Definitions of professional and well-informed investors

Last update 06.04.2021

“Professional Investor”

An Investor which is considered to be a professional client or may, on request, be treated as a professional client within the meaning of Annex II of the Investment Services and Activities and Regulated Markets Law 87(I)/2017 as amended. In general terms, a Professional Investor:

(a)

is considered to be the entity which is authorized or regulated to operate in the financial markets, including but not limited to entities authorized by an EU member state under the applicable European legislation. In addition, Professional Investors include but are not limited to large undertakings with prescribed net turnover and balance sheet totals, national and regional governments, public bodies that manage public debt, central banks, international and supranational institutions.

(b)

is upon request treated to be so if certain identification criteria are fulfilled and the prescribed procedure is followed as per the aforesaid Annex II.

“Well–Informed Investor”

Every Investor which is not a Professional Investor and fulfils the following conditions:

(a)

(i) he/she possess sufficient knowledge and experience in financial and business matters in order to be able to evaluate the benefits and risks associated with the planned investment in the Company’s Compartments and he is aware of the risks associated with the planned investments of the Company’s Compartments; or

(ii) his/her business activities are related with the management, acquisition or disposal of assets, either on his own account or on behalf of third parties, which are of the same type as the investments of the Compartment(s) he wishes to invest in; and

(b)

(i) his/her investment in a Compartment of the Company is at least equal to the minimum of EUR 50,000 (fifty thousand euro) (or currency equivalent); or

(ii) he/she has been assessed as a well-informed investor by a credit institution, or by an AIFM or by a UCITS management company or by an investment firm or by a manager which is licensed in Gibraltar or in another EU member state for the management of AIFs and AIFs with Limited Number of Persons whose assets under management do not exceed the thresholds laid down in article 4(2) of the AIFM Law or the corresponding article 3 paragraph (2) of Directive 2011/61/EU, and the above mentioned assessment indicates that he possess sufficient knowledge and experience in financial and business issues to be able to evaluate the benefits and risks associated with the planned investments of the Company’s Compartment(s) based on its (their) investment policy(ies); or

(iii) he/she is employed by any of the entities mentioned in subparagraph (ii) of paragraph (b) above and receive total remuneration that takes him/her into the same remuneration bracket as Natural Persons who effectively conduct one of the business activities of the entities mentioned in subparagraph (ii) of paragraph (b) or as the executive members of their government body who effectively conduct one of their business activities; whereas

(c)

without prejudice to paragraphs (a) and (b), persons who direct the Company or they are assigned with portfolio management duties related with the Company.