The client may communicate with the advisor and receive documents and information in Italian.

The sending of letters, informative notes, statements, any notifications, and any other written statement or communication, including changes to the information contained in this document, unless otherwise provided by law or contract, will be made to the client at the address indicated at the time of contract signature or subsequently communicated in writing.

The client may choose, at the time of signing the contract related to the advisory service or with subsequent written communication, to receive information through non-paper durable medium, particularly via email. To this end, the client will indicate a valid email address accessible only to them and commits to keeping it active (or to communicate a different valid email address in writing) until 14 months after the dissolution of the contract.

Communications and/or any notifications to the advisor must be made by the client to the advisor’s address or via certified email to the addresses mentioned above.

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

It is declared that the advisor is registered in the section of the register referred to in art. 18 bis of the Legislative Decree 24.2.1998 (TUF) held by the Supervisory Organization (ODV) provided for by art. 31, paragraph 4 of the aforementioned decree, with Resolution dated 19/03/2024 No. 2425.

The name and contact address of the Organization are:

OCF
Ufficio Albo Consulenti Finanziari UACF – Roma
Via Tomacelli 146
Staircase B – 4th Floor
00186 Roma

The advisor sends the client the following reports related to the provision of advisory service:

• Within 30 days from the end of each quarter/semester/calendar year, a report containing the composition and performance of the portfolio
• Within 60 days from the end of the calendar year, a report containing:

1. An updated statement indicating the reasons why the portfolio matches the preferences, objectives, and other characteristics of the client
2. The recommendations provided in the reference period
3. In aggregate form, the costs and charges of the service provided and of the financial products and services subject to recommendation

Pursuant to art. 177 of the Intermediaries Regulation, the advisor has adopted a conflict of interest policy aimed at:

• Identifying, in relation to the investment advisory service, the circumstances that generate or may generate a conflict of interest that could harm the interests of one or more clients, including their sustainability preferences
• Defining the procedures to follow and measures to adopt to prevent or manage such conflicts

The procedures and measures adopted aim to identify and prevent conflicts of interest that may arise between the advisor and the client or between the client and other clients of the advisor at the time of the provision of the service covered by this contract, in order to prevent such conflicts of interest from negatively affecting the client.

Should the measures adopted not be sufficient to avoid with reasonable certainty the risk of harming the client’s interests, the advisor will clearly inform the client on a durable medium about the general nature and/or sources of potential conflicts of interest arising from the recommendations provided, as well as the measures taken to mitigate the associated risks, so that the client can make an informed investment decision.

The client may request from the advisor further analytical details about the conflict of interest management policy at the previously indicated contacts.

The advisor provides investment advisory services as defined in Article 1, paragraph 5, letter f) of the Consolidated Law on Finance (TUF), consisting of “providing personalized recommendations to a client, upon their request or at the initiative of the service provider, regarding one or more transactions involving financial instruments”.

Specifically, the service provided by the advisor includes:

• Analyzing the allocation of the client’s overall portfolio and assessing the efficiency of the held products
• Potentially reformulating the asset allocation of the portfolio and the instruments and financial products held based on information provided by the client
• Conducting periodic assessments, on an annual basis, of the portfolio’s adequacy

The personalized recommendations provided to the client in the execution of the service may cover a wide range of financial instruments related to the following categories listed in Annex 1, Section C, of the TUF:

• Securities
• Shares and units of collective investment schemes (CIS)

The personalized recommendations may also concern financial products different from financial instruments, such as financial products issued by insurance companies and financial products issued by banks, as well as portfolio management services and order reception and transmission services.

The advisor reserves the right to perform the ancillary services referred to in no. 3 and no. 5 of Annex 1, Section B, of the TUF. The provision of non-personalized recommendations is not envisaged. Regarding any further professional activities carried out by the advisor, it is specified that they are not subject to the supervision of Consob or the Organism. The aforementioned advisory activity is directed both at retail clients and professional clients. In carrying out the activity, the advisor is not obligated to update the recommendations given to the client or to inform the client of losses incurred on the instruments subject to recommendation.

The client is free not to proceed with the investment/disinvestment operations recommended under this contract. The service can be provided by the advisor in a location different from their residence.

The advisor is not authorized to execute the operations recommended to the client, who may carry them out through authorized intermediaries (banks, SIMs, SGRs) within the scope of investment services and activities provided by them. As remuneration for the provision of the advisory service, the client is required to pay the advisor a fee commensurate with the content and value of the service. In the absence of a unique method of compensation quantification, it may vary based on the complexity and size of the assets under advisory, the objectives and risk profile of the client, and, generally, the time the advisor will dedicate to analysis and study on the specific case. Therefore, the advisor commits to submitting to the potential client, after they have provided the necessary information summarized above and before they are bound by an agreement for the provision of the advisory service, a customized fee estimate.

The methods and timing of payment will be specified in the aforementioned estimate. The fee paid by the client constitutes, by legal forecast and contractual obligation, the only form of remuneration for the advisor for the services provided to the client; the advisor is prohibited from receiving compensation (incentives) from third parties.

The advisor is required, by professional ethics, to be independent concerning the issuers of the financial products recommended, as well as in relation to the intermediaries authorized to perform investment services within which the client executes the recommendations. In the provision of the advisory service, the advisor cannot hold funds or securities belonging to clients.

The client and the advisor may agree that the advisor has the authority to view the client’s investments at banks, financial intermediaries, or asset management companies the client uses, without any authorization to operate. They may also agree that these investment firms directly send the advisor information on the operations executed by the client.

For more information on the contents of the advisory service and the obligations of the advisor and client, please refer to the investment advisory contract that must be signed in advance of the provision of the service.

In the provision of investment advisory services, the advisor provides the client with recommendations related to investment or divestment operations that, if executed, allow for the portfolio’s adequacy in relation to the client’s profile reconstructed based on the information provided through the completion of the questionnaire submitted before the conclusion of this contract or on the occasion of any subsequent updates.

Specifically, the advisor verifies that the recommended operation:

• Matches the investment objectives of the client, including their risk tolerance
• Is such that the client can financially bear the risks associated with the investment in line with their investment objectives
• Is such that the client possesses the necessary knowledge to understand the risks associated with managing their portfolio

The advisor conducts a periodic assessment of the portfolio’s adequacy on an annual basis.

The adequacy assessment is carried out to enable the advisor to act in the best interest of the client. It is therefore essential that the client, by completing the questionnaire provided by the advisor, supplies correct and updated information concerning:

• Their knowledge and experience in the field of investments regarding the specific type of product or service
• Their financial situation, including their ability to sustain losses
• Their investment objectives, including their risk tolerance
• Their sustainability preferences

The client is required to communicate any updates of the information to the advisor. The aforementioned information allows the advisor to understand the essential characteristics of the client and to recommend financial products and investment services that are appropriate with particular reference to their risk tolerance, their capacity to sustain losses, and their sustainability preferences; if the client does not provide the information requested in the questionnaire, the advisory service cannot be provided.

The client must be aware that incorrect or untruthful responses can compromise the reliability of the adequacy assessment and reduce their level of protection. The advisor is required to refrain from making recommendations if none of the financial products and investment services are suitable for the client.

Pursuant to Article 165, paragraph 1, letter h-bis of the Intermediaries Regulation, in the process of selecting financial instruments subject to the investment advisory service, the advisor integrates an evaluation regarding environmental, social, and governance (ESG) sustainability factors, to ensure that various products and instruments can be recommended only to clients who express sustainability preferences compatible with the characteristics of these instruments.

Since the advisory provided by the advisor pertains to the financial portfolio as a whole, the evaluation of sustainability factors is conducted at the portfolio level. This means that, overall, the portfolio must align with the client’s sustainability preferences; however, for reasons of risk management or achieving the client’s objectives, some individual instruments used may not align with said preferences.

The evaluation of environmental, social, and governance sustainability characteristics is carried out depending on the type of instrument/product according to the information declared by the issuer under current regulations or using external evaluation models (ratings) and/or analyses conducted internally.

Massimiliano Silla offers the following additional activities beyond investment advisory service:

• Consulting for the assessment and coverage of pension integration needs
• Consulting for identifying and quantifying family unit risks
• Consulting for personal and family financial planning
• Consulting for family succession planning

Although personalized, the above activities do not focus on specific financial instruments or financial products. The conduct of the mentioned activities is regulated by a specific contract, separate from that related to the investment advisory service, which involves the payment of a fixed or variable fee, agreed upon with the client from time to time, commensurate with the content and value of the service provided. The activities mentioned above are not subject to the supervision of Consob and the Organism, nor to the supervision of other authorities.

In providing advisory service, the advisor is not focused on specific categories or a specific range of financial instruments. The advisor does not propose standardized investment strategies but evaluates the most suitable strategy for each client, considering the client’s investment objectives, risk tolerance, and financial situation, including their capacity to sustain losses.