Investor's corner

Access to the different standards to which the performance of the companies in the GVC Gaesco Group is subject ...

• Circular 1/1996, of March 27 CNMV on rules of conduct
• Law 19/2003 of 4 July on the legal system of capital movements
• Law 24/1988 of July 28 on the Securities Market
• Royal Decree 1/2002 of 29 November
• Royal Decree 217/2008 of 15 February, on the legal system for investment services firms
• Royal Decree 362/2007 of 16 March, amending Regulation
• Royal Decree 364/2007 of 16 March, which modifies Royal Decree 685/1982, of 17 March
• Royal Decree 1333/2005 of 11 November, developing Law 24/1988 of 28 July
• Royal Decree 1819/2009 of 27 November, modifying Royal Decree 948/2001

GVC Gaesco Beka, S.V. S.A.U. has established a number of internal policies with the aim of enhancing the customer or potential customer's protection. This protection is to be achieved through three mechanisms:

• Ensuring maximum transparency.
• Reducing costs of operations.
• Establishing new requirements on the entity when providing investment services to customers or potential customers, as well as in implementing these investment services.

Below is the list of approved policies of GVC Gaesco Beka, S.V. S.A.U.:

• Best Execution Policy
  

  This section describes the criteria adopted by GVC Gaesco Beka, S.V. S.A.U. in executing customer orders, taking into account the characteristics of the customer, including their categorization as a retail or professional customer and the characteristics of the order, the characteristics of the financial instruments subject to the order and the execution venues or brokers to which it can go.

• Treatment policy orders

  This section describes the general procedures used by GVC Gaesco Beka, S.V. S.A.U. on reception, registration and execution, as well as the areas responsible for processes and functions.

• Asset Safeguarding Policy

  This section describes the measures that GVC Gaesco Beka, S.V. S.A.U. takes to ensure the protection of financial instruments and cash from customers in the development of their management and custody.

• Conflict of Interest Management Policy

  This section describes the mechanisms to effectively prevent conflicts of interest that may arise between GVC Gaesco Beka, S.V. S.A.U. and its customers or between customers, and that may result in injury to the same in the provision of investment services and effective management of conflicts of interest.

• Incentive Policy

  In this policy the conceptual typologies of commissions or other remunerations that might be received from or paid to GVC Gaesco Beka, S.V. S.A.U. are analysed, as well as the disciplines in which GVC Gaesco Beka, S.V. S.A.U. will further regarding the transparency of such fees and the provision of information to customers about them.

• Recordkeeping Policy

  In this policy the general principles are discussed in terms of records maintained by GVC Gaesco Beka, S.V. S.A.U., specific obligations regarding customer orders and transactions, as well as other maintenance obligations.

• Outsourcing Policy

  The criteria set out in this policy deal with the conceptual parameters and decision-making for both outsourcing functions related to investment services or activities by GVC Gaesco Beka, S.V. S.A.U. as necessary for the efficient operation of these investment service functions.

• Compliance Policy

  The powers and functions of the GVC Gaesco Beka, S.V. S.A.U. Regulatory Compliance of Securities set out in this policy, establishing the basis of the performance.

When providing investment services, GVC Gaesco Beka, S.V. S.A.U. must provide their retail customers (including potential customers) with this information prior to signing the contract for the provision of investment or ancillary services:

Pre-contractual information:

• Pre Documentation
• Corporate presentation
• Standard Rates
• Brochure of maximum rates filed with the National Stock Market Commission

Contractual Information:

• Contract of Custody and Administration of Securities
• Specific Terms for intermediation in National and International Financial Markets
• MEFF Derivatives Brokerage Contract
• International Derivatives brokerage contract

The GVC Gaesco Group, following current regulations, has established different levels of protection to customers based on their classification:

• Retail Customer: granted by default to natural persons and legal entities that can not be regarded as professional customers. The level of protection is maximum.

• Professional Customer: granted by default to entities that must be authorized or regulated to operate in financial markets, large companies and agencies that meet the quantitative criteria. The level of protection is medium.

• Eligible Counterparty: granted by default to firms providing investment services, credit institutions, insurance companies, collective investment vehicles and their management companies, other authorized or regulated financial entities, national governments and their corresponding offices. The level of protection provided is minimal.

The following documents give more details:

• Level of protection and discipline for each of the categories by type of customer
• Change of customer procedure categorization

The investment services and assistance that GVC Gaesco Beka, S.V. S.A.U. can give are listed in the following document:

• Types of services

Different levels of protection have been identified according to the rules, which depend on the services provided by GVC Gaesco Beka, S.V. S.A.U. to its customers.

Advisory and discretionary portfolio management will therefore enjoy greater protection than mere execution services or marketing products.

In order to provide discretionary management services and/or advice, GVC Gaesco Beka, S.V. S.A.U. shall perform the Customer Suitability Test. The purpose of the test is that the customer profiling and portfolio allocation should meets your objectives, financial situation, knowledge and experience.

The growing concern of the international community for the threat of money laundering and financing of terrorist activities has prompted legislators in most countries to set certain rules and obligations on certain subjects whose activity may be used in money laundering or terrorist financing activities.

The companies belonging to the GVC Gaesco Group are obliged to collaborate with the authorities in preventing these criminal activities.

The GVC Gaesco Group recognizes the importance of the fight against money laundering and terrorist financing, and is aware of the risk involved in the development of their activities in terms of the possible misuse of their services in order to launder money or finance terrorist activities.

Therefore, the GVC Gaesco Group is committed to working closely with the Competent Authorities by incorporating adequate and effective control mechanisms.

It is a priority for the GVC Gaesco Group to implement, verify and ensure that the measures and systems in place to meet the objectives are adequate and functioning properly.

The following documents describe certain procedures established by the GVC Gaesco GVC Group in order to mitigate the risks described above:

• Procedure for customer identification and awareness
• Procedure for accepted receipt and payment means
• Risk Operations Catalog

The GVC Gaesco Group is registered with the National Stock Market Commission Internal Rules of Conduct, whose main objective is to determine the behaviour and performance criteria to be observed by competent persons in accordance with what is stated in its articles, in connection with securities transactions and Public Information, as well as the processing, use and disclosure of Material Information in order to promote transparency in the development of the GVC Gaesco Group's activities and the proper disclosure and protection of investors and such other persons or institutions with regard to the GVC Gaesco Group.

The Rules of Conduct are supplementary codes of conduct or standards of a similar nature to the law or to what the competent authorities have generally established in the General Code of Conduct for Securities Markets and standards, developed or modified whenever appropriate, which will be strictly enforced by the GVC Gaesco GVC Group.

The following documents set out the principles of action that competent persons in the GVC Gaesco Group shall apply in all their actions.

• Principles of operation of the competent persons of GVC Gaesco GVC Group

The GVC Gaesco Group Customer Service Department has been created to safeguard the rights and interests of customers, knowing and addressing their complaints and grievances.

The Customer Service Department therefore contributes actively to increasing and improving the quality of the service that customers receive from the GVC Gaesco Group.

The primary function of this department is to study, process and resolve claims on financial services, operations or contracts made by GVC Gaesco Group customers regarding compliance with current regulations.

Once the necessary reports and documentation have been collected, and after a thorough analysis of the claims file, the Customer Service Department answers the customer in writing.

If the existence of any kind of problem or issue is observed as a result of the relationship with the GVC Gaesco Group, it is advisable to first try to resolve it via the assigned financial or commercial agent.

If, nevertheless, you do not agree with the proposed resolution, your complaint should be sent to the GVC Gaesco Group Customer Service Department in writing by completing the attached document and adding all necessary proof.

• Claim Document

In compliance with Organic Law 15/99, we inform you that the personal data you provide on this form will be included in data processing owned and operated by GVC Gaesco Beka, S.V. S.A.U., the sole purpose of which is to properly manage your claim.

You can, at any time and free of charge, exercise all rights to access, rectify, cancel and oppose your data and revoke your authorization without retroactive effects (in the terms specified in the Law on Data Protection Personal and according to the procedure established by law) by writing to GVC Gaesco Beka, S.V. S.A.U., C/Doctor Ferran, 3-5 Barcelona 08034.

The Proof of the Claim may be submitted via the following channels:

• By letter to: GVC Gaesco Beka, S.V. S.A.U. Customer Department - Doctor Ferran nº 3-5

08034 Barcelona - Tel. 93 366 27 27

• By fax: 93 414 06 62
• Paper Claim filed directly at our headquarters.
• By e-mail: atencionalcliente@gvcgaesco.es

• Customer Regulation Department

There is an additional figure for settling claims within GVC Gaesco Group, which is the 'Servicio de Defensor del Cliente de Bolsas y Mercados Españoles Sociedad Holding de Mercados y Sistemas Financieros, S.A.'.

This Banking Ombudsman Service is an efficient implementation of the protection and defense of customers established by Law 44/2002 of 22 November, on measures to reform the financial system and its instrument for implementation.

The Banking Ombudsman Service is competent to handle and resolve complaints and claims that customers bring against the entities of the GVC Gaesco Group on transactions and facts that have not been resolved by the Customer Service Department.

Customers may direct complaints as follows:

Customer Lawyer

Plaza de la Lealtad 1

28014 Madrid

• Regulation of the Banking Ombudsman (dated 2008 ...)

First you must go to Customer Service and the GVC Gaesco Group Customer Ombudsman. If you do not agree with the answer, or if two months have elapsed without a response, you can complain to the Commission.

The National Stock Market Commission has jurisdiction to deal with complaints from users regarding the performance of investment service firms, credit institutions (when providing investment services), fund managers and investment companies.

The claim must necessarily include the following information:

• Identification of the person or complainant: name, ID, address for service and contact number.
• Identification of the claimed entity and office in which the facts have occurred.
• Reason for or cause of the claim.
• Statement that the facts have not been or are not under litigation, arbitration or analysis in any other administrative or court proceedings.
• Copy of the complaint filed in the Customer Service or the Ombudsman of the entity or documentary evidence that two months have passed without a response from the company.
• Place, date and signature.
• Any documentation or information deemed appropriate in support of the claim.

Complaints should be addressed to:

Investor Assistance Office.

C/ Miguel Ángel 11

28010, Madrid.

http://www.cnmv.es/Portal/inversor/Como-Reclamar.aspx

The purpose of the GENERAL INVESTMENT GUARANTEE FUND (FOGAIN) is to offer customers of securities firms brokers and portfolio management companies to cover damages in the event that any of these entities might come under creditor intervention or insolvency by the National Stock Market Commission.

In either of these cases, if a customer can not receive a refund or delivery of cash and securities entrusted to the entity, the FOGAIN deploys its coverage and compensates said customers with a maximum amount of €100,000 for customers of institutions incurring any of the above events after the enforcement of Royal Decree 1642/2008, of 10 October, that is, October 11, 2008.

GVC Gaesco Beka, S.V. S.A.U. is attached to the Investment Guarantee Fund in accordance with the provisions of current legislation in order to ensure maximum protection of its customers' funds and financial instruments.

•  Corporate Bylaws

• Organization chart
• Board of Directors
• Compensation and Nomination Committee
• Audit and Control
• Procedures to ensure the suitability of the members of the Board of Directors

  Corporate Bylaws

The remuneration paid to the Board of Directors of GVC Gaesco Beka during the financial year 2017 amounts to  €4,000 in subsistence allowance. Solvency Report.

The remuneration policy of the management company is included within the remuneration policy of the Hacve Group. The remuneration policy is consistent with sound and effective risk management and does not provide incentives to take risks that exceed the level of risk tolerated. HACVE ASSETS Group Compensation Policy Summary