Client conduct policy

Purpose and scope

This policy sets out the principles that guide the relationship between Andvisory 360 Financial Services ASF, SL and its clients and potential clients. It applies to the persons involved in providing the firm's services. The specific terms of each advisory relationship are set out in the contract and in the documentation provided to the client.

Management is responsible for applying this policy and for reviewing it periodically.

Authorisation and supervision

Andvisory 360 Financial Services ASF, SL is a financial advisory firm authorised and supervised by the Autoritat Financera Andorrana (AFA — Andorran Financial Authority), with registration number ASF-04/23. Its activity is subject to the applicable Andorran financial regulations and, in particular, to Llei 7/2024, del 27 de maig, sobre organització i funcionament de les entitats operatives del sistema financer i l'abús de mercats (Law 7/2024 of 27 May on the organisation and functioning of operating entities of the financial system and market abuse).

The client's best interest

We act honestly, fairly and professionally, in the best interest of our clients. This principle guides our understanding of their circumstances, the selection of instruments, the formulation of recommendations and the monitoring of the service on the agreed terms.

We provide clear, accurate and non-misleading information about the services, the recommended instruments, and the associated risks and costs, in sufficient time for the client to make informed decisions.

Independent advice and remuneration

Andvisory 360's advice is not tied to any particular banking institution. We analyse a range of financial instruments appropriate to the nature of the service and select our recommendations according to their suitability for the client.

The fees the client pays Andvisory 360 for the advisory service, and the method for calculating them, are set out in the contract and communicated before the service is provided. Andvisory 360 does not accept or retain commissions or other benefits from third parties in connection with the independent advice provided to the client, except for minor non-monetary benefits permitted by the regulations. If it receives a monetary amount from a third party attributable to this service, it allocates and transfers that amount in full to the client concerned in accordance with the applicable regulations.

Conflicts of interest

We maintain procedures to identify, prevent and manage conflicts of interest that may arise between the firm, the persons who work for it and its clients, or between different clients. Where the measures adopted are not sufficient to prevent a risk of harm, we inform the client of the nature and source of the conflict before providing the service concerned.

Andvisory 360 provides advisory services to the investment fund Fermo Fund FI (ISIN ES0136396001), for which it may receive remuneration from the management company. This relationship is expressly disclosed to clients to whom the fund is recommended and does not, in itself, determine the fund's inclusion in an advised portfolio.

Where a client receiving independent advice from Andvisory 360 is recommended to invest in Fermo Fund FI, the firm will calculate the portion of the remuneration received from the management company that is attributable to that client's investment and will transfer it to the client in full. The calculation method, frequency and form of repayment will be communicated to the client before the investment. The recommendation of the fund must likewise pass the suitability assessment and be duly justified.

Suitability of recommendations

Before making personal recommendations, we obtain the necessary information about the client's knowledge and experience, their financial situation — including their ability to bear losses —, their objectives, investment horizon, risk tolerance and, where applicable, sustainability preferences.

We explain to the client why the recommendation suits their circumstances. If we do not have the information needed to assess its suitability, or if none of the instruments or services considered is suitable, we refrain from making the corresponding recommendation.

Information, costs and monitoring

Before the contract is entered into and throughout the provision of the service, we inform the client of the characteristics and risks of the recommended instruments and of the costs and charges that must be disclosed. Recommendations and monitoring reports are provided through the means and at the frequency agreed with each client.

Professional competence and confidentiality

The persons who provide information or advice have the knowledge and competence required for their duties and keep them up to date.

We treat client information confidentially and in accordance with data protection regulations. Information on the processing of personal data is available in the Privacy policy.

Scope of the service and custody

Andvisory 360 provides investment advice. It does not hold client assets in custody or manage client portfolios on a discretionary basis. The assets remain with the custodian chosen by the client, who retains the decision whether to accept and place the recommended transactions. Andvisory 360 does not receive or transmit orders on behalf of the client.

Enquiries and complaints

Clients and potential clients may raise enquiries or file complaints free of charge. The procedure, the channels for submission and the contact details of the responsible function are set out on the Enquiries and complaints page.