1. ARC is an investment firm registered in the commercial register of the Handelsgericht Wien (Commercial Court Vienna), at FN 219012b. The license granted by FMA (Austrian Financial Market Authority), Otto-Wagner-Platz 5, 1090 Vienna, comprises investment advisory services/consulting according to the act establishing the Federal Securities Supervisory Authority (WAG). As an investment firm, ARC is not licensed to accept or hold client funds or financial instruments.
2. The scope of our license entitles us to provide advisory services to interested parties (basically professional clients acc. to the WAG) – i.e. we provide product recommendations but neither accept nor remit buying/selling orders – about the following financial instruments:
   1. Transferable Securities
   2. Money Market Instruments
   3. Investment & Real Estate Funds Shares
   4. Financial Derivatives (securities, currencies, interest)
   5. Credit Derivates
   6. Financial Margin Trading
3. ARC is entitled to consult intermediaries bound by contract or financial service assistants acc. to WAG to provide securities services requiring a license.
4. in addition to investment consulting, ARC provides the following services:
   1. organisation and execution of presentations and training seminars
   2. supply of information, such as provided by publications and news services
   3. implementation of research and advisory projects, particularly relating to investment strategies that provide for "absolute proceeds"
5. information about ARC can be found in the Internet at www.arc.at.

1. You can reach us from Monday to Thursday between 9 a.m. and 5 p.m. and Friday between 9 a.m. and 3 p.m. by telephone at + 43 1 521 06 31
2. Our postal address (= registered office of ARC) is: Köstlergasse 1/28, A-1060 Vienna, Austria.
3. You can also contact us via fax (+ 43 1 521 0649) or e-mail office@arc.at.
4. All consulting on financial instruments is solely accomplished by ARC in personal interviews.
5. You can communicate with us in German and English. Documents provided for our clients (such as the present brochure) are available in German and, to some extent, also in English.

Included in the scope of ARC’s licenses is the right to consult intermediaries bound by contract or financial service assistants to provide securities services. However, ARC presently makes no use of this right.

ARC provides advice to interested parties but accepts no buying/selling orders for products . Nor does ARC remit such orders to banks, investment companies etc. Therefore, ARC has neither implemented a Best-Execution-Policy nor principles of order execution/forwarding and does not report on such. This duty falls to the respective institutes carrying out the client’s orders without the involvement of ARC.

ARC is anxious to always provide its services in the best interest of its clients. For this purpose, ARC has taken precautions to assure that potential conflicts of interest between ARC, its management, employees and possible co-operation partners (investment companies etc.) on one hand, and clients on the other (or conflicts between clients) can have no negative effects on the client’s interest. These precautions are briefly explained below:

1. At which points can conflicts arise?

   ARC foresees potential conflicts of interest between clients and

   1. ARC
   2. ARC’s employees, including its management
   3. other clients.
2. Which financial services can lead to conflicts of interest?
   1. Investment consulting: the delivery of personal recommendations concerning the dealing with financial instruments
   2. ARC’s involvement in the preparation of financial analyses to the emitter of the respective financial instrument or establishes financial analyses on its own (§§ 36, 37 WAG)
3. Potentiale Conflicts of Interest
   1. ARC has distribution agreements with selected investment companies (= not with all investment companies in the Austrian market
   2. ARC receives commissions/brokerage in varying rates from these investment companies for the portfolios brokered in Austria
   3. Personal business dealings by ARC‘S employees (including the management) involving the same products clients are provided advice for.
   4. "Benefits" (§ 51 WAG) or other (non-monetary) equivalents by product providers or other third parties
4. Precautions against conflicts of interest

   The relevant legal rules and regulations oblige ARC and its employees to act with due lawfulness, diligence and fidelity in the interest of its clients. The aim of these rules and regulations is to guarantee early detection and, if possible, prevention of potential conflicts of interest. The prevention of such potential conflicts of interest is the duty of the compliance organization. The following precautions were implemented to avoid conflicts of interest:

   1. all employees, whose activities are likely to lead to conflicts of interest, are obliged to disclose their transactions concerning financial instruments
   2. the compliance officer is authorized to bar employees from transactions in securities
   3. Priority of interests. Client interest always overrides the interests of ARC or its employees
   4. specific rules and regulations for all employees in charge of financial analyses
   5. regular trainings and instruction for the relevant employees
   6. ARC has established mandatory rules and regulations for the employees concerning other potential benefits (such as invitations etc.) proffered by product providers or other third parties and monitors compliance with these rules.
5. Disclosure of conflicts of interest

   In certain isolated cases it is possible that ineluctable conflicts of interest not stated in this list may arise. Should such a case arise, ARC will inform the client about the specific conflict of interest (such as commission payments by product partners).

1. Objective consulting services for value: the client is responsible for his decisions and pays solely for our consulting services. In this case the client will receive a document by whose countersigning he acknowledges that ARC has arrangements with certain product partners (mentioned by name) and therefore receives commissions from said product partners.
2. Remuneration of ARC via the emitter: the client acknowledges by his signature that the consulting fee is covered by the product partner via compensations/commissions to ARC and is thus ultimately settled via a portion of the management fee and thus by the client.
3. In case of a consulting mandate, ARC remits the commissions/compensations and other benefits (acc. to WAG) granted to ARC by product partners or other third parties for successful procurement to the client, up to the amount of the fee agreed upon (balancing), so that parallel accounting of fee and commissions cannot take place.
4. Insofar as the benefits granted to ARC serve as remuneration for investment advisory service, they are (amongst other things) also used for the maintenance of ARC’s infrastructure, IT, employee training initiatives or the professional information processing for our clients
5. The Austrian Financial Market Authority (FMA) lists the standard fees for security services on its homepage free of charge (https://www.fma.gv.at/en/financial-service-providers/investment-service-providers/market-standard-fees/) eine Liste der marktüblichen Entgelte für Wertpapierdienstleistungen veröffentlicht.

1. As of now ARC does not foresee any significant potential negative consequences of sustainability risks affecting either investment advisory, assets, finances, profits or firm reputation. We will actively observe any given or potential negative consequences of sustainability risks affecting either investment advisory, assets, finances, profits or firm reputation within our risk management strategy (Risk Management) and will thereby be able to react on potential risks.
2. ARC feels obliged to its ecological, social and climate friendly business operations but does not include the most prominent negative effects of investment decisions on sustainable factors to the broader extent of our work in the strict sense of the Disclosure Regulation, as the necessary financial products and -instruments, which content-wise fully comply in terms of information disclosure to the regulation, have limited availability, meaning that it is therefore not possible for the firm to perform business in terms of the Disclosure Regulation.
3. Sustainability risk does not affect the remuneration policy of the firm. The remuneration policy neither engages in incentives to participate in excessive sustainability risks nor advantages or disadvantages financial products, which promote sustainable investing (according to Article 8 of the Disclosure Regulation) or actively strive for such (according to Article 9 of the Disclosure Regulation).