LYNX Asset Managers is a financial broker registered the Portuguese Securities Market Commission (CMVM) (under number 328), and the Investor Compensation Scheme (ICS) (under number 129 of 17-09-08).

Investor Compensation Scheme

The Investor Compensation Scheme (ICS) is a legal entity, established under the terms of Decree-Law 222/99 of 22 June, which operates jointly with the Portuguese Securities Market Commission (CMVM). The ICS aims to protect investors in case an investing company is not able to repay or refund the money or financial instruments held by them.

The ICS protects investors, but institutional investors are excluded. Maximum compensation is 25,000 Euro per investor (and not per account) in case the FI does not repay the securities to the customer (for more information, please visit: www.cmvm.pt)

Money deposit

Pursuant to the legislation in force, when opening an account, LYNX Asset Managers deposits the money received from its customers in global (jumbo) accounts opened with credit institutions on behalf of LYNX Asset Managers for its customers.

LYNX Asset Managers acts with particular diligence when selecting those credit institutions by checking whether they are legally qualified to provide this service, and learning about their reputation and solvency. Concurrently, LYNX Asset Managers keeps accounting records concerning the individual accounts of its customers, which are separated from LYNX’s assets.

Conflict of Interest Policy

To safeguard the interest of its clients, LYNX has added a conflict of interest policy to its Internal Regulation that sets forth a number of rules and procedures which must be followed by all employees in the sense of treating all clients with transparency and fairness and ensuring that their interests take precedence over the interests of LYNX or its employees.

Compliance Office

The Compliance Office aims to ensure internal and external rules and standards are complied with and disseminated to all areas of the organisation and respective employees. This office contributes to a culture of internal control, guaranteeing the respect for ethical values and mitigating the risks in the execution of Society’s activities.

Pursuant to the national law and legislation and the recommendations of international agencies, LYNX Asset Managers implements a set of policies and procedures destined to prevent company’s operations from being used for money laundering and terrorist financing and therefore bringing any additional operational and reputational risks.

The society executes the ‘know your client’ policy strictly, which has been divided into four key areas:

– ACCEPTANCE of clients.

– IDENTIFICATION of clients.

– MONITORING of clients and operations.

– RISK MANAGEMENT concerning the risk of money laundering and terrorist financing.

This way, LYNX Asset Managers complies with all procedures required to fight any type of criminal activity, reinforcing acknowledgement and prevention instruments and keeping the ethical standards inherent to the society’s professional practice.

The society further monitors special processes, via the reinforced exercise of Due Diligences, pursuant to the Identification and Acceptance of Client Policy, namely concerning the opening of accounts/contracts and validation of the KYC (Know your Customer).

As to the best practices, LYNX Asset Managers also monitors operations and guarantees that all internal and external Compliance policies are adopted and maintained by providing the relevant authorities with all information required by law. Through a transparent operation regime, the society encourages all direct and indirect employees to comply with the best practices, promoting the strict compliance with the code of ethics and internal regulations of the society.