1.0 Enclosed Documents
These documents were drawn up based on an analysis carried out by Wealtheon sa, licensed by the FSMA/Belgium, AMF/France, AFM/Netherlands or CSSF/Luxembourg. These documents do not comply with the regulations to promote the non-alignment of investment research and are not subject to any sanction upon acting prior to the distribution of results from the investment research. Wealtheon sa is hereinafter referred to as ‘Wealtheon’.
1.1 Notification
The investment strategies and recommendations in these documents are a basic facsimile of in-company discussions at Wealtheon and of Wealtheon's investment strategies. They do not contain any recommendations whatsoever based on evaluation of your or your client's personal state of affairs and should not to be mistaken for a personalized investment advice. Therefore, it is a matter of your consideration whether and if so, how the recommendations and strategies in these documents are implemented.
1.2 Memo
A description of the category, characteristics and risks related to equities and other financial instruments can be found in the memo regarding the category, characteristics and risks of securities which is attached to the agreement on providing investment recommendations.
2.0 Information Investment Recommendations by Wealtheon
In accordance with the relevant legislation, please find below a detailed overview of the sources, principles and methods, no-conflict-of-interest statement and policy on conflicts of interest.
2.1 Investment Recommendations and Primary Sources
For the outline of the following prominent primary sources were used: Bloomberg LLP, The Economist, OESO, Morgan Stanley, JP Morgan, Merrill Lynch. The issuers of the incorporated equities were not consulted as a source. Moreover, they were not informed on the contents of the investment recommendations prior to distribution.
2.2 Principles and Methods
For the assessment of a financial instrument or an issuer of such, Wealtheon deploys the following principles and methods: macro-economic analyses performed by Wealtheon [and] technical analyses performed by Wealtheon, company analyses performed by Wealtheon. The corporation observes a time span of approximately 5 years with regard to the valuation of historical data.
In this respect, Wealtheon abides by methods which the corporation considers to be sufficiently detailed, accurate and reliable. Wealtheon is not liable for results which are achieved or obtained consequent to the use or pursuing of these analyses and recommendations.
2.3 No interests involved nor possible conflict of interests
By means of this memorandum, Wealtheon declares to have no association whatsoever with any issuer which – in the event of making investment recommendations – could affect the corporation’s position to either advise in favor of or against the issuer concerned. The term ‘association’ refers to any relationship – other than based on exclusively business- and/or service-related objectives – which might cause Wealtheon to put forward a different investment recommendation than if such an association would not have existed.
2.4 Policy on Conflict of Interest
On request, you will receive a memorandum with a summary of Wealtheon’s policy on Conflicts of Interest including the measures which have been implemented in order to avoid and prevent any such situation.