Data Protection | Concept Capital Group AG

Regulatory Information

Client information

This text applies mutatis mutandis to females and a plural

This information brochure provides you with information about Concept Capital Group AG (hereinafter referred to as «Concept Capital» or «Asset Manager»), our measures to avoid assets without contact and dormant assets, the financial services we offer and the associated risks, how we deal with conflicts of interest, compensations and the initiation of mediation proceedings before the Ombudsman's Office as well as the data protection declaration. The information in this brochure may change from time to time. The latest version of this brochure can be accessed at any time at www.conceptcapital.world.

We inform you about the costs and fees of the financial services offered in the respective appendix to our asset management agreement.

For information on the risks generally associated with financial instruments, please refer to the brochure «Risks Involved in Trading Financial Instruments» published by the Swiss Bankers Association. The brochure is available on the Internet under the online link:

SBA_Risks_Involved_in_Trading_Financial_Instruments_2019_EN.pdf swissbanking.ch

This brochure fulfils the information requirements under the Financial Services Act (FinSA) and the Ordinance to the Federal Act on Data Protection (DPO) and is intended to provide you with an overview of the financial services offered by Concept Capital Group AG and the handling of client data.

Should you require further information, we would be pleased to be at your disposal in a per- sonal meeting.

Content

Information about Concept Capital Group AG......................................................................3
1. General information............................................................................................................3
2. Field of activity.................................................................................................................... 3
3. Supervisory status and competent authority and supervisory organization...........3
4. Business affiliations............................................................................................................3
Dormant assets...........................................................................................................................4
Financial services offered by Concept Capital......................................................................4
1. Portfolio Management........................................................................................................4
  1. Nature, features and functionalities of the financial service...............................4
  2. Rights and obligations.................................................................................................5
2. Execution Only..................................................................................................................... 5
  1. Nature, features and functionalities of the financial service...............................5
  2. Rights and obligations.................................................................................................5
3. Risks...................................................................................................................................... 5
4. Market offer taken into account........................................................................................7
Conflicts of Interest.................................................................................................................. 8
1. In general..............................................................................................................................8
2. Compensations from third parties....................................................................................9
Ombudsman's offices................................................................................................................ 9
Data Privacy Policy..................................................................................................................... 9
1. General information.............................................................................................................9
2. Data security........................................................................................................................ 10
3. Categories of personal data...............................................................................................10
4. Origin of personal data....................................................................................................... 10
5. Purpose of processing.........................................................................................................10
6. Disclosure to third parties, categories of recipients..................................................... 11
7. Outsourcing of Services...................................................................................................... 11
8. Duration of storage.............................................................................................................. 12
9. Rights of the data subjects..................................................................................................12
10. Mentioned organizations, companies etc.........................................................................12
11. Contact....................................................................................................................................12

1. Information about Concept Capital Group AG

1.1 General information

Name

Concept Capital Group AG

Address

Gartenstrasse 17

ZIP / City

8002 Zurich

Phone

+41 44 512 79 65

E-Mail

info@conceptcapital.world

Website

https://www.conceptcapital.world

Trade Reg. Nr.:

CHE-199.478.954

VAT.-Nr.:

CHE-199.478.954

1.2 Field of activity

Concept Capital Group AG has its registered office and place of business in Zürich. It essentially carries out the following activities:

Portfolio Management for retail, professional and institutional clients;
Execution-only services for private, professional and institutional clients;
Offering financial instruments;
Other services: family office services

For further information on Concept Capital, please refer to our corporate presentation.

1.3 Supervisory status and competent authority and supervisory organization

Concept Capital obtained a license as an asset manager pursuant to Article 17 of the Financial Institutions Act (FinIA). The license is granted by the Swiss Financial Market Supervisory Authority FINMA, Laupenstrasse 27, 3003 Bern. Concept Capital is supervised by AOOS – Schweizerische Aktiengesellschaft für Aufsicht, Clausiusstrasse 50, 8006 Zürich, Switzerland, +41 44 215 98 98, info@aoos.ch, www.aoos.ch

1.4 Business affiliations

Concept Capital has no economic associations with third parties which could lead to a conflict of interest.

In particular, Concept Capital is neither legally nor economically part of a group or cor- porate structure, nor does it maintain any significant ties with third parties.

As an independent asset manager, Concept Capital deliberately works together with several custodian banks.

2.Dormant assets

Occasionally, contacts with clients are broken off and assets subsequently become dormant. Such assets can be permanently forgotten by the clients and their heirs. The following is recommended to avoid loss of contact or dormant assets:

Change of address and name: Immediate notification of any change of resi- dence, address or name;

Special instructions: Information about longer absences and of any redirec- tion of correspondence to a third-party address as well as of how the client can be reached in urgent cases during this time;

Granting of powers of attorney: An authorized person can be designated whom Concept Capital can approach in the event of an interruption of contact;

Substitute contacts: It may be advisable to provide the contact details of the legal successors and/or other persons who can be contacted by Concept Capi- tal in the event of a breakdown or loss of contact in order to (re)establish con- tact with the client or his legal successors. It is the client's responsibility to in- form Concept Capital of any changes in the respective contact details;

Orientation of trusted persons and testamentary disposition: Another pos- sibility to avoid lack of contact and news is to inform a trusted person about the relationship with the asset manager. However, the asset manager may only provide information to such a trusted person if he or she has been authorized to do so in writing. Furthermore, the assets concerned may be mentioned, for ex- ample, in a testamentary disposition.

Concept Capital is available for any questions. Further information can also be found in the brochure «Dormant Assets» published by the Swiss Bankers Association. The brochure is available on the Internet under the online link «Dormant Assets (swissbanking.ch)».

3. Financial services offered by Concept Capital

3.1 Portfolio Management

3.1.1 Nature, features and functionalities of the financial service

In asset management, Concept Capital manages, in the name, for the account and at the risk of the client, assets which the client has deposited with a custodian bank. Concept Capital carries out transactions at his own discretion and without consulting the client. In doing so, Concept Capital ensures that the transaction he executes corresponds to the client's financial circumstances and investment objectives as well as to the investment objectives agreed with the client and ensures that the structuring of the portfolio is suitable for the client.

3.1.2 Rights and obligations

The client has the right that the assets in his portfolio are managed by the asset man- ager. In doing so, Concept Capital selects the investments within the framework of the considered market offer to be included in the portfolio with due care. Concept Capital shall ensure an appropriate distribution of risk to the extent permitted by the investment strategy. It shall regularly monitor the assets under his management and ensure that the investments are in line with the investment strategy agreed on in the investment profile and are suitable for the client.

Concept Capital shall regularly inform the client about the asset management agreed on and provided to the client.

Pursuant to Art. 72 FinSA, Concept Capital is also obliged to provide the client with a copy of its client file and all documents relating to them at the client's request. By sign- ing the contract, the client agrees that the disclosure may be made electronically.

3.2 Execution Only

3.2.1 Nature, features and functionalities of the financial service

Execution Only refers to all financial services that involve the mere transmission of cus- tomer orders by Concept Capital without any advice or administration. In the case of Execution Only, orders are initiated and transmitted to Concept Capital exclusively by the customer. Concept Capital does not check whether the transaction in question is in line with the client's knowledge and experience (appropriateness) or financial circum- stances and investment objectives (suitability). In connection with the future placing of orders by the customer, Concept Capital will not reiterate that no adequacy and suitability check will be carried out.

3.2.2 Rights and obligations

In the case of Execution Only, the Client has the right to place orders for the purchase or sale of financial instruments within the scope of the market offer taken into account. Concept Capital has the duty to transmit placed orders for execution

with the same dili- gence that it uses in its own affairs.

Concept Capital shall inform the client without delay of any material circumstances that may affect the correct processing of the order. Furthermore, Concept Capital shall reg- ularly inform the Client about the orders agreed upon and performed

3.3 Risks

The following risks may arise in connection with the financial services provided by Con- cept Capital, which are within the client's sphere of risk and must therefore be borne by the client:

Risk of the selected investment strategy: The investment strategy selected and agreed upon by the Client may give rise to various risks (cf. below). The cli- ent bears these risks in full. A presentation of the risks and a corresponding risk explanation are provided before the investment strategy is agreed on.

Substance preservation risk or the risk that the financial instruments in the portfolio depreciate: This risk, which can vary depending on the financial instrument, is borne in full by the client. For the risks of the individual financial instruments, please refer to the brochure «Risks Involved in Trading Financial Instruments» of the Swiss Bankers Association.

Information risk on the part of Concept Capital or the client, or the risk that Concept Capital or the client has too little information to make an informed in- vestment decision:

In the case of portfolio management, Concept Capital will take into ac- count the client's financial circumstances and investment objectives. If the client provides Concept Capital with insufficient or inaccurate information regarding his financial circumstances and/or investment objectives, there is a risk that Concept Capital will not be able to make investment decisions that are suitable for the client.

In Execution-only, the client makes investment decisions without the intervention of Concept Capital. Accordingly, the client requires specialist knowledge to understand the financial instruments and time to familiarize himself with the financial markets. If the client does not have the necessary knowledge and experience, the client runs the risk of investing in a financial instrument that is inappropriate for him. A lack of or in- adequate financial knowledge could also lead to the customer making investment decisions that do not correspond to his financial circum- stances and/or investment objectives

Risk as a qualified investor in collective investment schemes: Clients who make use of asset management or investment advisory services within the framework of a permanent portfolio management or investment advice relation- ship are considered as qualified investors within the meaning of the Collective Investment Schemes Act (CISA). Qualified investors have access to forms of collective investment schemes that are exclusively open to them. This status allows a broader range of financial instruments to be taken into account. Collective investment schemes for qualified investors may be exempt from regulatory requirements. Such financial instruments are therefore not or only partially subject to Swiss regulations. This may give rise to risks, in particular with regard to liquidity, investment strategy or transparency. Detailed information on the risk profile of a particular collective investment scheme can be found in the constituent documents of the financial instrument and, where applicable, in the basic information sheet and the prospectus.

Cluster risks or concentration risks refer to the risk of a portfolio being dependent on certain securities, issuers, etc. if these make up a large part of the portfolio. In times of a market downturn, such portfolios may suffer more extensive losses than more diversified portfolios. Concept Capital addresses these risks in the context of asset management by monitoring the following thresholds:
- Concentrations of 10% or more in individual securities;
- Concentrations of 20% or more in individual issuers.

Concentrations due to collective investment schemes that are subject to regulatory risk diversification requirements are excluded from these thresholds.

The provisions on concentration risks also apply in the same way to proprietary products of Concept Capital or to products of third parties economically linked to Concept Capital.

In the case of Execution Only, the following risks may also arise:

Risk regarding the timing of the order placement or the risk that the client chooses a bad time for the order placement, which leads to price losses.

Risk of insufficient monitoring or the risk that the client does not monitor his port- folio or monitors it insufficiently: The asset manager does not have a monitoring, warning or clarification obligation at any time. Inadequate monitoring by the client may be associated with various risks, such as cluster risks.

Furthermore, portfolio management may involve risks that lie within the sphere of risk of Concept Capital and for which Concept Capital is liable vis-à-vis the client. Concept Capital has taken appropriate measures to counter these risks, in particular by observing the principle of good faith and the principle of equal treatment when processing client orders. As far as it is within its sphere of influence Concept Capital shall ensure the best possible execution of customer orders.

3.4 Market offer taken into account

The market offer taken into account when selecting the financial instruments compromises only third party financial instruments. Within the scope of portfolio management and portfolio related investment advice, the following financial instruments in particular are available to the client:

Account balances with domestic and foreign banks
Money market investments
Interest-bearing debt securities (bonds, etc.)
Equity securities (shares, etc.)
Collective investment instruments (investment funds of all standard banking in- vestment instruments, namely securities, indices, real estate, commodities)
Alternative investments, non-traditional investments
Standardized and non-standardized derivative financial instruments
Precious metals
Insurance products

Concept Capital does not invest in contracts for difference and does not engage in securities lending as a counterparty or as an agent. Any agreements between the client and the custodian bank in this regard are completely outside the responsibility of Concept Capital.

In the case of Execution Only, the market offering taken into account in the selection of financial instruments is based on that of the custodian bank selected by the client.

Use of derivative products

Concept Capital may use derivative products on behalf of its clients. Concept Capital shall only use such products if and to the extent that this is permissible in accordance with the legal, professional and contractual investment regulations applicable in the specific case and taking into account any investment instructions. Derivatives are used in this context to hedge existing securities positions or to build up new securities posi- tions. Derivatives that are traded on a recognized stock exchange or over-the-counter are permitted.

Use of self-managed products

Concept Capital may also use a self-managed products like strategy indices (Actively Managed Certificate, AMC) for its clients if and to the extent that this is permissible in accordance with the applicable statutory, professional and contractual investment regulations in the specific case and taking into account any investment instructions.

The client is aware that Concept Capital may receive additional compensation when using its own financial instruments, in particular self-managed products, e.g. due to management fees that may arise at the product level (so-called double remuneration). These are treated as third-party compensation and the corresponding measures apply (see section 4.2).

The use of structured products is associated with particular risks for investors, such as issuer and guarantor risks. Concept Capital takes these risks into account appropriately in its risk management and explicitly draws its customers' attention to the risks associated with the structured products in a suitable manner.

Concept Capital will generally purchase these assets through a bank, stock ex- change or broker. However, it may also make the acquisition outside organized markets or multi-lateral trading systems.

4.Conflicts of Interest

4.1 In general

Conflicts of interest may arise when Concept Capital has an interest in the outcome of a financial service provided to clients that is contrary to that of the Clients.

Possible causes of conflicts of interest are namely:

Financial incentives for Concept Capital to carry out certain investment decisions, e.g. compensation from third parties
The use of Concept Capital's own products or those of third parties economically linked to him
The coincidence of several client orders
The coincidence of client orders with Concept Capital's own transactions or those of his employees.

The following chapter regulates the handling of compensation from third parties.

Furthermore, no conflicts of interest arose in the course of providing services to the client at Concept Capital that could not be completely resolved by countermeasures.

4.2 Compensations from third parties

Concept Capital may receive compensation from third parties (e.g. brokerage fees, com- missions, commissions, rebates, kick-backs, finder's fees, portfolio maintenance com- missions or other pecuniary benefits) in connection with the provision of its financial ser- vices.

The level of third-party compensation is independent of the chosen investment strategy and is specified in “Annex IV: Information on compensation from third parties”.

In order to avoid potential conflicts of interest in this context, Concept Capital has taken the following measures to minimize conflicts of interest through compensation from third parties:

Contractual regulation specifying the range of the compensation paid by third parties in the individual service contracts or their annexes. The customer can request further information about possible future compensation from third parties and how it will be handled at any time.

Obligation to disclose compensation from third parties: Upon request, Concept Capital shall inform the Client of the compensation actually received. Information on such a request is provided free of charge once a year; if the customer exercises this right more frequently, Concept Capital reserves the right to charge a fee to cover costs.

Concept Capital also agrees with the Client on a performance-related profit share based on the annual performance increase of the total assets under man- agement. This should lead to an alignment of the interests of Concept Capital and the Client.

4.3 Use of own financial instruments in addition to those of third parties

Concept Capital may experience the following conflicts of interest as a result of using its own financial instruments, in particular self-managed products:

Receiving additional compensation, in particular levying additional management fees at the product level (so-called double remuneration); for Actively Managed Certificates (AMCs) managed by Concept Capital, this additional compensation amounts annually to 0.01% to 0.5% of an AMC’s volume.

Regardless of management fees, Concept Capital may have an interest in maximizing the volume of these products in order to reduce costs or take advantage of synergies, for example.

These conflicts of interest cannot be completely eliminated, but the following measures have been taken to mitigate them:

Organizational measures to avoid unjustified preferential treatment of own financial instruments over third-party financial instruments

Additional compensation from own products is considered third-party compensation and the corresponding measures apply.

Concept Capital also agrees with the client on a performance-related profit share based on the annual performance increase of the total assets under management. This is intended to align the interests of Concept Capital and the Client.

5.Ombudsman's offices

In the event of disputes, the client may initiate a mediation procedure before the follow- ing ombudsman's office:

Name:

OFS Ombud Finance Switzerland

Address:

16 Boulevard des Tranchées

ZIP / City:

1206 Genf

Phone:

+41 22 808 04 51

E-Mail:

contact@ombudfinance.ch

Website:

https://ombudfinance.ch/

6.Data Privacy Policy

Information on data protection can be found in our privacy policy, which can be accessed at https://www.conceptcapital.world/data-protection.

May - 2025