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).

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)

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.

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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.

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.

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.

Legal Framework

Directive 2014/65/EU of 15 May 2014 and related legal instruments on the marketing in financial instruments became effective in January 2018 with the goal of strengthening transparency, investor protection, and service quality and mitigating conflicts of interest.

The MiFID II sets forth that companies providing investment services act in accordance with the best interests of its clients (article 24 of the MiFID II) and, when executing orders, adopt all measures required to obtain the best possible result for their clients (article 27 of the MiFID II and article 333 of the Portuguese Securities Code – hereinafter “CMV”), taking into account price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order.

These amendments are included in a bundle that contains the MiFID II, the MiFIR (Regulation (EU) No. 600/2014 of the European Parliament and of the Council of 15 May 2014), two delegated regulations of the European Commission, one delegated directive of the European Commission and a relevant set of Regulatory Technical Standards and Implementing Technical Standards (RTS/ITS).

In addition to the amendments made by the MiFIDII, the MiFIR introduces significant changes in terms of the transparency of pre- and post-trade information and the information concerning the reporting of transactions.

Client Classification

Financial brokerage clients can be categorized as i) professional, ii) retail, or iii) eligible counterparties. Professional investors are distinguished: 1. “by nature”, i.e. those whose categorization is pursuant to the law, or 2. “by request”, i.e. retail investors which have requested to be treated as professional investors. The law sets forth a higher degree of protection for professional investors than for retail investors. Retail investors can request that LYNX treats them as professional investors. Meeting this requirements will depend on a prior assessment of the Client’s knowledge and experience that guarantees that Clients are able to make their own investment decisions and understand the risks involved, given the nature of the services, financial instruments, and operations contracted.

In this case, the Client must meet two of the following requirements: 1. Have made a significant volume of operations in the relevant market, an average of 10 operations per quarter, in the last four quarters. 2. Have a financial instrument portfolio that also includes deposits (demand or time) that exceed (euro) 500,000. 3. Have performed duties in the financial market for at least one year under a role that required them to know the services or operations in question; 4. Show that they can make their own investment decisions and that they understand the risks inherent to the service, financial instruments, and operations in question (qualitative test). Eligible counterparty is the classification usually given to banks, other financial institutions and national governments and corresponds to a category that offers a lower degree of protection.

Reception, Transmission and Execution of Orders Procedure Introduction

The MiFIDII has reinforced the duties to provide clients and the public with information concerning the execution of orders in the best conditions. The Reception, Transmission and Execution of Orders Procedure describes the rules, mechanisms, and other procedures that apply to the execution of orders from Clients and/or the transmission of orders to agencies that are authorized to execute orders, to ensure compliance with the applicable legal standards arising from the MiFID II, MiFIR and other legal instruments and legal or regulatory rules that complement such instruments.

Scope

This procedure applies to the service provided by LYNX concerning the reception, transmission and/or execution of orders of financial instruments given by Clients classified as “Retail” and “Professional”, under the MiFIDII, but does not apply to clients classified as “Eligible Counterparties”.

Criteria and Factors for obtaining the best execution

The rules that apply to Investment Management and Portfolio Management are: 1. Best conditions, where investment decisions made by LYNX must be executed by the counterparty that can execute them in the best conditions, considering the price, costs, speed, likelihood of execution and settlement, size, nature or any other relevant factor. 2. Best execution, concerning each financial intermediary, LYNX has identified the financial intermediaries to which orders are transmitted and which have the means that allow for the best execution of orders.

3. Quality control, operations made are duly controlled to prevent errors or, if applicable, to correct any failure that is detected. 4. Annual assessment, LYNX assesses the effectiveness of the policy that was adopted annually or whenever a relevant event occurs, particularly whether the agencies are complying with legal requirements and the quality of order execution by the financial intermediaries identified, which leads to changing the policy if any defect is encountered that compromises the best execution conditions, namely non-compliance with service levels, which must be monitored continuously. 5. Communication to clients, LYNX must notify its Clients and keep the supporting documentation updated regarding changes adopted in the selection of the financial intermediaries identified, as well as guarantee that the participants know and understand the execution policy that was adopted and all relevant amendments made to such policy. To obtain the best results possible concerning the execution of orders given by the Clients, LYNX considers the following criteria: 1. client profile (including their categorisation as Professional or Retail Client). 2. the characteristics of the order given by the Client. 3. the characteristics of the instrument that is the object of such order. 4. the characteristics of the centres where such order can be executed in the best way possible. To safeguard the interests of its Clients, when executing or transmitting orders concerning operations of the Clients, LYNX takes into account relevant factors, such as the quantity, nature of order or operation, price, costs, in relation to orders, data, exact time of transmission of order and identification of financial intermediaries to which the order was transmitted, in relation to executed operations, date, exact time when trade decision was made and operation was executed, likelihood of execution and settlements, speed in execution, as well as any other consideration relevant to the execution.

Means for reception, transmission and execution of orders concerning financial instruments

Client instructions must be assessed before the execution of the order, by recognising the client’s signature by similarity. Orders given by telephone, fax or e-mail are only accepted if the specific requirements established by LYNX for such orders are complied with before order execution.

Protection of Client Assets

LYNX guarantees that all procedures and accounting records that keep client assets safe are implemented. Adopts procedures for this purpose that are aligned with the standards from the supervisory entities in this matter (see Deposit Guarantee Fund and Investor Compensation Scheme).

For more information concerning the Marketing in Financial Instruments Directive II, please check the website of the CMVM. https://www.cmvm.pt/en/Investor_area/invest_protect/investorProtect/dmif2/Pages/dmifII_rmif_menu.aspx

Transparency and Support Duties

Following the entry into force of the MiFIR on 1 January 2018, legal persons must hold a legal entity identifier (LEI) to make any transaction in a regulated market and over-the-counter (OTC) market associated to financial instruments (shares, securities, bonds, shares in investment funds, commercial paper, treasury bills, CDFs, futures contracts and options about financial markets, forward rate agreements, and swaps).

Supporting Information

MiFID II [Marketing in Financial Instruments Directive II]

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014L0065&from=PT

MiFIR [Marketing in Financial Instruments Regulation]

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014R0600&from=PT

Useful information Answer to frequently asked questions about the RTS and ITS in the scope of the MiFIDII/MiFIR:

https://www.cmvm.pt/en/Investor_area/invest_protect/investorProtect/dmif2/Pages/qa-about-mifid_and_mifir.aspx

Institutional Information

Name LYNX – Asset Managers, SGOIC S.A. (LYNX)

Address Av. Duque D’Ávila, 185– 4º D 1050-182 Lisboa, Portugal

Legal status Public Limited Company

Share Capital € 1,050,000

Taxpayer ID and Registered in the Commercial Registry Office of Lisbon under no. 507 929 934 § Supervisory Agencies Portuguese Securities Market Commission (www.cmvm.pt)

Code with CMVM 328

External Auditors BDO, SROC SA § Chartered Accountant: AASCSGA, SROC (Ana A. Santos, C. Sousa Góis & Associado, SROC, Ld.ª)

Compliance contact Av. Duque d’Ávila, 185 – 4º D – 1050-082 Lisboa, Portugal Telephone: + +351 351,211 534; Fax: +351 211 534 097 / compliance@lynxassetmanagers.com

National and International Standards

LYNX observes the recommendations of the FATF/GAFI, which constitute an updated, complete, and consistent list of measures to prevent money laundering and combat terrorist financing.

LYNX follows the recommendations posted in www.portalbcft.pt, which was created and is maintained by the AML/CFT Coordination Committee. This portal provides up-to-date, structured information and examples of the best practices in each actuation area and encourages and recommends that all Clients and Employees check and use it, given that:

• The portal contains relevant links to the pages of the Information Intelligence Unit and sectoral authorities, as well as other national and international agencies with responsibilities in terms of preventing money laundering and combating terrorist financing.
• Contains relevant information to the general public, namely periodic assessments and reports in the areas of anti-money laundering and combating the financing of terrorism that must become public knowledge.

LYNX complies with the legal frameworks and regulations in force, with the most relevant being:

• Portuguese Penal Code (where Article 368-A typifies the laundering crime).
• Law No. 97/2017 of 23 August 2017 – Governs the application and execution of the restrictive measures approved by the United Nations or by the European Union and sets forth the sanctions applicable to breaches of such measures.
• Law No. 96/2017 of 23 August 2017 – Sets the criminal policy objectives, priorities and guidelines for 2017-2019.
• Law No. 92/2017 of 22 August 2017 – Requires the use of a specific means of payment in transactions involving amounts equal to or greater than EUR 3000.
• Law No. 89/2017 of 21 August 2017 – Approves the Legal Regime of the Central Register of Beneficial Ownership.
• Law No. 83/2017 of 18 August 2017 – Sets forth preventive and repressive measures to combat money laundering and terrorist financing.
• Law No. 15/2017 of 3 May 2017 – Forbids the issue of bearer securities,
• Law No. 72/2015 of 20 July 2015 – Defines the objectives, priorities and guidelines of the criminal police for 2015-2017.
• Law No. 52/2003 of 22 August 2003 – Sets forth measures to combat terrorism.
• Law No. 5/2002 of 11 January 2002 – Lays down measures to combat organised crime and economic and financial crime and provides for a special system for the collection of evidence, the violation of professional secrecy and loss of assets to the State in relation to unlawful acts of a specified type, such as money laundering and terrorist financing.
• Decree-Law No. 123/2017 of 25 September 2017 – Sets forth the scheme for the conversion of bearer securities into nominative securities, in execution of Law no. 15/2017 of 3 May 2017.
• Decree-Law No. 61/2007 of 14 March 2007 – Approves the legal system governing the control of cash carried by natural persons entering or leaving the EU through the Portuguese territory, and the control of cash movements with other EU Member States.
• Resolution No. 88/2015 of the Council of Ministers of 1 October 2015 – Establishes the AML/CFT Coordination Committee.
• Ministerial Order No. 345-A/2016 of 30 December 2016 – Amends Ministerial Order No. 150/2004, which establishes the list of countries, territories and regions with privileged taxation systems.
• Portuguese General Tax Law – Article 63-C imposes the mandatory use of bank accounts only for corporate activities, as well as – where invoices or equivalent documents are equal or higher than 1000 EUR – the use of payment methods that allow to identify the respective recipient.
• General Regime on Tax Infractions – Article 129 sets forth the fines that apply to offences arising from the violation of obligations set forth by article 63-C of the General Tax Law.
• Notice of Banco de Portugal No. 8/2016 of 30 September 2016 – Establishes the duties of registration and communication to the Bank of Portugal of payment operations, corresponding to payment services, whose beneficial owner is a natural or legal person having its head office in an offshore jurisdiction, as well as the conditions, mechanisms and procedures for complying with such duties.
• Notice of Banco de Portugal No. 5/2008 of 1 July 2008 – Defines the conditions, mechanisms and procedures deemed adequate and necessary for performing the internal controls for monitoring compliance with legal ML/TF prevention requirements.
• Notice of Banco de Portugal No. 9/2012 – Approves the Report on the Prevention of Money Laundering and Terrorist Financing (RPB) and sets forth the mandatory annual completion and submission of such report to Banco de Portugal via the BPnet system.
• Notice of Banco de Portugal No. 7/2009 of 16 September 2009 – Prohibits credit granting to entities having their head office in an offshore jurisdiction considered as non-cooperative or whose ultimate beneficiary is unknown.
• Notice of Banco de Portugal No 5/2008 of 18 December 2008 – Defines the principles and minimum requirements that should be observed by the financial institutions’ internal control system.
• Instruction No. 9/2017 of 3 of July of 2017 – Identifies and sets forth the requirements that apply to proof procedures under point c) of article 18(5) of the Notice of Banco de Portugal No. 5/2013 for compliance with the identification duty set forth by article 7 of Law 25/2008 of 5 June 2008.
• Instruction No. 46/2012 of 17 December 2012 – Approves the Self-Assessment Questionnaire (QAA) in terms of AML/CTF by setting forth the annual completion and submission of such questionnaire to Banco de Portugal via the BPnet system.
• CMVM Regulation no. 3/2015 – Venture Capital, Social Entrepreneurship and Specialised Alternative Investment.
• CMVM Regulation no. 2/2015 – Collective Investment Undertakings (Securities and Real Estate) and the Marketing of Individual Open-End Pension Funds.
• Deliberation no. 998/2017 of 9 November 2017 – Procedures concerning the compliance with the obligation of communicating operation start and real estate transactions made.
• Regulation no. 282/2011 of 6 May 2011 – Governs the obligations set forth by Law no. 25/2008,
• the Circular Letters of Banco de Portugal and/or CMVM and/or Regulation (EU), which impose restrictive measures against certain persons and entities.
• For more information, please check the Legislation page at www.portalbcft.pt, where you can find the updated, effective legislation.

Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) Measures Adopted by LYNX

LYNX has internal policies and procedures in place that guarantee the compliance with the national AML/CFT legislation.

LYNX applies the following relevant policies and procedures:

• Risk Assessment, which is an essential process to prevent and combat money laundering and terrorist financing that promotes a risk-based approach. By using this approach, LYNX focuses more on controlling clients, products, markets, transactions or counterparties that present the biggest risk of money laundering and terrorist financing.
• Preventive duties that impose a vast range of AML/CFT obligations, among others. Highlights go to: Obligation of control; Obligation of Customer identification and customer due diligence; Obligation to issue suspicious transaction reports; Obligation to refrain from carrying out transactions; Obligation to refuse to carry out transactions; Obligation to keep documents and records; Obligation of scrutiny; Obligation to cooperate; Obligation of non-disclosure; Obligation to train staff.
• Knowing and Monitoring the Client, which ensures compliance with the obligation of identifying every Client, monitoring operations made via computer records. Every new account that is opened is checked against the lists of suspects and terrorist organisations notified by the relevant authorities.
• Politically Exposed Persons (PEPs) and holders of other public positions are identified, and the monitoring of their operations reinforced (both as Clients and beneficial owners).
• Document Retention, which lasts 7 years after the operation has been made, even when the commercial relation has terminated.
• Monitoring of Suspicious Operations, which is made using a risk-based approach.
• Reporting of Suspicious Transactions is made pursuant to the internal policies and procedures to comply with the obligation of reporting to the Attorney General’s Office and the Financial Intelligence Unit of Polícia Judiciária all transactions that may constitute the practice of money laundering or terrorist financing.
• Reporting of relevant bank account transactions and verification of transfers: LYNX reports all relevant suspicious bank operations above €15,000 (or less, if suspicious) to the Attorney General’s Office and the Financial Intelligence Unit of Polícia Judiciária. Transfer details are checked (LYNX uses the banking system for this purpose).
• Training in PF_MLTF is given to all Employees, every six months, unless there are changes that require shorter intervals. – Compliance is exercised independently.
• Sanction Policy: LYNX does not establish or keep business or operation relationships with persons or entities from sanctioned countries.

Mis-selling Prevention Policy

LYNX Asset Managers SGOIC SA has a Mis-Selling Prevention Policy.

LYNX has a set of measures in place to prevent and mitigate risks associated to the mis-selling of investment products.

The measures we deem essential are those concerning governance, remuneration policy, marketing and recommendation of products. According to the governance, the Board of Directors is responsible for the decision-making process and the assurance of independent and influential duties of the Compliance department, as well as for the control and guidance towards an ethical, socially responsible information culture that ensures the interests and trust of clients (whether professional or retail) at all levels of company’s operation. The remuneration policy excludes commercial bonuses and incentives to Employees and Intermediaries. The marketing and recommendation of products policy promotes greater, improved quality of the services provided to clients, improving the quality of information given, both in terms of content and form, and reinforcing Employee training requirements, as well as internal control and execution mechanisms. We have absolutely defined that the governance and product monitoring conduct must focus on client’s interests and rely on our knowledge of their profile. We further seek to promote financial literacy of savers and investors so that their investment decisions can be make from a place of increased knowledge, responsibility, and awareness.

1. Scope

LYNX Asset Managers, SGOIC, S.A., collective person 507929934, with registered office at Av. Duque D'Ávila, 185, 4D 1050-082, in Lisbon, in the scope of its activity, guarantees the protection of the personal data collected, processed and stored by it, ensuring that their processing is done in accordance with the General Data Protection Regulation (EU) 2016/679, of the European Parliament and of the Council, of 27 April 2016, and other applicable national legislation, as well as the duties of confidentiality, through its Privacy Policy.

2. Purpose

The purpose of the present policy is to establish and ensure compliance with the rules applicable to the processing of personal data and to ensure the rights of the data subject, namely by LYNX.

This Privacy Policy applies exclusively to the collection, processing and storage of personal data by LYNX.

a) Entity and contact details of the Person Responsible for processing personal data

LYNX Asset Managers, SGOIC, S.A.

Duque D'Ávila, 185, 4D 1050-082 Lisboa

Telephone: (+351) 211 534 090

E-mail address: info@lynxassetmanagers.com

b) Data Protection Officer Contact Details (DPO)

LYNX Asset Managers, SGOIC, S.A.

Duque D'Ávila, 185, 4D 1050-082 Lisboa

Telephone: (+351) 211 534 090

E-mail address: protecaodados@lynxassetmanagers.com

3. Definitions

To facilitate the understanding of this Policy, the following definitions are used:

- Personal data: any information relating to an identified or identifiable natural person (the "Data Subject"); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, electronic identifiers or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

- Processing of personal data: means any operation or set of operations which is performed upon personal data or upon sets of personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, deletion or destruction.

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- Personal data controller (controller): the natural or legal person who determines the purposes and means of the processing of personal data.

- Subcontractor or processor: natural or legal person, who processes personal data on behalf of LYNX (controller), in the context of the provision of services, formalised through an Agreement.

- Supervisory authority: an independent public authority which, in the case of Portugal, is the National Commission for Data Protection (CNPD), responsible for supervising the correct application of the legislation on personal data protection.

4. What personal data is collected and processed by LYNX?

LYNX processes the personal data it collects as part of the commercial relationship established with its customers (actual or potential), and in order to comply with applicable legal and regulatory obligations.

The personal data that is collected and processed by LYNX, as a general rule, are: full name, photograph, place of birth, nationality, date of birth, identification document number and validity, marital status, tax identification number, address, email, telephone and/or mobile phone number, educational qualifications, employment status, name of employer, financial and asset information, investor profile, level of risk of money laundering and terrorist financing.

Other personal data may be requested, such as, in particular, property system, affiliation and other elements of an economic, social or political nature.

Principles observed

In the processing of personal data that LYNX carries out, it observes the principles of lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; limitation of storage; integrity; confidentiality and responsibility.

5. What are the Channels for Collecting Personal Data?

Personal data is collected directly from the data subject itself, via email, telephone/mobile phone and/or an Agreement between both parties and indirectly via partners or third parties, including legal representatives.

6. Use and Purpose of Collected Personal Data

The personal data collected is treated in strict compliance with the rules and principles of the General Data Protection Regulation, as well as the applicable national legislation, and in no situation shall the data collected be processed and kept without legitimacy and lawfulness for that purpose.

In this context, personal data, processed by LYNX, may be based on the need to perform an Agreement to which the data subject is a party or in order to comply with pre-contractual procedures at the request of the data subject.

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Compliance with a legal obligation to which the controller is subject, as well as processing for the purposes of legitimate interests by LYNX or third parties, shall also be lawful and valid grounds for the collection and processing of personal data, as shall any other purpose for which consent has been given by the data subject.

7. How long will the Personal Data be kept?

LYNX keeps the personal data of the data subjects for as long as is necessary for the purpose for which it was collected.

For the purposes described in this Privacy Policy, personal data will be kept and maintained until 10 (ten) years after the end of the contractual relationship.

Once the maximum period of retention has been reached, and if there is no situation of major interest that prevents it (such as, in particular, the continuation of contractual obligations or rights enforceable against LYNX, as well as legal, regulatory or procedural requirements), the personal data will be destroyed in a secure manner.

LYNX keeps personal data for the period of time required to meet contractual, legal, regulatory and procedural obligations. The personal data held by LYNX will have to be kept for as long as necessary in order to ensure:

- Compliance with a duty to maintain data, imposed by law or other regulations, in particular under commercial and tax law, banking law and the Money Laundering and Terrorist Financing Act and the Securities Code;

- The right to keep evidence in accordance with the applicable statutory limitation periods;

- Compliance with judicial decisions, of any nature.

8. How does LYNX ensure adequate protection of Personal Data?

LYNX is committed to guaranteeing and ensuring the protection of the personal data made available to it, through appropriate technical and organisational measures, in order to prevent possible intrusion, disclosure, alteration, unauthorised processing and access, as well as against any unlawful processing.

As a general rule, it also undertakes to ensure that it only processes the strictly necessary personal data for each specific processing purpose (principles of purpose limitation and data minimisation) and that the data is not available or made available to third parties unlawfully (principle of lawfulness, fairness and transparency).

9. Rights of the data subject:

a) Right to Transparency: LYNX shall provide the data subject, free of charge, with information regarding the processing, in a concise, transparent, intelligible and easily accessible manner, using clear and simple language.

Provide information on the action taken without undue delay and no later than one month from the date of receipt of the request.

Where the data subject makes the request by electronic means, the information shall, where possible, be provided by electronic means, unless the data subject requests otherwise.

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b) Right of Access: The data subject has the right to access its personal data and obtain information about the purposes, categories, recipients or categories of recipients to whom its personal data have been or will be disclosed, the expected period for which they will be kept and their origin.

c) Right of Rectification: The data subject has the right to obtain from LYNX, the rectification of inaccurate personal data concerning it. Taking into account the purposes of the processing, the data subject has the right to have its incomplete personal data completed, including by means of an additional declaration.

d) Right to Erasure or to be Forgotten: the data subject has the right to request LYNX to erase their personal data, and LYNX is obliged to erase the personal data, without undue delay, where it is found that:

• The personal data is no longer necessary for the purpose for which it was collected or processed;

• The data subject withdraws the consent on which the processing of the data is based and if there is no other legal ground for such processing;

• The data subject objects to the processing of the personal data and there are no major legitimate interests justifying the processing;

• Personal data has been unlawfully processed;

• Personal data must be deleted in order to comply with a legal obligation arising from Union or Member State law to which LYNX is subject.

e) Right to Limitation of Processing: The data subject has the right to obtain from LYNX the limitation of processing if it contests the accuracy of the personal data.

f) Right to Notification: LYNX shall notify each recipient to whom personal data have been transmitted of any rectification or erasure of personal data or restriction of processing.

g) Right to Portability: The data subject shall have the right to receive the personal data concerning it in a structured, commonly used and machine-readable format that it has provided to LYNX, as well as the right to transmit such data to another controller without hindrance;

h) Right of Opposition: The data subject has the right to object at any time, on grounds relating to its particular situation, to the processing of personal data concerning it. LYNX shall cease the processing of personal data, unless it provides compelling legitimate grounds for such processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

i) Automated Individual Decisions, including Profiling: The data subject shall have the right not to be subject to a decision taken solely on the basis of automated processing, including profiling, which produces legal effects concerning the data subject or significantly affects the latter in a similar manner.

10. Subcontractors

LYNX, in the pursuit of its activity, may use third parties – Subcontractors/processors – for the provision of certain services, which may involve access, by these third parties, to personal data of the data subjects. LYNX ensures that in these circumstances the appropriate technical and organisational measures are taken to ensure that the subcontractors/processors meet the applicable legal requirements and offer adequate guarantees with regard to data protection.

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11. Exercise of rights

LYNX has appointed a Data Protection Officer to whom any questions concerning the protection of personal data may be addressed via email at protecaodados@lynxassetmanagers.com or via letter addressed to LYNX ASSET MANAGERS SGOIC S.A. Av. Duque D'Ávila, 185, 4D, 1050-082 Lisbon.

The exercise of the rights referred to in our Privacy Policy, as well as any clarification or additional information on the same may be requested via email protecaodados@lynxassetmanagers.com or via letter addressed to LYNX ASSET MANAGERS SGOIC S.A. Av. Duque D'Ávila, 185, 4D, 1050-082 Lisbon.

12. Changes to the LYNX Privacy Policy

LYNX reserves the right to modify this Privacy Policy at any time and, in the event of its modification, the same will be included and updated on its website, with the User/Data Subject having direct access to said information.

Customer privacy is important to LYNX and we are committed to the protection and confidentiality of your personal data.

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Conflict of Interest Management Policy

LYNX’s Conflict of Interest Management Policy is pursuant to Directive 2006/73/CE of the Commission of 10 August 2006 and complies with legal requirements, especially the Portuguese Securities Code and the Legal Framework of Credit Institutions and Financial Companies.

The Conflict of Interest Management Policy intends to ensure that LYNX acts to prevent conflicts of interest both at the level of its Principles, Internal Standards and Internal Operation.

Employees are encouraged to adopt behaviours that show their integrity, equity, impartiality, and primacy to and respect for their Clients’ interests.

In addition to LYNX’s Code of Ethics, Employees are informed and trained with the purpose of acting effectively.

Conflicts of Interest are situations that may lead to material loss for a Client and that are originated between LYNX and:

1. Clients,
2. Board of Directors and Supervisory Body or any other Relevant Persons (according to Article 304(5) of the Portuguese Securities Code, relevant persons are the members of the management body and the persons that effectively direct the business of the financial intermediary or the tied agent and the Employees of the financial intermediary, tied agent or outsourcing entities, involved in the pursuing or supervising of financial intermediation activities or the operational functions that are essential for the provision of continual services under the conditions of quality and efficiency”).
3. Shareholders,
4. Suppliers/Subcontractors.

The Conflict of Interest Policy applies to all operation areas, but those areas that deserve more attention, because they imply a higher risk, are:

• Portfolio management,
• Investment research,
• Decisions for the acquisition of capital of businesses,
• Personal transactions made by Employees. LYNX also identifies situations where conflicts of interest are more likely to happen:
• Providing services that involve discretionary management of portfolios to Clients, combined with the possibility of recommending LYNX products.
• LYNX’s interest, which differs from the Client’s, as result of a service,
• Employees who receive incentives or other benefits that affect service provision,
• A Client that exercises the same activity as LYNX,
• LYNX’s gains or losses to the detriment of Client’s interests.

When operating, LYNX may face unexpected situations that are not listed above and that can generate conflicts of interest. In that case, the Board of Directors must be informed promptly by the Employee involved so that the situation can be analysed and the best measures possible adopted.

To allow LYNX to be in a position where it can identify potential conflicts of interest, information deemed relevant and transactions are registered, as well as the decision that led to their occurrence.

LYNX observes principles and implements measures for the prevention and management of potential conflicts of interest. Here are some examples of these mechanisms:

• Control of own transactions and independence in decision-making: all Employees ask the respective member of the Board of Directors for a prior authorisation that states their intention to perform personal transactions involving securities and are forbidden to use LYNX’s information for their own benefit,
• Inside Trading and Front Running: the use of data in a way that can be deemed an abuse of privileged information or conveying orders in the scope of their management (Funds and Discretionary Management) that will objectively compromise binding orders that come from Clients are expressly forbidden,
• Information restriction: information is conditioned by restrict access to Employees and the areas it concerns, and disclosing LYNX or Clients’ data is forbidden,
• Independent areas: LYNX’s different areas of operation act independently,
• Financial products vs. Client profile: financial products are selected according to Client’s interests and associated risks,
• Third-party remunerations: Employees cannot receive any type of remuneration from third parties that arises directly or indirectly from their relationships established via their professional activity at LYNX,
• Segregation of duties: different persons from different areas are involved in situations that can potentially generate conflicts of interest,
• Prevention against influence: the guarantee that decisions are not influenced by external persons,
• Equal treatment: where the Client is a shareholder of LYNX and/or the group of companies to which LYNX belongs, they must be treated like any other Client,
• Precise information: LYNX provides detailed, exhaustive information to Clients about the services that are provided,
• Prevention, communication and remedying, mitigating the occurrence of situations that can generate mis-selling practices, associated or not with the placement of financial instruments issued by LYNX itself or entities with which LYNX is strictly connected.
• Incentives to LYNX’s Employees to ensure Clients’ interests prevail over LYNX and/or Employees’ interests, by means of transparent, rigorous, and impartial actions.
• When managing more than one collective investment undertaking, LYNX handles each one of them like a Client, by acting in their interest and not charging or attributing them costs that were not planned and giving them relevant information in due time.
• Where the measures adopted by LYNX are not enough to prevent conflicts of interest, Clients are treated with fairness and are duly informed about the existing risks before the transactions are made to allow for an informed decision-making process.
• This way, the occurrence of conflicts of interest implies that the Client is informed about the existing risk.
• The duty to inform does not prevent LYNX from analysing the risk inherent to the conflict of interest in the best interest of LYNX and its Client. LYNX reserves the right not to perform transactions, if deemed necessary.
  

1.Main Principles

LYNX operates based on the principles of honesty, fairness, and professionalism to better serve its Clients’ interests.

For the purposes of this policy, here is a list of terms and their respective meanings:

a) Clients are all (i) existing clients; (ii) potential clients (e.g. concerning which LYNX individually seeks to start a contractual relationship); (iii) clients which have ended their business relationship with LYNX, but with which LYNX is still bound by trustee obligations or any other obligations of equivalent nature; (iv) participants in Collective Investment Undertakings (OICs) managed by LYNX; and v) the OICs managed by LYNX.

b) Employees: all workers, interns, services providers, and agents, whether permanent or temporary, regardless of the nature of their bond to LYNX, who provide any service, execute any job or perform any activity for LYNX (e.g. suppliers, subcontractors, and tied agents).

c) LYNX Group: the group of companies whose share capital is directly or indirectly held by LYNX HOLDING SGPS S.A., with single registration and legal person number 510180850, share capital of € 2,146,949.00 and with registered office at Avenida Duque de Ávila, nº 185, 4º D, Lisboa, Avenidas Novas, 1050 – 082 Lisboa. LYNX is included in this group because its share capital is held by LYNX HOLDING SGPS S.A.

The Benefits Paid to or Received from Third Parties (Inducement) Policy, set forth in this document, seeks to cumulatively:

• Strengthen the protection of Clients;
• Confirm that priority is given to Clients’ interests when investment services are provided;
• Ensure that the provision of investment services is not influenced or skewed by benefits of any nature that are received; and
• Increase transparency as to the quality and costs of services provided to Clients.

2.Lawful benefits

LYNX can only offer to or receive remunerations, commissions, or benefits from third parties, when:

a) Such payment contributes to reinforcing the quality of the activity provided to the Client, i.e. is necessary for providing the financial intermediary service to the Client (for instance, mandatory fees or custody fees);

b) The existence, nature, and sum (or respective calculation method, where the sum is not defined) of such benefit is disclosed to the Client before the investment service in question is provided; and

c) Such payment does not interfere with LYNX’s obligation to act honestly, fairly and professionally to better serve Clients’ interest.

For purposes of point c) above, LYNX can receive remunerations, commissions or benefits whenever service provision is not wrongfully influenced or distorted by such payments.

3.Service Quality Reinforcement Requirements

Non-cash remunerations, commissions or benefits are deemed to reinforce the quality of the service in questions, when:

a) They are justified by the provision of an additional or upper level service to the Client that is proportional to the benefits received, such as:

1. Provision of consultancy services concerning non-independent investment and access to a wide variety of adequate financial instruments, including the adequate number of instruments from third parties which are not strictly related to LYNX;
2. Provision of consultancy services concerning non-independent investment in conjunction with a proposal made to the Client in the sense of assessing annually the adequacy of the financial instruments in which the Client invested or with another continuous service that is liable to add value to the Client, such as recommendations as to the optimal allocation of their assets; or
3. Access to a wide range of financial instruments, at competitive prices, which are likely to meet the Client’s needs, including an adequate number of financial instruments from third-parties which are not strictly related to LYNX, in conjunction with the provision of added-value instruments, such as the provision of information destined to objectively support the Client’s decision-making process, or allow for the Client to follow, model and adjust the range of financial instruments where they invested, or with periodical reports concerning the performance, costs and expenses concerning financial instruments.

b) They do not benefit LYNX, its shareholders, employees or LYNX group entities directly, without any clear advantage for the Client; and

c) They are justified by the offering of a continuous advantage for the Client in relation to a continuous benefit.

4.Prohibitions

In the scope of the discretionary management of portfolios on behalf of someone else, LYNX cannot receive any remuneration, commission or benefit, except for non-cash benefits that are not significant, provided they comply with the service quality reinforcement requirements and are reasonable and proportional.

5.Non-cash benefits that are not significant

LYNX can accept the following non-cash benefits that are not significant from partners with which LYNX has entered into distribution agreements:

a) information or documentation concerning a financial instrument or investment service of generic nature or personalised nature to reflect the circumstances of an individual Client;

b) Written material from a third party to which an issuer or potential issuer has ordered and paid to promote a new issue, or where the third-party company is hired and paid by the issuer to generate the referred material on a continuous basis, provided that the relationship is clearly disclosed in the written material and such material is provided concurrently to any other financial intermediary that wants to receive it or to the general public;

c) Participation in conferences, seminars or any other training initiatives about the benefits and features of a given financial instrument or investment service;

d) Reasonable hospitality expenses, such as food and drinks during a business meeting or conference, seminar or any other training initiatives mentioned in point c) above; and

e) Other non-cash benefits that are not significant and are found by the CMVM to improve the quality of the service provided to a Client and not liable to prevent LYNX duty of acting in the Client’s best interest, considering the total of benefits granted by one entity or group of entities and the nature and dimension of such benefits.

By making this Policy available, LYNX is complying with the duty of ex-ante disclosure of the non-cash benefits that are not significant and that LYNX can receive during the term of a contract entered into with the Client, namely a financial brokerage contract.

The benefits above are reasonable and proportional and do not compromise Client’s interests.

6.Investment Recommendations (“Research”)

LYNX does not receive investment recommendations pursuant to article 12-A of the Portuguese Securities Code and of the Regulation (EU) no. 596/2014 of the European Parliament and of the Council of 16 April 2014.

LYNX finds that the following forms are not considered investment recommendations and can be received freely:

a) Assessments in the scope of the issue of securities – documents prepared in the scope of or for the purposes of an issue in a primary securities market, especially those prepared by investment companies that were hired by the issuer to assist in the scope of such transactions.

b) Contact mediation (corporate access) – personalized or organizational support services (including road shows).

c) Economic or market data without associated investment recommendations – information services, dissemination of information, where those facts or data that were disseminated are not subject to any judgement, recommendation or any other service performed by the respective provider.

7.Execution of orders

LYNX cannot receive any non-pecuniary payment, discount or benefit for the execution of orders in a given negotiation structure that violates the applicable obligations regarding conflicts of interest, including the rules concerning unlawful benefits.

8.Information duties

LYNX discloses the existence, nature and sum concerning the non-pecuniary remuneration, commission or benefit. Where such sum cannot be determined, the Client is informed about the calculation method, via a detailed, true, and explicit document, before the provision of the financial mediation service.

Where LYNX received incentives on a continuous basis with regard to investment services provided to Clients, the company informs the latter, individually and annually, of the effective sum concerning payments or benefits received or paid in a durable medium and in the way agreed with the Client when the Client file was created.

The Compliance department executes the internal control procedures that allow to ensure that LYNX does not receive any remuneration, commission or benefit in the scope of the discretionary management of portfolios on behalf of someone else, nor in the scope any other activity.

If the Compliance department finds that any undue benefit was received, the Clients involved will be repaid the amount corresponding to the pecuniary or non-pecuniary remuneration, commission or benefit received within a maximum of ten business days.

9.Records

LYNX keeps an internal list of all non-cash remunerations, commissions and benefits received from any third parties concerning the provision of investment services or the like. Such list described how those remunerations, commissions and benefits improve the quality of the services provided to the corresponding clients, as well as the measures taken not to prejudice the obligation of the financial intermediary of acting according to the highest diligence, loyalty, and transparency standards in the sense of protecting the legitimate interests of the Clients.

The list above is elaborated by the Compliance department and kept for a period of 5 (five) years after the commercial relationship with the Client has been terminated.

10.Permanent Compliance with the Benefits Paid to or Received from Third Parties Policy

LYNX adopts the measures set forth in the Policy whenever the company pays or receives any non-cash remuneration, commission or benefit.

11.Benefits Paid to or Received from Third Parties Policy Review

This Policy will be reviewed annually, without prejudice to extraordinary reviews that take place whenever deemed fit by the Board of Directors or at the request of the Compliance department, namely following the Internal Control Report or whenever any inefficiency or misalignment is verified.

12.Availability to Clients

The effective Policy will be available to Clients at www.lynxassetmanagers.com and upon request made directly to LYNX.

Definitions

The following definitions shall apply throughout this document, unless the context otherwise requires and without prejudice to other definitions in the document. References to the singular form shall always include the plural form (and vice versa):

“Director(s)”

shall mean one or more members of the Board of Directors of LYNX.

“Clients”

shall mean any natural or legal person who is entering into or has a business relationship with LYNX, regardless of the type of service provided or the transaction carried out, including, but not limited to, under management Collective Investment Undertakings (CIU) participants (defined below), discretionary management clients and CIU under management counterparties (in particular buyers or sellers of real estate or lessees or purchasers of shares held by CIUs).

“CMVM”

shall mean the Portuguese Securities Market Commission, the supervisory and regulatory authority for the financial instruments markets and the agents operating therein, in Portugal.

“LYNX employees”

shall mean employees, trainees, service providers and agents, on a permanent or occasional basis, regardless of the nature of their employment with LYNX, who provide work, services or any activity (e.g. suppliers, subcontractors and tied agents), including “Senior Employees” as defined below.

“Senior Employees”

shall mean the directors, the members of the Supervisory Board and senior management, those responsible for portfolio management, marketing, human resources, risk takers and control functions and those employees receiving total remuneration that takes them into the same remuneration level as senior management and risk takers, and whose professional activities have a material impact on the risk profile of the CIU under management.

“Board of Directors or BoD”

shall mean LYNX’s Board of Directors, the senior management body of LYNX.

“Documentation of Managed CIUs

shall mean, for each CIU under management (defined below), the latest version of its management rules and regulations and, where applicable, other documentation, such as subscription contracts and service agreements.

“LYNX”

shall mean LYNX ASSET MANAGERS SGOIC S.A., a public limited company incorporated under Portuguese law, having its registered office at Avenida Duque D'Ávila, No. 185, 4D, 1050-082 Lisbon, and a share capital of € 1,050,000.00 (One million and fifty thousand euros), registered with the Commercial Registry Office of Lisbon under the single registration and taxpayer identification number 507.929.934, and authorised and supervised by the CMVM, as a SGOIC (managing entity of collective investment undertakings) under the RGOIC.

“Malus Scheme”

shall mean the scheme by which the amount of variable remuneration which has been deferred and whose payment is not yet vested may be reduced, totally or partially.

“Withholding or Clawback”

shall mean the scheme by which LYNX withholds, without definitively making available, the amount of variable remuneration whose payment already constitutes an acquired right (withholding) or the contractual scheme by which the Senior Employee, subject to certain conditions, agrees to repay to LYNX, in whole or in part, the variable remuneration already received by him/her (recovery).

“Sustainability Policy”

shall mean LYNX's Environmental, Social and Governance Sustainability Policy.

“CIU”

shall means collective investment undertaking governed by the General Regime for Collective Investment Undertakings, approved by Law No. 16/2015, of 24 February, as amended.

“CIUs Under Management”

shall mean the CIUs under management by LYNX as a managing entity of collective investment undertakings, including undertakings for the collective investment in transferable securities (OICVM), undertakings for the collective investment in real estate/alternative investments (OIA) and undertakings for investment in venture capital.

“RGOIC”

shall mean the General Regime for Collective Investment Undertakings, approved by Law No. 16/2015, of 24 February, as amended.

Introduction

1. According to the law LYNX as the managing entity of collective investment undertakings authorised and supervised by CMVM, must prepare and apply a Remuneration and Remuneration Benefits Policy that is consistent with and promotes sound and effective risk management and does not encourage the assumption of risks incompatible with the risk profiles and Documentation of the CIUs Under Management, in a manner and to the extent appropriate to their size and internal organisation and the nature, scope and complexity of their activities.

2. This Policy is addressed to Senior Employees.

Term

3. This Policy shall be remain force for an indefinite period of time, without prejudice to its updating and revision, as well as the annual evaluation to be carried out as foreseen in this document.

4. This Policy and its subsequent update and revision shall apply only to remuneration that is set after its approval.

1. Framework

1.1 In determining this Policy LYNX has taken into consideration its size and internal organisation as well as the complexity of its activities and its economic situation. Furthermore, LYNX shall always take into consideration its current state at any given time and shall subject this Policy to periodic review to ensure that it is compatible with its financial situation and to safeguard its sustained growth.

1.2 Furthermore, LYNX adopts this Policy with a view to promoting solid and effective risk management and not encouraging the assumption of risks that are incompatible with the risk profiles and documentation of the CIU Under Management, but always with a view to its integration in a competitive context with that in which it operates as a CIUs managing entity, and bearing in mind the importance of the quality, capacity, dedication, sense of responsibility and technical knowledge of its Senior Employees who are responsible for taking and implementing strategic decisions and conducting the affairs of the Company.

1.3 These are the assumptions that generally determine LYNX's Remuneration and Benefits Policy and are deemed to be suitable to attract and keep the most competent and reputable professionals in the market at the service of the Company.

1.4. This Policy was first defined by the General Meeting on the proposal of the Board of Directors, after hearing the Compliance Department and the Compliance Officer, who participated in its design and then approved by the LYNX supervisory body, which is competent and responsible for the periodic annual review of its general principles and objectives, and is also responsible for the supervision of its implementation and compliance.

1.5. The revisions of this Policy, which shall be at least annual, must be formalised in a separate document, always updated, specifying any changes that may be introduced and the respective reason. This document and its updates must be kept on file with the Board of Directors or the person responsible for Human Resources, when the latter exists, and disclosed to Senior Employees.

2. Purposes of the Remuneration and Benefits Policy

2.1 Considering the framework of this Policy and the legal requirements imposed by the legislation in force and applicable, it is established, in particular, by virtue of the following purposes:

a) Clarity and transparency in the criteria determining fixed and variable remuneration, as well as benefits;

b) A governance model in line with the best market practices, by comparison with companies of the same activity, weighted by size;

c) An effective risk management and control to avoid exposure to the level of risk tolerated by LYNX, including sustainability risks as set out in the Sustainability Policy, and to avoid exposure to conflicts of interest;

d) A fixed monthly remuneration that is competitive in order to attract and retain competent and reputable professionals, and an annual variable remuneration that stimulates performance and rewards results achieved, taking into account market practices and always based on uniform, consistent, fair, balanced and transparent criteria, without prejudice to the provisions of paragraph g) below;

e) The alignment of annual variable remuneration consistent with the size and financial results of the Company, with the risks and complexity of its business and with its sustainable growth, discouraging exposure to excessive risk and promoting the continuity and sustainability of positive results, in particular by setting maximum limits on remuneration components;

f) The calculation of the annual variable remuneration on an individual basis shall consider the evaluation of the respective performance, based on criteria of a financial and non-financial nature, in accordance with the functions and level of responsibility, as well as the Company's results, using national and international practices in the sector of activity as a term of comparison, without prejudice to the provisions below on variable remuneration;

g) Independence of the Senior Employees who exercise control and risk management functions in relation to the structure units they control, attributing them remuneration according to the achievement of the objectives associated with their functions and independent of the performance of the respective structure units;

h) Absence of remuneration insurance or other risk coverage mechanisms;

i) Compliance with applicable regulations and guidelines, both in terms of procedures and remuneration policy.

3. Scope of application

3.1 Subjective Scope

The Remuneration and Benefits Policy shall be applicable to Senior Employees.

3.2 Objective Scope

This Policy shall apply to remuneration and benefits paid or awarded by LYNX, including the annual variable remuneration component.

4. Powers to define the Remuneration and Benefits Policy

4.1. Except as provided in the following paragraph, the definition of this Policy shall be the responsibility of the General Meeting, upon proposal of the Board of Directors, after hearing the Compliance Department and the Compliance Officer, who shall take part in its conception, and will then be approved by the LYNX supervisory body, the latter being exclusively responsible for the periodic review of its general principles and objectives as well as the supervision of its implementation and compliance. The Compliance Department and the Compliance Officer shall be responsible for a centralised and independent internal review of the implementation of the Policy at least once a year in order to verify its compliance.

4.2 The General Meeting shall also be responsible for approving the remuneration and any performance bonuses or supplements of the members of the governing bodies of LYNX, including the respective terms and conditions applicable to their effective payment.

4.3 The General Meeting may create and appoint a Remuneration Committee to replace it in the exercise of its powers foreseen in paragraphs 4.1 and 4.2 above, which shall be composed of two to five members, who may or may not be shareholders, in accordance with the terms of the articles of association.

4.4 Currently, LYNX is not large enough, either in terms of its structure or in terms of the CIUs under management, or its internal organisation and the nature, scope and complexity of its activities, to qualify as a significant managing entity, pursuant to paragraph 3, of Annex I, of the RGOIC, and is therefore not required to implement a Remuneration Committee.

4.5 Except as provided in paragraph 4.6, the LYNX Board of Directors shall be responsible for proposing the remuneration of the Senior Employees (with the exception of the Directors) who have risk management or control functions and the proposal shall be submitted to the General Meeting or the Remuneration Committee, if there is one, for approval.

4.6. The remuneration of the Directors shall always be approved by the General Meeting or the Remuneration Committee, if the latter has been elected, as provided for in the LYNX Articles of Association.

5. Components of the Remuneration Policy

5.1. Fixed remuneration

In accordance with the preceding principles, the following guiding principles are assumed by this document:

a) The remuneration of the Senior Employees shall consist of a fixed monthly remuneration and a variable annual remuneration, without prejudice to the provisions of sub-paragraphs d) and k) below;

b) The fixed monthly remuneration shall be paid, in accordance with the law, 14 (fourteen) times a year to all Senior Employees;

c) The setting of the monthly amount of the Directors' remuneration shall take into consideration the duties and tasks attributed, as well as their availability and dedication;

d) The members of the Supervisory Board shall be remunerated by a fixed annual amount, determined by the General Meeting or the Remuneration Committee and in line with the criteria and market practices used appropriate to the size of the Company and its turnover;

e) Currently, the monthly remuneration of the Senior Employees does not include any variable component, and therefore the legal provisions that presuppose the payment of remuneration based on performance evaluations are not applicable;

f) This Policy shall be reviewed and approved annually pursuant to paragraph 4 above;

g) Any amendment to the Remuneration and Benefits Policy established herein, namely as regards the decision not to award variable remuneration as foreseen and by the deadlines defined above, shall be subject to the procedure described in paragraph 4. above;

h) The remuneration of the non-executive Directors shall not be dependent on the performance or value of LYNX and they shall therefore not earn any variable remuneration;

i) LYNX does not pay any compensation or indemnity, including payments related to the duration of a notice period or non-competition clause, in cases where the removal of a Director, or the termination of his contract by agreement, results from inadequate performance of his duties;

j) Senior Employees who exercise control and risk management functions shall be remunerated in accordance with: (i) the achievement of the o associated with their functions, regardless of the performance of the respective structure units; and (ii) the overall performance of LYNX and its results.

5.2. Variable remuneration

5.2.1 As previously stated, at the present date no variable component is envisaged in the monthly remuneration of Senior Employees.

5.2.2 However, an annual variable remuneration is awarded, for which the following rules shall be complied with:

a) The total amount of the variable component of the annual remuneration shall be determined by combining the evaluation of the Senior Employee's performance (with a weight of 80%), which shall consider financial and non-financial criteria under the terms of paragraph 5.2.4 below, the performance of the structure unit or the CIU Under Management (with a weight of 10%), and the overall results of LYNX (with a weight of 10%);

b) The evaluation of the performance of the Senior Employees shall be carried out within a multi-year framework appropriate to the term of the CIUs Under Management, ensuring that the evaluation process is based on long-term performance and that the payment of the remuneration components dependent on this is spread over a period which takes into account the reimbursement policy of the CIUs Under Management and the respective investment risks;

c) No variable remuneration granted will have a guarantee, except in the context of hiring new employees, only in their first year and if there is a solid and strong capital base at LYNX;

d) Appropriate ratios shall be established between the fixed and variable components of the total remuneration of the Senior Executives, with the fixed component representing a sufficiently high proportion of the total remuneration to allow the application of a fully flexible Policy regarding the variable component of the remuneration, including the possibility of not awarding and/or not paying it;

e) The attribution of the annual variable remuneration cannot exceed the value of the respective annual fixed remuneration for each of the Senior Employees;

f) LYNX has not instituted any payments related to the early termination of the duties of Senior Employees;

g) The measurement of the performance of Senior Employees used to calculate the variable component of remuneration shall provide for adjustments considering the various types of current and future risks;

h) The annual variable remuneration shall always be paid in cash, since LYNX has neither the legitimacy nor the capacity to deliver units or shares of the CIUs Under Management, insofar as almost all of them are closed, as well as it cannot, and should not, carry out capital increases for the sole purpose of delivering the corresponding shares or units to its Senior Employees. Additionally, no CIU Under Management represents more than fifty percent (50%) of the total portfolio managed by LYNX;

i) Whenever the annual variable remuneration of a Senior Employee does not exceed 80% (eighty per cent) of his fixed annual remuneration, 60% (sixty per cent) of the former shall be paid in full to the Senior Employee on the payment date, and payment of the remaining 40% (forty per cent) shall be deferred for a period of 3 (three) years, and paid proportionally and increasingly over this period;

j) Whenever the annual variable remuneration of a Senior Employee exceeds 80% (eighty per cent) of the fixed annual remuneration, 40% (forty per cent) of the former shall be paid in full to the Senior Employee on the payment date, and payment of the remaining 60% (sixty per cent) shall be deferred for a period of 3 (three) years and paid proportionally and increasingly over this period;

k) The variable component of the remuneration of Senior Employees, including the deferred portion of that remuneration, should only constitute a vested right or be paid if it is sustainable in the light of LYNX's financial situation and substantiated in the light of the performance of the structure unit concerned, the CIUs Under Management and the employee in question ;

l) Without prejudice to labour or civil law, the variable component of the remuneration of Senior Employees shall be altered if the performance of LYNX or the CIUs Under Management declines or is negative, taking into account both the current remuneration and reductions in the payment of amounts for which the right to receive payment has already been established, including through malus or clawback schemes, as provided for in this Policy.

5.2.3 The attribution of an annual variable remuneration to Senior Employees shall always be decided and determined pursuant to paragraph 4. of this Policy, and it shall be the responsibility of the body foreseen therein, under the respective terms, in particular:

a) Apply the Alignment, Reduction and Recovery Mechanisms set out in the following paragraphs of this Policy;

b) Decide not to apply the provisions of sub-paragraphs 5.2.2 i) and j) above to the variable annual remuneration component whenever it does not exceed €50,000.00 (fifty thousand euros) and simultaneously does not exceed one third of the fixed annual remuneration of the Senior Employee;

c) Decide, in objective and reasoned terms and with respect for the principle of proportionality, not to apply the provisions of sub-paragraphs 5.2.2 i) and j) above, whenever the component of annual variable remuneration to be attributed in concrete exceeds the limits provided in sub-paragraph b) above, but does not jeopardise the overall financial situation of LYNX, the financial performance of the CIUs Under Management and/or LYNX and is appropriate to the Sustainability Policy, in particular with regard to the adoption of good governance practices.

5.2.4 Assessment criteria for the Senior Employee

5.2.4.1. The criteria for defining the total amount of the variable component of the annual remuneration are as follows:

a) favourable economic and financial situation of LYNX;

b) positive performance of LYNX, from the perspective of the turnover generated and results obtained; and

c) Performance of the business area or of the CIUs and/or Portfolios under management;

d) Compliance with the Sustainability Policy.

5.2.4.2. the definition of the total amount of the variable component of the annual remuneration shall be made based on the assessment of individual performance, with the overall results of LYNX and, in the case of the Board of Directors, also based on the assessment of the performance of this body as a whole.

5.2.4.3 With the exception of the Supervisory Board, the variable component of the annual remuneration of the Senior Employees shall be determined on the basis of a standard benchmark corresponding to the achievement of 100% of the objectives set: i) by the Board of Directors, for the other Senior Employees; or ii) by the LYNX General Meeting or Remuneration Committee, for the Board of Directors.

5.2.5. Aligning scheme of the interests of Senior Employees with the interests of the company

If, in a given financial year, LYNX suffers a negative result or if the Company needs to increase its own funds and does not have sufficient means at its disposal, no deferred variable remuneration may be paid to Senior Employees for previous financial years and they shall not be awarded any new variable remuneration in that financial year.

5.2.6 Malus Scheme of the variable remuneration

5.2.6.1 The deferred variable remuneration of Senior Employees may be reduced, wholly or partially, if, during the deferral period and until its expiry, any of the following events demonstrably occur:

a) A significant and proven decline in the financial performance of the CIU Under Management and/or LYNX and/or the business unit of which the Senior Employee is a member;

b) Significant and proven failure in the risk management of the CIU Under Management and/or LYNX and/or the business unit to which the Senior Employee belongs;

c) Significant negative changes in the overall financial situation of LYNX;

d) Serious misconduct or error by the Senior Employee, namely through violation of applicable legal, regulatory and/or internal norms;

e) Non-compliance with mandatory provisions of the Sustainability Policy.

5.2.6.2. The reduction of the variable remuneration shall always be proportional to the loss value of the event determining the reduction, and the total reduction may occur whenever that value determines it.

5.2.6.3. The decision to apply this mechanism is taken in accordance with the provisions of paragraph 5.2.3.

5.2.7 Withholding or Clawback Scheme for variable remuneration

5.2.7.1. The variable remuneration of Senior Employees, whether paid or deferred, may be permanently withheld or recovered, in whole or in part, by LYNX if the Senior Employee:

a) Has caused significant damage to LYNX and/or one or more of the CIUs Under Management and/or one or more Clients, including significant reputational damage;

b) Fails to comply with suitability and appropriateness criteria, in accordance with the RGOIC;

c) Has received inducements from third parties within the scope of its activity;

d) Has breached financial secrecy rules;

e) Has caused non-compliance with prudential rules to which LYNX is bound.

5.2.7.2 LYNX shall resort to withholding, in whole or in part, the variable remuneration deferred and not yet paid to the Senior Employee and shall always resort to clawback, in whole or in part, in cases where the variable remuneration has already been paid.

5.2.7.3. The decision to apply this scheme shall be taken in accordance with the provisions of 5.2.3.

5.3 General aspects of remuneration

5.3.1 LYNX considers it essential that fixed remuneration always represents a sufficiently high proportion of total remuneration to ensure an appropriate balance between the fixed and variable components of total remuneration.

5.3.2 The annual variable remuneration of the Senior Employees shall always be aligned with the strategy defined for the activity, objectives, values, interests and duration of the CIUs Under Management, as well as with the activity, performance, objectives, values and interests of LYNX, in order to ensure a sustainable growth consistent with the risk profile of the CIUs Under Management and LYNX. It is thus intended to ensure a financially sustainable model for LYNX, its shareholders, employees, clients and CIUs Under Management, which is why it is necessary to establish the deferral of 40% (forty percent) of the annual variable remuneration of the Senior Employees over a minimum period of 3 (three) years, whenever it does not exceed 80% (eighty percent) of the fixed annual remuneration, without prejudice to the provisions of paragraph 5.2.3.

5.3.3 For the reasons set out in the immediately preceding paragraph, it is understood that 80% (eighty per cent) of the fixed annual remuneration of the Senior Employees is a particularly high figure and, as such, it is justified that, whenever the annual variable remuneration exceeds that percentage, it is necessary to defer payment of 60% (sixty per cent) over a minimum period of 3 (three) years, without prejudice to the provisions of paragraph 5.2.3.

6. Conflicts of interest

LYNX has implemented a Conflict of Interest Policy, which includes, in particular, rules concerning the remuneration of LYNX Employees and Senior Employees and must be complied with, in particular, with regard to such rules, to prevent and avoid conflicts of interest, in particular between LYNX Employees, Senior Employees, LYNX, CIUs Under Management and Clients.

7. Performance evaluation of the management and supervisory bodies and other Senior Employees

7.1 Notwithstanding the provisions of paragraph 7.2, the evaluation of the performance of the Senior Employees shall be carried out annually by the Board of Directors, in accordance with parameters that may be defined, provided, however, that an appropriateness is guaranteed in relation to the term of the CIU Under Management and it is ensured that the evaluation process shall be based on long-term performance and that payment of the remuneration components dependent thereon shall be spread over a period which takes into account the redemption policy of the CIU Under Management and the respective investment risks.

7.2 The performance of the members of the Supervisory Board shall be evaluated by the Shareholders' General Meeting, as well as the performance of the members of the Board of Directors, until the Remuneration Committee is constituted.

7.3 The evaluation policy, due to its direct relationship with remuneration updates and the possible attribution of variable remuneration, shall be divulged internally, so as to be known by all LYNX Employees, in particular Senior Employees.

7.4 The remuneration of Senior Employees who exercise risk management and control functions shall be subject to direct supervision by the LYNX supervisory body.

7.5 This assessment shall identify the measures required to correct any shortcomings detected, and if applicable, shall be presented at the General Meeting.

8. Benefits

8.1. The Directors shall only be provided with a mobile phone and/or a car both and/or parking spaces, all for professional use, as well as health insurance, without any other associated benefits.

8.2 For LYNX Employees and Senior Employees, with the exception of those referred to in paragraph 8.1 above, as well as for the supervisory body, it is only foreseen to provide differentiated health insurance and/or parking, without any other associated benefits.

8.3 There is currently no discretionary pension benefit plan, so that if a LYNX employee or a Senior Employee terminates employment before the legally stipulated age of retirement, no discretionary pension benefits shall be provided.

8.4 For the exercise of their functions, Executive Directors shall not receive additional compensation.

8.5. No hedging or similar schemes, as provided for in sub-paragraph u) paragraph 1 of Annex I of the RGOIC, may be used by the directors, senior employees or LYNX in favour of any of them. For this purpose, LYNX shall request and obtain from its Directors and Senior Employees a written statement, by which they expressly undertake not to use any hedging or similar schemes for the aforementioned purposes.

8.6 Where Directors exercise any other functions in companies controlled by LYNX under the Portuguese Commercial Companies Act, any remuneration earned by them in the controlled companies shall be deducted from the remuneration earned by them at LYNX.

9. Final provisions

9.1 This Remuneration Policy is, in its entirety, in line with the principles reflected in the applicable legislation and with the recommendations of the competent supervisory authorities.

9.2 LYNX believes that the remuneration policy set out herein meets the objectives of the legislator and the regulator of its activity, being consistent with effective risk management and control, avoiding excessive exposure to risk, while being consistent with the objectives, values and interests that it proposes to pursue.

9.3 LYNX understands, therefore, that it is adopting a clear and transparent structure, establishing remuneration parameters for the governing bodies and employees within criteria consistent with sound and prudent management.

10. Disclosure

Members of the management and supervisory bodies and members of any Remuneration Committee must ensure that this Policy is transparent and accessible to all LYNX Employees and Senior Employees at all times, in particular by dissemination by email or publication on the LYNX Internet site or by any other means.

No consideration of adverse impacts of investment decisions on sustainability factors

Article 4 of Regulation (EU) 2019/2088 on disclosure of information related to sustainability in the financial services sector (SFDR) requires financial market participants to ensure transparency on whether or not they consider the negative impacts of their investment decisions on sustainability factors, establishing the principle of “respect or justify”, depending on whether or not these impacts are taken into account and must also be able to measure their size and provide this information.

"Sustainability factors", for the purposes of the mentioned SFDR Regulation, are environmental, social and government issues, respect for human rights, the fight against money laundering, financing of terrorism, proliferation of weapons of mass destruction, corruption and bribery.

Formally LYNX ASSET MANAGERS SGOIC S.A. (hereinafter LYNX) does not consider the negative impacts of its investment decisions, made on behalf of the investment funds and portfolios under its management, on sustainability factors, although it recognizes the relevance of integrating environmental, social and environmental factors governance in its decision-making process, as well as the need and importance of informing the market and investors about the impact of its decisions, reasons and why it adopted a Sustainability Policy which includes, for instance criteria that prevent investment in certain companies and sectors that have obvious negative impacts on sustainability factors. To that extent, investments related or likely to be related to radioactive materials (except for medicinal purposes), illegal activities established by law or international convention or agreement or subject to phase-out or international prohibition, corruption, money laundering, terrorist financing, weapons of mass destruction, child or forced labor, pornography and prostitution, and violation of human rights are excluded.

Despite the relevance of the sustainability issue, the current regulatory framework on the transparency of the negative impacts on the mentioned factors is not yet complete and the lack of information on standard indicators on these factors, particularly relevant for their measurement, makes it very difficult to carry out a complete, effective and detailed consideration and demonstration of the negative impacts of investment decisions on sustainability factors.

On the other hand LYNX must necessarily respect the management mandate given to it by the investors of the investment funds and portfolios under its management, such as the investment policies and objectives. Therefore the adoption of management measures even if related with sustainability factores must respect and be compatible with the management mandates given to it.

To this extent LYNX is developing a progressive adaptation, whereby the correct and formal consideration of sustainability factors and the impacts of its decisions on such factors is dependent on the evolution, dissemination and consolidation of the regulatory framework, as well as standard indicators on sustainability factors, in order to correctly measure the negative impact of their investment decisions on sustainability factors.

LYNX is monitoring the development of the regulatory framework on sustainability as well as the evolution of the publication of technical details defined in the “Regulatory Technical Standards” (“RTS”) on this matter, awaiting the conclusion and entry into force of the entire regulatory framework relating to the disclosure of information related to sustainability, with the aim of starting from that moment to consider, formally and documentally, the negative impact of its investment decisions on sustainability factors, as well as the consequent relevance of this impact on the yield of the investment funds and portfolios under their management and also in the investment decision-making process, which may determine a change in the composition of assets and portfolios under management.

This presente statement of no consideration of negative impacts on sustainability factors thus complies with the provisions of article 4, paragraph 1, subparagraph b) of the SFDR Regulation and article 12 of Delegated Regulation 2022/1288, of Commission. However, LYNX will take into account publicly available information that allows it to assess the negative impact of its investment decisions on the aforementioned factors in accordance with the priority objectives identified in its Sustainability Policy.

If you would like to learn more about LYNX's policies related to Sustainability, such as the LYNX Sustainability Policy or the Engagement Policy, please consult the Regulatory Info section on our website.

Article 4 of Regulation (EU) 2019/2088 on disclosure of information related to sustainability in the financial services sector (SFDR) requires financial market participants to ensure transparency on whether or not they consider the negative impacts of their investment decisions on sustainability factors, establishing the principle of “respect or justify”, depending on whether or not these impacts are taken into account and must also be able to measure their size and provide this information.

"Sustainability factors", for the purposes of the mentioned SFDR Regulation, are environmental, social and government issues, respect for human rights, the fight against money laundering, financing of terrorism, proliferation of weapons of mass destruction, corruption and bribery.

Formally LYNX ASSET MANAGERS SGOIC S.A. (hereinafter LYNX) does not consider the negative impacts of its investment decisions, made on behalf of the investment funds and portfolios under its management, on sustainability factors, although it recognizes the relevance of integrating environmental, social and environmental factors governance in its decision-making process, as well as the need and importance of informing the market and investors about the impact of its decisions, reasons and why it adopted a Sustainability Policy which includes, for instance criteria that prevent investment in certain companies and sectors that have obvious negative impacts on sustainability factors. To that extent, investments related or likely to be related to radioactive materials (except for medicinal purposes), illegal activities established by law or international convention or agreement or subject to phase-out or international prohibition, corruption, money laundering, terrorist financing, weapons of mass destruction, child or forced labor, pornography and prostitution, and violation of human rights are excluded.

Despite the relevance of the sustainability issue, the current regulatory framework on the transparency of the negative impacts on the mentioned factors is not yet complete and the lack of information on standard indicators on these factors, particularly relevant for their measurement, makes it very difficult to carry out a complete, effective and detailed consideration and demonstration of the negative impacts of investment decisions on sustainability factors.

On the other hand LYNX must necessarily respect the management mandate given to it by the investors of the investment funds and portfolios under its management, such as the investment policies and objectives. Therefore the adoption of management measures even if related with sustainability factores must respect and be compatible with the management mandates given to it.

To this extent LYNX is developing a progressive adaptation, whereby the correct and formal consideration of sustainability factors and the impacts of its decisions on such factors is dependent on the evolution, dissemination and consolidation of the regulatory framework, as well as standard indicators on sustainability factors, in order to correctly measure the negative impact of their investment decisions on sustainability factors.

LYNX is monitoring the development of the regulatory framework on sustainability as well as the evolution of the publication of technical details defined in the “Regulatory Technical Standards” (“RTS”) on this matter, awaiting the conclusion and entry into force of the entire regulatory framework relating to the disclosure of information related to sustainability, with the aim of starting from that moment to consider, formally and documentally, the negative impact of its investment decisions on sustainability factors, as well as the consequent relevance of this impact on the yield of the investment funds and portfolios under their management and also in the investment decision-making process, which may determine a change in the composition of assets and portfolios under management.

This presente statement of no consideration of negative impacts on sustainability factors thus complies with the provisions of article 4, paragraph 1, subparagraph b) of the SFDR Regulation and article 12 of Delegated Regulation 2022/1288, of Commission. However, LYNX will take into account publicly available information that allows it to assess the negative impact of its investment decisions on the aforementioned factors in accordance with the priority objectives identified in its Sustainability Policy.

If you would like to learn more about LYNX's policies related to Sustainability, such as the LYNX Sustainability Policy or the Engagement Policy, please consult the Regulatory Info section on our website.

LYNX Asset Managers SGOIC S.A. follows the Anti-Money Laundering/Combating the Financing of Terrorism Policy below:

Institutional Information

• Name: LYNX – Asset Managers, SGOIC S.A. (LYNX)

• Address: Av. Duque D’Ávila, 185– 4º D 1050-182 Lisboa, Portugal

• Legal status: Public Limited Company

• Share Capital: € 1,050,000

• Taxpayer ID and Registered in the Commercial Registry Office of Lisbon under no. 507 929 934 § Supervisory Agencies: Portuguese Securities Market Commission (www.cmvm.pt)

• Code with CMVM: 328

• External Auditors: KRESTON, SROC (representada por Jaime de Macedo Santos Bastos)

• Compliance contact: Av. Duque d’Ávila, 185 – 4º D – 1050-082 Lisboa, Portugal Telephone: + 351 211 534 090; email: compliance@lynxassetmanagers.com

National and International Standards

• LYNX observes the recommendations of the FATF/GAFI, which constitute an updated, complete, and consistent list of measures to prevent money laundering and combat terrorist financing.

• LYNX follows the recommendations posted in www.portalbcft.pt, which was created and is maintained by the AML/CFT Coordination Committee. This portal provides up-to-date, structured information and examples of the best practices in each actuation area and encourages and recommends that all Clients and Employees check and use it, given that:

▪ The portal contains relevant links to the pages of the Information Intelligence Unit and sectoral authorities, as well as other national and international agencies with responsibilities in terms of preventing money laundering and combating terrorist financing.

▪ Contains relevant information to the general public, such as periodic assessments and reports in the areas of anti-money laundering and combating the financing of terrorism that must become public knowledge.

LYNX complies with the legal frameworks and regulations in force, with the most relevant being:

▪ Portuguese Penal Code (where Article 368-A typifies the laundering crime).

▪ Law No. 97/2017 of 23 August 2017 – Governs the application and execution of the restrictive measures approved by the United Nations or by the

European Union and sets forth the sanctions applicable to breaches of such measures.

▪ Law No. 96/2017 of 23 August 2017 – Sets the criminal policy objectives, priorities and guidelines for 2017-2019.

▪ Law No. 92/2017 of 22 August 2017 – Requires the use of a specific means of payment in transactions involving amounts equal to or greater than EUR 3000.

▪ Law No. 89/2017 of 21 August 2017 – Approves the Legal Regime of the Central Register of Beneficial Ownership.

▪ Law No. 83/2017 of 18 August 2017 – Sets forth preventive and repressive measures to prevent and combat money laundering and terrorism financing.

▪ Law No. 15/2017 of 3 May 2017 – Forbids the issue of bearer securities,

▪ Law No. 72/2015 of 20 July 2015 – Defines the objectives, priorities and guidelines of the criminal police for 2015-2017.

▪ Law No. 52/2003 of 22 August 2003 – Sets forth measures to combat terrorism.

▪ Law No. 5/2002 of 11 January 2002 – Lays down measures to combat organised crime and economic and financial crime and provides for a special system for the collection of evidence, the violation of professional secrecy and loss of assets to the State in relation to unlawful acts of a specified type, such as money laundering and terrorist financing.

▪ Decree-Law No. 123/2017 of 25 September 2017 – Sets forth the scheme for the conversion of bearer securities into nominative securities, in execution of Law no. 15/2017 of 3 May 2017.

▪ Decree-Law No. 61/2007 of 14 March 2007 – Approves the legal system governing the control of cash carried by natural persons entering or leaving the EU through the Portuguese territory, and the control of cash movements with other EU Member States.

▪ Resolution No. 88/2015 of the Council of Ministers of 1 October 2015 – Establishes the AML/CFT Coordination Committee.

▪ Ministerial Order No. 345-A/2016 of 30 December 2016 – Amends Ministerial Order No. 150/2004, which establishes the list of countries, territories and regions with privileged taxation systems.

▪ Portuguese General Tax Law – Article 63-C imposes the mandatory use of bank accounts only for corporate activities, as well as – where invoices or equivalent documents are equal or higher than 1000 EUR – the use of payment methods that allow to identify the respective recipient.

▪ General Regime on Tax Infractions – Article 129 sets forth the fines that apply to offences arising from the violation of obligations set forth by article 63-C of the General Tax Law.

▪ CMVM Regulation no. 3/2015 – Venture Capital, Social Entrepreneurship and Specialised Alternative Investment.

▪ CMVM Regulation no. 2/2015 – Collective Investment Undertakings (Securities and Real Estate) and the Marketing of Individual Open-End Pension Funds.

▪ CMVM Regulation no. 2/2020 - establishes measures to prevent and combat money laundering and the financing of terrorism to be implemented by financial obligated entities subject to CMVM supervision and by auditors within the scope of the attributions conferred by Law No. 83/2017, of 18 August (the "LBCFT") and by Law No. 97/2017.

▪ Deliberation No. 988/2017 of 9 November 2017 – Procedures concerning the compliance with the obligation of communicating operation start and real estate transactions made.

▪ IMPIC Regulation No. 603/2021 of 2 July 2021 - Regulation within the scope of preventing and combating money laundering and terrorism financing in the real estate sector that revokes IMPIC Regulation no. 276/2019, of March 26.

▪ the Circular Letters of Banco de Portugal and/or CMVM and/or Regulation (EU), which impose restrictive measures against certain persons and entities.

▪ For more information, please check the Legislation page at www.portalbcft.pt , where you can find the updated, effective legislation.

Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) Measures Adopted by LYNX

• LYNX has internal policies and procedures in place that guarantee the compliance with the national AML/CFT legislation.

• LYNX applies the following relevant policies and procedures:

▪ Risk Assessment, which is an essential process to prevent and combat money laundering and terrorism financing that promotes a risk-based approach. By using this approach, LYNX focuses more on controlling clients, products, markets, transactions or counterparties that present the biggest risk of money laundering and terrorist financing.

▪ Preventive duties that impose a vast range of AML/CFT obligations, among others such as Obligation of control; Obligation of Customer identification and customer due diligence; Obligation to issue suspicious transaction reports; Obligation to refrain from carrying out transactions; Obligation to refuse to carry out transactions; Obligation to keep documents and records; Obligation of scrutiny; Obligation to cooperate; Obligation of non-disclosure; Obligation to train staff.

▪ Knowing and Monitoring the Client and Counterparties, which ensures compliance with the obligation of identifying every Client and Counterparties, monitoring operations made via computer records. Every new account that is opened is checked against the lists of suspects and terrorist organisations notified by the relevant authorities.

▪ Politically Exposed Persons (PEPs) and holders of other public positions are identified, and the monitoring of their operations reinforced (both as Clients and beneficial owners).

▪ Document Retention, which lasts 10 years after the operation has been made, even when the commercial relation has terminated.

▪ Monitoring of Suspicious Operations, which is made using a risk-based approach.

▪ Reporting of Suspicious Transactions is made pursuant to the internal policies and procedures to comply with the obligation of reporting to the Attorney General’s Office and the Financial Intelligence Unit of Polícia Judiciária all transactions that may constitute the practice of money laundering or terrorist financing.

▪ Reporting of relevant bank account transactions and verification of transfers: LYNX reports all relevant suspicious bank operations above €15,000 (or less, if suspicious) or above €1,000 in case it involves virtual assets and also any suspictious transations to the Attorney General’s Office and the Financial Intelligence Unit of Polícia Judiciária. Transfer details are checked (LYNX uses the banking system for this purpose).

▪ Training in AML is given to all Employees, every six months, unless there are changes that require shorter intervals.

▪ Compliance activity is exercised independently.

▪ Sanction Policy: LYNX does not establish or keep business or operation relationships with sanctioned persons or entities.

ENGAGEMENT POLICY ON LISTED COMPANIES

1. PURPOSE

1. The purpose of this Policy is to ensure an effective and sustainable involvement of LYNX in companies whose shares are traded on a regulated market (commonly referred to as listed companies) that are subject to investment by the collective investment undertakings (CIU) managed by the same, as well as by the investment portfolios of its Clients under its discretionary management (Portfolios) and, to that extent, describes how LYNX integrates the involvement of its role as shareholder in the investment strategy of those companies (hereinafter referred to as Investee Companies).

2. When drafting the Policy, LYNX complied with the regulatory framework in force and, in particular, with the provisions of article 251-B of the Portuguese Securities Code (“CVM”), approved by Decree-Law No. 486/99, of 13 November, as amended, and article 92-B of the General Regime of Collective Investment Undertakings (“RGOIC”), approved by Law no. 16/2015, of 24 February, as amended, both provisions entered in the referred laws through Law No. 50/2020, of 25 August, which transposes Directive (EU) No. 2017/828 of the European Parliament and of the Council, of 17 May 2017, into national law, as regards the encouragement of long-term shareholder engagement.

3. The regulatory framework of this Policy is composed of the following legal documents:

a) Decree-Law No. 89/2017, of 28 July, which transposes Directive 2014/95/EU of the European Parliament and of the Council of 22 October 2014 that amended Directive 2013/34/EU, into Portuguese law, as regards disclosure of non-financial and diversity information by certain large undertakings and groups.

b) Law No. 50/2020 of 7 August, which transposes Directive (EU) 2017/828 of the European Parliament and of the Council of 17 May 2017, into Portuguese law, as regards the encouragement of long-term shareholder engagement.

c) The General Regime of Collective Investment Undertakings, approved in an annex to Law No. 16/2015, of 24 February, republished by Decree-Law No. 56/2018, of 9 July and amended by Law No. 35/2018, of 20 July, amended and republished by Decree-Law No. 144/2019, of 23 September, amended by Law No. 25/2020, of 07 July and amended by Law No. 50/2020, of 7 August.

2. SCOPE OF APPLICATION

1. This Policy shall be applicable wherever LYNX invests in shares traded on the regulated market, on behalf of the CIU and/or Portfolios managed by it, i.e., it shall be applicable only when the investment is made in shares representing the share capital of companies admitted to trading on a regulated market (listed companies) and shall be applicable taking into account, at all times, the particular circumstances of each Investee Companies and the size and/or relevance of the shareholding/investment held therein.

3. MONITORING OF INVESTEE COMPANIES ON RELEVANT ISSUES

1. In order to carry out a diligent and comprehensive monitoring of Investee Companies, LYNX systematically and permanently collects and analyses the relevant information available concerning them, including, in particular, their strategy, capital structure, risk, corporate governance, financial and non-financial performance and the social and environmental impact of these companies.

2. LYNX shall monitor the information concerning Investee Companies that is publicly disclosed, in particular relevant facts, as well as information on their corporate and other events that may affect them in the performance of their activity or in their liquidity and solvency.

3. The monitoring of the listed matters shall be carried out in accordance with the following criteria.

3.1. RISK, STRATEGY AND CAPITAL STRUCTURE

1. LYNX shall carry out an integrated analysis of the risk inherent to the Investee Companies, taking into account the various risk factors involved, namely strategic risks, business risks, financial risks, market risks, liquidity and solvency risks, operational risks, corporate governance risks and risks linked to environmental and social sustainability.

2. Given their importance, strategy, the capital structure of the Investee Companies, their financial capacity, solvency and market risk are the main aspects considered and monitored by LYNX.

3. The risk analysis of each Investee Company (effective or potential) shall be carried out by LYNX in close articulation with the investment Policy of the CIU under management and/or with the risk profile associated with each Portfolio under management.

3.2. CORPORATE GOVERNANCE

1. LYNX shall ensure that Investee Companies in which it has a relevant position, given the amount invested and/or the influence exercised, adopt the best corporate governance practices and shall support a vision of value creation for them in the medium and long term.

2. As issuers of shares admitted to trading on a regulated market (listed companies), Investee Companies are legally binded to prepare annual information on the corporate governance structure and practices adopted and also to disclose a set of information (pursuant to Article 20 of Directive 2013/34/EU of the European Parliament and of the Council of 26 June 2013, as amended and, in the case of issuers of shares admitted to trading on a regulated market located or operating in Portugal, under Article 245-A of the CVM). This information allows LYNX to know and monitor the options and decisions taken by Investee Companies regarding various aspects of their corporate governance.

3. In analysing the governance of Investee Companies, LYNX shall pay particular attention to the following factors: i) the degree of transparency and alignment of interests with the CIUs and Portfolios under management; ii) the effectiveness and adequacy of adopted governing policies; iii) the organisational culture and its ability to reflect the values and principles of each company; iv) the remuneration policy and the risk profile associated with it; and v) the environmental, social and governance sustainability policy.

4. LYNX may decide to disinvest or refrain from investing, in particular if it considers that the Investee Company does not follow adequate corporate governance practices, does not present satisfactory indicators of the factors specified in the previous paragraph, at its discretion, or its performance and activity is not aligned with the interests of the CIU and/or the Portfolios under management.

3.3. FINANCIAL AND NON-FINANCIAL PERFORMANCE AND ENVIRONMENTAL AND SOCIAL IMPACT

1. In monitoring the performance of Investee Companies, LYNX shall analyse not only the financial information, but also the non-financial information, this information being disclosed under Articles 19-A and 29-A of Directive 2013/34/EU of the European Parliament and of the Council of 26 June 2013, as amended (or other rules that may replace these), for companies issuing shares admitted to trading on a regulated market located or operating in the European Union, and under Articles 66-B and 508-B of the Portuguese Companies Act (or other rules that may replace these) for companies issuing shares admitted to trading on a regulated market located or operating in Portugal (companies listed on the Portuguese stock exchange).

2. With regard to the environmental impact of Investee Companies, LYNX shall endeavour to avoid investment in activities that significantly undermine the environmental objectives set out in Regulation (EU) 2020/852 of European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (Taxonomy Regulation), and in complementary European legislative acts, safeguarding the situations in which such investment may be legally carried out and provided that it complies with the Investment Policies of the CIUs under management or the investment purposes of the Portfolios under management.

3. On the other hand, LYNX shall guide its actions in an articulated manner with the Sustainability Policy, in particular with regard to the Sustainable Development Goals (SDGs).

4. With regard to the impact in terms of social sustainability of Investee Companies, LYNX places particular emphasis on activities involving human rights violations and child labour.

5. LYNX shall undertake to carry out its activity, in relation to the Investee Companies, in compliance with the ESG factors (Environmental, Social and Governance - ESG), considering that the creation of value by Investee Companies requires the consideration of the impact in terms of social and environmental sustainability and governance resulting from their activity and the distribution chains used by them. Such commitment may determine a double effect, either not investing in listed companies that do not comply with relevant ESG criteria (negative selection), or investing in listed companies that comply with ESG criteria (positive selection).

4. DIALOGUE WITH INVESTEE COMPANIES

LYNX considers dialogue with the Investee Companies to be important and, therefore, whenever justified, shall establish direct contact with them, namely to transmit suggestions that may seem relevant on any matter of special importance or concern, taking into account its alignment with the interests of the CIUs and the Portfolios under management.

5. EXERCISE OF VOTING AND OTHER RIGHTS ATTACHED TO SHARES

1. LYNX shall diligently and critically exercise the rights attached to the shareholdings in Investee Companies held by the CIUs and the Portfolios under management by the same, including, in particular, the corresponding voting rights.

2. The exercise of voting rights in the aforementioned Investee Companies by LYNX shall be based on case-by-case analysis according to the information collected and the particularities of each case, always acting: i) in the exclusive interest of the participants of the CIU under management and in compliance with the investment policy inherent to each CIU; and ii) in the exclusive interest of the holders of the Portfolios under management and in compliance with the investment purposes of each Portfolio.

3. LYNX shall partake in the general meetings of Investee Companies, whether they are based in Portugal or abroad, when, at its sole discretion, it deems that there is a justified interest in such attendance and with a view to the consequent exercise of voting rights.

4. LYNX shall make the exercise of voting rights at general meetings of Investee Companies conditional on compliance with the following principles and rules:

a) Relevance of the resolution

LYNX admits to vote only on resolutions of great and inescapable impact on the interests of Investee Companies, assessed from the point of view of the participants of the CIUs or the Portfolios under management, including, but not limited to, when restrictions on the liquidity of the instruments held may be at stake, in particular, regarding limitations on the rights of shareholders.

(b) Effectiveness of the vote

A decision to vote shall only be formed where the number of votes represented by LYNX is relevant in determining the outcome of the resolution.

c) Independence of the vote

The decision to vote and the way of voting are formed, exclusively, on the basis of the exclusive interest of the participants of the CIUs and of the Portfolios under management, as well as in accordance with the respective Investment Policies and purposes, and LYNX does not reveal its vote prior to the general meeting being held.

d) Concerted voting

The eventual concerted voting in Investee Companies shall only occur in favour of defending the interests of the participants of the CIUs under management and in accordance with their investment policy, as well as in favour of defending the Clients who are the owners of the Portfolios under management and in accordance with their investment purposes and seeking, whenever possible and in accordance with these factors, to safeguard the sustainable development and continuity of the said Companies.

e) Public Disclosure

LYNX shall disclose annually to the public on its website: i) the way it votes in the general meetings of its Investee Companies; such disclosure may exclude votes that are not significant in view of the subject matter of the vote or the size of LYNXs’ holding in the company; ii) a general description of the way it votes in those companies; and iii) an explanation of the votes it considers, at its sole discretion, to be the most important.

f) Use of Consultants

LYNX does not intend to use voting consultants and shall develop internally the necessary analysis regarding the exercise of voting rights, without prejudice to the possibility of doing so, if and when it deems necessary or convenient, always aiming at the exclusive interest of the participants of the CIU under management and the holders of the Portfolios under management, the respect for the respective Investment Policies and purposes and the sustainable development of the company.

g) Representation for voting

i. In the case of Investee Companies where it is impossible for LYNX employees to attend the relevant general meetings, LYNX may resort to third parties duly mandated to ensure the representation and/or transmission of the vote, it being understood that the vote, whenever possible, shall be previously determined by LYNX, which shall communicate it to its representative.

ii. If LYNX decides to exercise the right to vote at a general meeting, its representation may only be conferred on a director or employee of the company, or on an independent entity without a stake in the capital of LYNX, and may not be conferred on an entity with which it has a controlling or group relationship or which holds a shareholding position in the Investee Companies.

iii. Whenever possible, the proxy mandate shall be accompanied by specific instructions on the resolutions likely to be voted on and the corresponding vote and the LYNX representative may not vote on any resolution without express and prior instruction from LYNX’s Board of Directors.

h) Prevention of conflicts of interest

The right to vote in Investee Companies shall always be exercised by LYNX with respect for the principle of preventing conflicts of interest, LYNX seeking to ensure that this exercise occurs without the existence of conflicts of interest or, at least, with the mitigation of any existing conflicts.

6. COOPERATION WITH OTHER SHAREHOLDERS

1. LYNX shall maintain an open dialogue and may cooperate with other reference shareholders of the Investee Companies whenever this is relevant and appropriate for the defence of the interests of the participants of the CIU under management and/or the holders of the Portfolios under management, in accordance with their respective Investment Policies and purposes and provided that this does not imply any violation of current legal and/or regulatory rules or of any internal Policies.

2. The issues that are most likely to involve cooperation with other shareholders of the Investee Companies include the preparation of lists for the appointment of members of the corporate bodies and the approval of amendments to the articles of association. The commitment to this cooperation with other shareholders of the Investee Companies shall depend on the nature and size of the shareholding held and shall be more relevant in Investee Companies where a more significant shareholding is held.

3. The cooperation to be established with the other Investee Companies’ shareholders, however, shall respect the autonomy of each one and, as such, shall not imply its qualification as concerted action for the purposes of article 20 of the Portuguese Securities Code.

7. COMMUNICATION WITH STAKEHOLDERS

1. LYNX shall be attentive to the impact of Investee Companies on the communities in which they are located and may cease investment in them if they have a negative impact or if it is not possible to prevent or stop their negative impact on the communities, always safeguarding the interests of the participants of the CIU under management and/or the holders of the Portfolios under management, as well as respect for the respective Investment Policies and purposes and the sustainable development of the company.

2. LYNX shall keep an open dialogue with the interested parties in Investee Companies (e.g. employees, creditors, clients, public authorities) whenever it is relevant, to the extent appropriate to safeguard the interests of the Investee Companies themselves and the interests of the participants of the CIU under management and/or the holders of the Portfolios under management, always with respect for the regulatory framework in force and the investment policies and purposes of the CIU and the Portfolios under management.

3. Regarding the communication with Investee Companies’ employees, LYNX shall respect the applicable limitations imposed by law, bearing in mind and respecting the legal duties of loyalty and confidentiality imposed on such employees, particularly under Article 129(1)(f) of the Portuguese Labour Code and, where applicable, the duty of confidentiality resulting from Articles 78 and 79 of the General Regime of Credit and Financial Institutions and Article 304(4) of the Securities Code, which require employees to maintain loyalty to their employers, in particular by not disclosing information regarding their organisation, production methods or business. Where there are proper communication channels between shareholders and employees, LYNX shall communicate through those same channels.

8. CONFLICTS OF INTEREST

1. LYNX is aware that real or potential conflicts of interest may arise with regard to its involvement and therefore mechanisms shall be put in place to identify possible conflicts of interest and act to prevent or minimise the risk of their occurrence.

2. LYNX has a Conflict of Interest Policy in place that establishes the procedures and measures to be adopted for the identification, management and mitigation of conflicts of interest.

9. EXPLANATION OF NON-COMPLIANCE WITH THIS POLICY

Annually, LYNX shall disclose to the public, on its website, a clear and reasoned explanation as to why it has failed to comply with one or more of the requirements of this Policy, where such a failure has occurred.

10. APPROVAL, SUPERVISION AND REVIEW

1. This Policy has been approved by the Board of Directors and it shall be the responsibility of the various areas of the Company to implement the necessary procedures to comply with it.

2. LYNX integrates in its periodic validation procedures the criteria of analysis of Investee Companies carried out periodically. These records shall allow it to produce evidence of the various parameters of analysis of the Investee Companies, so that it shall be possible to know them in depth and the eventual need to question them or take any action against them, particularly at a general meeting.

3. The Compliance Department and the LYNX Compliance Officer shall be responsible for monitoring compliance with this Policy and for preparing the annual reports on its application. This Policy shall be reviewed regularly in the light of the experience of its application and of any legislative changes, being the Compliance Department and the Compliance Officer responsible for submitting proposals for revision to the Board of Directors.

11. TERM OF VALIDITY

This Policy shall be valid for an indefinite period, without prejudice to eventual amendments, adaptations and updates that may be necessary and agreed upon by LYNX’s governing bodies.

12. PUBLICATION

1. This Policy shall be made available for consultation on the LYNX website at [www.lynxassetmanagers.com].

2. LYNX shall also annually disclose to the public, on its website, annual reports on the implementation of this Policy.