Precontractual Information Disclosure
Pursuant to Art. 165 of the Regulation adopted by Consob Resolution No. 20307/2018 (the "Intermediaries Regulation"), information on Mr. Marco Terrone (hereinafter the "ADVISOR") and the services provided by him is set out below.
The information contained in this Document must be provided to the client or potential client before they are bound by an agreement for the provision of investment advisory services, or in any event before such service is provided.
The recipient of this document is invited to read the following before making any decision regarding the conclusion of an investment advisory agreement.
The ADVISOR is available to provide further information regarding the nature and characteristics of the investment advisory service.
1. Advisor Information
2. Language Used
The Client may communicate with the ADVISOR and receive documents and information in Italian or English.
3. Methods of Communication Used
The sending of letters, information notes, reports, any notifications, and any other written statement or communication, including changes to the information contained in this Document, unless otherwise provided by law or contract, will be made to the Client with full effect at the address indicated upon signing the contract or subsequently communicated in writing.
The Client may choose, at the time of signing the advisory service contract or by subsequent written communication, to receive information via a non-paper durable medium and, in particular, via email. For this purpose, the Client will indicate a valid email address accessible only to him and undertakes to keep it active (or communicate in writing a different valid email address) until 14 months after the termination of the contract.
Communications and/or any notifications to the ADVISOR must be sent by the Client to the ADVISOR's registered address or by certified email (PEC) to the addresses indicated above.
The sending of recommendations by the ADVISOR and the confirmation of the execution of operations by the Client may be carried out in the following ways:
4. Registration in the Register pursuant to Art. 18-bis of Italian Legislative Decree No. 58 of February 24, 1998
It is declared that the ADVISOR is registered in the section of the register referred to in Art. 18-bis of Italian Legislative Decree 24.2.1998 (TUF) held by the Supervisory Body provided for in Art. 31, paragraph 4 of the said Decree, by Resolution of 02/07/2026 No. 3020.
The name and contact address of the Supervisory Body are:
Financial Advisors Register Offices - UACF
Viale Lunigiana 46 – 20125 Milano (MI)
5. Reporting on the Performance of the Advisory Service
The ADVISOR sends the Client the following reports regarding the performance of the advisory service:
- Quarterly/Semi-annually/Annually: within 30 days from the end of each calendar quarter/semester/year, a report containing the composition and performance of the Portfolio;
- Comprehensive annual report: within 60 days from the end of the calendar year, a report containing:
- a) an updated statement indicating how the Portfolio corresponds to the Client's preferences, objectives, and other characteristics;
- b) the recommendations provided during the reference period;
- c) in aggregated form, the costs and charges of the Service provided and of the Financial Products and services recommended.
- identifying, with reference to the investment advisory service, the circumstances that generate or could generate a conflict of interest that could harm the interests of one or more clients;
- defining the procedures to be followed and the measures to be adopted to prevent or manage such conflicts.
- The analysis of the client's overall portfolio allocation and the evaluation of the efficiency of the held products
- The potential reformulation of the portfolio asset allocation and of the financial instruments and products held based on the information provided by the client
- The periodic evaluation, on an annual basis, of the suitability of the portfolio
- Transferable securities
- Units and shares in collective investment undertakings (UCITS/funds)
- Corresponds to the client's investment objectives, including their risk tolerance;
- Is of such a nature that the client can financially bear the risks associated with the investment compatibly with their investment objectives;
- Is of such a nature that the client possesses the necessary knowledge to understand the risks involved in managing their portfolio.
- Their knowledge and experience in investment matters regarding the specific type of product or service;
- Their financial situation, including their ability to bear losses;
- Their investment objectives, including their risk tolerance;
- Their sustainability preferences.
- Analysis and research on financial instruments and products;
- Advisory services for the assessment and coverage of wealth and income risks;
- Advisory services for the assessment and coverage of pension integration needs;
- Advisory services for the optimal management of income flows;
- Advisory services for personal and family financial planning;
- Advisory services in negotiations with investment and insurance companies regarding applied conditions;
- Advisory services for the asset, financial, and economic coordination between private, professional, and corporate activities.
6. Conflict of Interest Policy
Pursuant to Art. 177 of the Intermediaries Regulation, the ADVISOR has adopted a Conflict of Interest Policy aimed at:
The procedures and measures adopted are aimed at identifying and preventing conflicts of interest that could arise between the ADVISOR and the Client or between the Client and other clients of the ADVISOR at the time of providing the Service covered by this Contract, in order to prevent such conflicts of interest from adversely affecting the Client.
Where the measures adopted are not sufficient to avoid, with reasonable certainty, the risk of damaging the Client's interests, the ADVISOR will clearly inform the Client on a durable medium of the general nature and/or sources of potential conflicts of interest arising from the recommendations provided, as well as the measures adopted to mitigate the related risks, so that the Client can make an informed investment decision.
The Client may request further analytical details on the conflict of interest management policy from the ADVISOR using the contact details previously provided.
7. Provided Activity and Methods of Performance
The advisor carries out the investment advisory service referred to in Art. 1, paragraph 5, letter f) of the TUF, consisting of "the provision of personalized recommendations to a client, at their request or on the initiative of the service provider, regarding one or more operations relating to financial instruments".
In particular, the service provided by the advisor covers:
The personalized recommendations provided to the client in execution of the service may cover a wide range of financial instruments attributable to the following categories listed in Annex 1, Section C, of the TUF:
Personalized recommendations may also cover financial products other than financial instruments, such as financial products issued by insurance companies and financial products issued by banks, as well as portfolio management services and reception and transmission of orders services.
The advisor reserves the possibility to perform the ancillary services referred to in No. 3 and No. 5 of Annex 1, Section B, of the TUF. The provision of non-personalized recommendations is not foreseen. With regard to any other professional activities carried out by the advisor, it is specified that they are not subject to supervision by Consob or the Register. The aforementioned advisory activity is aimed at both retail and professional clients. In carrying out the activity, the advisor is not obliged to update the recommendations provided to the client and to communicate to the client the losses suffered on the recommended instruments.
The client is free not to proceed with the investment/divestment operations recommended in execution of this contract. The service may also be provided by the advisor in a place other than his registered address.
The advisor is not authorized to execute the operations recommended to the client, who may carry them out through authorized intermediaries (banks, investment firms - SIMs, asset management companies - SGRs) within the framework of the investment services and activities provided by them. As remuneration for carrying out the advisory service, the client is required to pay the advisor a fee commensurate with the content and value of the service. In the absence of a unique method of quantifying the compensation, it may vary depending on the complexity and size of the assets under advice, the client's objectives and risk profile and, generally, the time the advisor will dedicate to the analysis and study of the specific case. Therefore, the advisor undertakes to submit a personalized fee proposal to the potential client, after they have provided the necessary summarized information and before they are bound by an agreement for the provision of the advisory service.
Payment terms and schedule will be indicated in the aforementioned fee proposal. The fee paid by the client constitutes, by law and by contract, the advisor's sole form of remuneration for services rendered; the advisor is prohibited from receiving compensation (inducements) from third parties.
The advisor is required, by professional code of conduct, to be independent from the issuers of the recommended financial products, as well as from the intermediaries authorized to carry out the investment services through which the client executes the recommendations. In providing the advisory service, the advisor cannot hold funds or securities belonging to clients.
The client and the advisor may agree that the advisor has authority to view the client's investments at the banks, financial intermediaries, or asset management companies utilized by the client, without any authorization to operate. They may also agree that these investment companies send information on operations executed by the client directly to the advisor.
For more information on the contents of the advisory service and the obligations of the advisor and the client, reference is made to the investment advisory contract which must be signed prior to the performance of the service.
8. Periodic Suitability Assessment
In performing the investment advisory service, the advisor provides the client with recommendations in relation to investment or divestment operations which, if executed, ensure the suitability of the portfolio with respect to the client's profile rebuilt on the basis of the information provided by filling out the questionnaire submitted before the conclusion of this contract or during any subsequent updates.
In particular, the advisor verifies that the recommended operation:
The advisor performs a periodic suitability assessment of the portfolio on an annual basis.
The suitability assessment is carried out to enable the advisor to act in the client's best interest. It is therefore essential that the client, by filling out the questionnaire submitted by the advisor, provides correct and updated information concerning:
The client is required to communicate any updates to the information. This information enables the advisor to understand the essential characteristics of the client and to recommend financial products and investment services that are suitable with particular reference to their risk tolerance, ability to bear losses, and sustainability preferences; if the client does not provide the information requested in the questionnaire, the advisory service cannot be provided.
The client must be aware that incorrect or untruthful answers can compromise the reliability of the suitability assessment and decrease their level of protection. The advisor is required to refrain from making recommendations if none of the financial products and investment services are suitable for the client.
9. Integration of Sustainability Factors
Pursuant to Art. 165 paragraph 1 letter h-bis of the Intermediaries Regulation, in the selection process of financial instruments covered by the investment advisory service, the advisor integrates an assessment regarding environmental, social, and governance (ESG) sustainability factors, in order to ensure that products and instruments are only recommended to clients who express sustainability preferences compatible with the characteristics of the instruments themselves.
Since the advice provided by the advisor concerns the financial portfolio as a whole, the assessment of sustainability factors is carried out at the portfolio level. This means that, as a whole, the portfolio must be aligned with the client's sustainability preferences; however, for reasons of risk management or achieving client objectives, some individual instruments used might not be aligned with the aforementioned preferences.
The assessment of environmental, social, and governance sustainability characteristics is carried out depending on the type of instrument/product according to the information declared by the issuer under current regulations or using external evaluation models (ratings) and/or internal analyses.
10. Other Professional Activities Conducted by Marco Terrone
Marco Terrone provides the following activities in addition to the investment advisory service:
The aforementioned activities, although personalized, do not concern specific financial instruments or financial products.
The performance of the aforementioned activities is regulated by a specific contract, distinct from the one relating to the investment advisory service, which provides for the payment of a fixed or variable fee agreed with the client from time to time, commensurate with the content and value of the activity provided.
The activities indicated above are not subject to supervision by Consob, the Register, or other Authorities.
11. Proposed Investment Strategies
In performing the advisory service, the ADVISOR is not biased towards specific categories or a specific range of financial instruments.
The ADVISOR does not propose standardized investment strategies but assesses the most suitable strategy for each Client, taking into account the Client's investment objectives, risk tolerance, and financial situation, including their ability to bear losses.