosure is clearly shown in the disclaimer of each report.
  • There is a "Restricted list" of equities, where employees are not permitted to trade in. This list is made up of stocks that we are preparing to publish research on and/or the equities included in our daily recommendations.
  • Compliance Department manages the "Restricted list". It is permanently updated and distributed to the staff and members of the Board of Directors.

    b)Proprietary trading

    Compliance Department has to approve any order for our Proprietary book after checking that the stock is not "Restricted". The Head of Trading has to check that there are no outstanding orders from clients for the same stock, before accepting Proprietary orders to assure no conflict, except when it is to the benefit of the client.

    c) Board members and other employees trading securities on their own interest.

    When their own investment decisions are taken, staff must inform to the Compliance Department, within a day, of any operations done on their behalf in the Spanish, Portuguese, Italian, French, Belgium, Dutch, Swiss and German Stock Exchanges.

    It is required that these positions are maintained for a minimum of three days before they can be undone.

    d) Asset Management Company in the same Financial Group.

    There is an Asset Management Company that is part of the same Financial Group as us. Orders received from that Company receive the same treatment, and are subject to the same Policy as the ones received from the rest of our clients.

    e) Trading and Execution issues.

    For avoiding Conflicts of interest regarding the execution of our clients' orders, we have in place our "Best Execution Policy" which also follows MIFID and CNMV legal regulation.

    In intermediary trades, Fidentiis Equities will be able to act as intermediary for the clients at the same time on both sides, buyer and seller, charging to all clients taking part, the usual trading commissions for brokerage in stock exchanges. In these cases, if the commission to be received from one of the parties in the trade or any of the terms of the relationship exceeds what is usually done in the market, the counterparty in that trade will be informed specifically and previously by Fidentiis Equities.

    Procedures to comply with legal and internal regulations and procedures, including how to manage and solve the Conflicts of Interests, are widely and accurately explained in our internal Operation Manual Handbook. Compliance Department is responsible for controlling and monitoring these issues and for keeping a register of them in case they arise.