ANTI-FRAUD POLICY

With the present policy Visolis Fund Trust ( “Visolis” or “Fund”) is defined the fraud prevention policy. 

FRAUD PREVENTION POLICY

Fraud occurs whenever a person brings about a malicious behavior designed to create his own economic advantage and to disadvantage an investor. Therefore it is considered that the cases of fraud may derive from the following factors, for which are provided the following safeguards, without prejudice to the fact that the Fund will report to the Judicial Authority any situation susceptible to integrate the details of a fraud. 

Fraud related to the bidder’s behavior

The Fund believes that the greater risk of fraud derives from the publication of false or incomplete information provided by the subjects qualifying as bidders (the "Offerors") in accordance with Article 2, paragraph 1, letter c) of CONSOB Regulation No. 18592 of June 26, 2013. The Fund, during the phase of investment selection, formally verifies the proposals of the bidders, aimed at evaluating the accuracy, completeness and transparency of the information provided during the preparation of the investments for the purpose of collection, possibly using of the work of external collaborators to confirm the actual. 

Fraud related to financial transactions

The services relating to the execution of the investment orders on the fund and of the acceptance to the risk capital subscriptions, will be managed by the depositary bank with which the fund has drawn an operating agreement (the "Bank"). Therefore, in this context are applied all anti-intrusion measures implemented by the Bank.

Fraud related to the publication of information  material

The fund publishes its investments on its portal (the "Portal") only after having done a careful evaluation of the investment projects, the benefit-risk ratio, the business plan and the lawfulness of the same. This allows the fund to carry out a correct and exact control on the contents of its investments, fully verifying the real prospects of success, highlighting in detail the positive and negative aspects of the investment. At the same time, checks are done on the lawfulness and truthfulness of the documents provided during the selection process. This verification will allow the investor to have an exact picture of the project in which he invests his savings, while avoiding the risks of fraud.

 

CONFLICT OF INTERESTS POLICY

Visolis Fund Trust is an Italian investment company, which acts as a promoter of investments in Italy. Visolis looks after the costumer’s interests in carrying out its business.

Visolis Fund Trust, from time to time, may be exposed to potential conflicts of interest, of its partners and employees on one hand, and those of its clients on the other, and conflicts between the interests of the various customers.

Visolis Fund Trust implements all appropriate measures to identify and prevent or manage conflicts of interest between its managers and its employees, any person directly or indirectly connected to it for control reasons, its customers and among the various customers, who may arise at the level of supply, by Visolis, of investment services and ancillary services, or from the combination thereof, including cases attributable to third-party incentives or fees paid directly by investment companies and other forms of incentives.

Visolis Fund Trust has defined policies and procedures to identify, manage and limit the conflicts of interest that may arise during the course of its business. For example, organizational and administrative mechanisms to protect customers' interests. A fundamental element of this policy is that people who perform various commercial activities involving a conflict of interests must carry out these activities independently of each other. These policies are subject to supervision and continuous review by the C.d.A. of Visolis Fund Trust and the local superior management.

​If necessary, the Visolis Fund Trust maintains at least the following procedures to be chased, and the following measures to be taken:

  • Effective procedures to prevent or control the exchange of information between responsible persons committed to activities that involve a risk of conflict of interest, in the event that the exchange of information may damage the interests of one or more customers;

  • Separate supervision of the responsible persons whose main functions involve the performance of activities or the supply of services on behalf or in favor of customers, whose interests may be conflicting or in any case who represent different interests that may conflict;

  • The elimination of any potential direct links between the remuneration of the persons responsible mainly committed to an activity and the remuneration of, or the income produced by, other responsible persons engaged mainly in another activity, where conflicts of interest may arise in relation to these activities;

  • Measures to prevent or limit the possibility that a person exercises improper influence on the way in which a responsible person performs investment or ancillary services or activities;

In some cases, the Visolis Fund Trust procedures and controls may not be enough to guarantee that a potential conflict of interest does not harm the interest of a particular customer. In the event that the organizational or administrative mechanisms introduced by the Visolis Fund Trust to prevent conflicts of interest from negatively affecting the customer’s interests, are not enough to guarantee with reasonable certainty to prevent the risks for the customer’s interests to be damaged. Visolis Fund Trust, as a last resource, informs customers of the general nature and / or origins of the conflict of interest and the measures taken to reduce the risks before carrying out activities on their behalf.

COMPLAINT HANDLING POLICY (claims)

With the present fund policy defines the terms and methods with which the contractors of Visolis Fund Trust (the "Customers"), whether they are subjects qualifying as bidders (the "Offerors") pursuant to Article 2, clause 1, letter c) of CONSOB Regulation No. 18592 of June 26, 2013 (the "Regulation") or as an investors pursuant to the Regulation (the "Investors"), may submit complaints to Visolis regarding the service offered. 

Claims must be presented in the specific area of the Portal

These complaints must contain the identification data of the complainant (name, surname / company name, residence or registered office) and the addresses to which the claimant wants to be contacted, as well as the specific reasons on which the complaint is based.

The complainants' personal data will be processed in accordance with the privacy report available in the specific area of ​​the Portal.

 

Visolis fund commits to notify the Customer of the outcome of the complaint within 7 (seven) working days from its receipt, as long as it contains all the elements necessary for its evaluation.

In this regard, Visolis fund reserves the right, within the same term of 7 (seven) working days from receipt of the complaint, to ask for clarifications about the content of the complaint. In this case the answer will be provided within 5 (five) working days of receipt of the requested clarifications.

The answers will contain the reasons why Visolis fund considers the claim to be founded or not. In the event that the claim is considered founded, Visolis fund will inform the Customer of the measures and timing in which it intends to resolve the problem reported by the complainant and remedy any damage suffered by the latter. In the event that the claim is considered unfounded, the Visolis fund will provide the complainant, in addition to the reasons behind his decision, with the necessary information to appeal, where he considers it worthwhile, and with out-of-court dispute resolution systems.

Disregarding the specific previsions relating to the resolution of disputes contained in the information material present in the portal applicable to Investors and Offerors, where requested by the Complaint on a voluntary and non-obligatory basis, may find application the legal action in front of the Arbitrator for Financial Disputes ( ACF), established by the CONSOB regulation n. 19602/2016. More information on the procedure before the ACF is available at:  http://www.consob.it/web/area-pubblica/arbitro-per-le-controversie-finanziarie