Regulation

1. Information about the company and the services it provides

 

• Contact information

Business name: RSI Global Investiciono Drustvo ad Podgorica

Abbreviated name: RSI GLOBAL Podgorica

Headquarter: Ankarski bulevar 16, Podgorica, Montenegro

PIB: 03393429

Registration number: 40009801

Share capital: 950,000 Euros

Internet address: www.rsiglobalinvest.com

Email: [email protected]

Phone:

Accounts:

Hipotekarna Bank AD Podgorica

Client domestic account 520-000000043829-23

Corporate domestic account 520-000000043828-26

Client foreign account ME25520004200000291835

Corporate foreign account ME25520004200000291738

 

• Investment services and activities

 

The company performs the following financial services and activities:

1. execution of orders for the client's account,
2. trading for its own account,
3. portfolio management,
4. investment consulting,
5. services of conducting the offer, i.e. sale of financial instruments from the obligation to

purchase,

6. services of conducting the offer, i.e. sale of financial instruments without the obligation of

redemption.

• Work permit

 

The regulatory body that has issued a license to the Company to provide investment services is

 

the Capital Market Authority (hereinafter: the Authority), by Decision No. 03/2-4/1-21 from the date of 06.09.2021, and 03/2-4/3-21 from the date 04.10.2021.

 

• Communication with clients

 

• The language of communication

 

The language of communication is Montenegrin and English. The Company may communicate

with clients - foreign legal or natural persons in English or another foreign language provided by

the contract.

 

• Manner of giving and receiving orders

 

In accordance with Article 27 of the General Business Rules of the Investment Company, the

Company receives client orders in the following ways:

- directly, in writing,

- by mail, telephone or electronically.

An order received in writing is valid if it is signed by the client or his authorized representative /

proxy. Receipt of the order by phone is valid if the call was received from the phone number

registered as a means of communication, which the client submits when opening the account.

Every telephone conversation with clients is recorded in order to have an archive as evidence

for receiving orders.

 

• Place of placing an order

 

The Company may accept orders in:

- the registered office of the Company,

- business premises of an authorized investment company

 

       1.4.4. Manner of submitting documentation and other information by the Company

 

The Company presents to its clients and potential clients general acts and other documents in

the Montenegrin language.

For clients of foreign legal and natural persons, the Company will provide translation into English

of general acts and other written and information.

 

• Client reporting

 

The Company will provide the client with a notice on the following:

- time and place of receipt of the order, change and revocation of the order;

- acceptance or refusal to execute the order, stating the reasons for refusing the order,

immediately upon receipt of the order, and no later than the next working day from the day of

receipt / rejection of the order.

Immediately after the execution of the order, the Company will deliver to the client:

- submit important information on the execution of the order, i.e. to the small client the

Certificate on the execution of the order, no later than the first working day after the

execution of the order, in the manner defined by the contract,

- notification of the price of each individual tranche if the transactions are executed in

tranches.

The Company will notify the client of any significant change in the information provided, through

a durable medium or in a manner specified in the Agreement.

The Company shall, at least once a year, submit to each individual client a report on the Client's

assets, ie financial instruments held for the Client in the manner specified in the Agreement,

unless such report is submitted as part of another periodic report.

At the client's request, the Company will provide the client with proof that it has executed the

order in accordance with the adopted policies and procedures on order execution.

The Client is obliged to immediately notify the Company in writing of the change of address and

other data that are relevant for notification, as well as for the fulfillment of the Company's

obligations in providing investment and additional services and activities.

 

• Information regarding the protection of financial instruments

 

The Company may use financial instruments from the client's account only on the basis of the

client's order.

The Company has established adequate systems for the protection of clients 'property rights

which prevent the use of clients' financial instruments on behalf of the Company or on behalf of

other clients, except with the express consent of the client.

The accounts of the Company's financial instruments are separated from the clients' accounts.

Clients' financial instruments are not owned and do not enter the Company's assets and cannot

 

be used to pay the Company's liabilities to clients.

Clients' financial instruments may not be included in the liquidation or bankruptcy estate of the

Company, nor used to pay its liabilities,

The Company may not pledge or dispose of financial instruments owned by a client without his

prior written authorization.

The Company may not:

- executes client orders in a manner that is not in accordance with the Law on Capital Market

("Official Gazette of Montenegro", No. 001/18) and acts of the Authority, i.e. acts of a regulated

market, or MTP,

- buys, sells or borrows for its own account the same financial instruments that are the subject

of the client's order before acting on the client's order.

The Company may hold financial instruments of clients for the purpose of providing financial

services to a third party on its own behalf (administration of financial instruments of clients).

The Company is liable to the client only for the actions or omissions of its employees and is not

liable to the client for the actions or omissions of the competent authorities and institutions.

The Company is obliged to keep records, accounts and correspondence related to the client

precisely and accurately, to regularly harmonize them with the records and accounts of third

parties who hold the client's property, to keep them in such a way that at any time and

immediately distinguish the client's property. assets of other clients and assets of the Company

itself and when the client's assets are kept in a consolidated account.

The Company is obliged to take into account the expertise and market reputation of the

depositary when selecting the foreign depositary on whose accounts it will hold financial

instruments, to subject the depository to state regulations governing the safekeeping of financial

instruments for another person, to periodically review the choice of depositary and agreed

holding arrangements. safekeeping of the client's financial instruments. Exceptionally, the

Company may deposit a client's financial instruments with a depository in a country where the

holding and safekeeping of financial instruments on behalf of another person is not specifically

regulated, only if the nature of the financial instrument or investment service associated with

that instrument requires in writing the deposit of its financial instruments with a depositary in

that State. The Company may not alienate or pledge financial instruments owned by a client

without his prior written authorization, buy, sell or lend financial instruments solely for the

purpose of charging a commission or other fee, use the client's financial instruments to pay its

obligations and other clients' obligations. The client's financial instruments held by the Company

 

may be used for the Company's account or for the account of other clients only with the express

consent of the client.

 

• Conflict of interest management policy

 

Conflict of interest in the provision of investment services is possible in the following cases:

1. When the interests of a client of the Company conflict with:

- the interests of another client of the Company,

- the interests of the Company, other relevant persons and all persons closely related to them;

2. When the Company has received confidential / insider information regarding a current or

former client, which would be useful to another client;

3. When the interests of the relevant person are in conflict with the interests of the Company.

 

           1.7.1. The method of determining the existence of a conflict of interest

 

In determining conflicts of interest that may harm the interests of clients, it will be considered

whether the Company, relevant persons and persons closely related to them, by providing

investment services:

1. They can make a financial profit or avoid a loss to the detriment of the client;
2. Have a financial or other interest or benefit from the results of a service provided to a client

or a transaction performed on behalf of a client that differs from the client's interest;

3. Have a financial or other motive that corresponds to the interests of another client or group

of clients to the detriment of the interests of the client to whom a particular service is provided;

4. Perform the same activity as the client;
5. Receive or will receive from a person who is not a client additional incentive due to work done

for the client in the form of money, goods, services, etc., which is not the usual commission or fee

for that work.

An incentive in the sense of this Ordinance is considered to be any gift in the form of money,

valuables, rights and services given free of charge to the Company and / or relevant persons.

Employees can receive a gift worth up to 50 Euros, and any gift received above that amount is

required to report to the Management Board, and to return it to the giver if the Management

Board makes such a decision. Employees are not allowed to receive money as an incentive

regardless of the amount.

 

Relevant persons must not provide investment and additional services in a way that is in the

interest of individual clients and to the detriment of other clients.

The relevant person is obliged to: when providing investment services:

1. Puts the interests of its clients before its own interests;
2. To operate fairly, honestly and professionally in accordance with the best interests of clients.

Methods of managing conflicts of interest and controlling access to confidential information

include:

Control of information exchange between:

- relevant persons in the Company,

- various parts of the Company,

- obligation to report personal transactions,

- informing the client about possible conflicts of interest related to the investment service /

transaction and obtaining written consent of the client not to oppose such a conflict of interest,

- non-acceptance of the provision of investment services.

The control, access and flow of confidential information is limited to persons who must know

that information.

Relevant persons are prohibited from:

1. disclose confidential information regarding financial instruments traded on a regulated

market, i.e. MTP, or OTC, to another relevant person employed by the Company,

2. participate, personally or through the Company, in any decision on the purchase or sale of

financial instruments while in possession of confidential information directly related to the

Company

3. receive or attempt to obtain confidential information regarding financial instruments from

other employees or a client of the Company,

4. access files and databases containing confidential information, except in accordance with the

Conflict of Interest Management Policy;

5. disclose information to third parties related to the purchase / sale of financial instruments

purchased / sold by a client of the Company, as well as other insider information in order to

obtain personal benefit for themselves or third parties.

Information obtained by relevant persons in connection with issued orders and transactions of

clients' financial instruments, as well as their portfolios, is considered a business secret.

 

 

• Client complaints

 

The company is obliged to adopt procedures for dealing with client complaints. The complaint

may be filed by the Company's clients, ie the Company's potential clients, in one of the

following ways:

1. by direct submission of a written complaint at the Company's registered office,
2. by sending by mail,
3. by sending a scanned complaint by e-mail to: [email protected]

Complaints shall be submitted in writing, on the Form which is an integral part of this Ordinance

and must contain at least the following information:

1. personal data of the person submitting the complaint, namely: name and surname, i.e.

name of the legal entity, JMBG (MB), address, contact e-mail and contact telephone,

2. the date of filing the complaint,
3. description of the subject of the complaint and evidence,
4. signature of the complainant.

The client can also make a proposal for resolving the situation that is the subject of the

complaint, if he wishes.

The person authorized to act on client complaints (hereinafter: the authorized person) shall,

within five working days from the date of receipt of complaints, determine any disputed facts,

compile a report on complaints and submit it to the Executive Director of the Company.

The Executive Director to whom the complaint with the report of the authorized person has been

submitted, is obliged to immediately, and no later than within 3 working days from the day of

receipt, make a decision on the complaint and submit it to the authorized person for further

action.

 

No later than the next working day from the day of receipt of the decision of the Executive

Director, the authorized person shall forward the response to the complaint to the client in

writing.

The Company will send a response to the complaint in the manner specified by the complainant

in the complaint form. If the complainant has not specified the manner of receiving the response

to the complaint, the Company will send the response to the specified e-mail address or by mail

to the address specified in the complaint form.

 

 

2. Information regarding financial instruments

 

 

• Financial instruments and related risks

 

The Company's activities include all financial instruments defined by the Capital Market Act.

In accordance with the Law on Capital Market, financial instruments are:

1. transferable securities
2. money market instruments
3. investment units
4. derivatives, i.e. derivative financial instruments

 

• Basic characteristics of individual financial instruments

 

Transferable securities are types of securities that are transferable on the capital market,

except for payment instruments, such as:

1. shares of a joint stock company and other securities representing a share in the capital or

membership rights in companies or other entities and certificates of deposited shares;

2. bonds and other forms of securitized debt, including certificates of such deposited securities; i
3. other securities that give the right to acquire or sell transferable securities that enable the

purchase or sale or payment in cash, the amount of which is determined by reference to

transferable securities, currency, interest rates, yields, goods, or other indices or units.

Equity securities are shares and other transferable securities, equivalent to shares of the

company that represent a share in the capital, as well as other types of transferable securities

that give the right to acquire them on the basis of conversion or enjoyment of rights arising from

them.

Debt securities are bonds and other forms of transferable securitized debts, except for securities

that are equivalent to shares and securities which, if converted or exercise the voting rights

arising therefrom, give the right to acquire shares or securities of equivalent shares.

 

Shares

 

Shares are dematerialized equity securities issued by a joint stock company. A joint stock

company is a company whose share capital is divided into shares that have one or more

shareholders and have no maturity.

Actions can be:

- ordinary and

- privilege.

Shares are securities that represent participation in the capital or voting rights of a legal entity.

Shares of the same class always give the same rights. Ordinary actions always make up one

class of actions. Shares can be issued with or without par value. If the company issues shares

with a nominal value, all shares of the same class must have the same nominal value. Ordinary

shares give the rightful owner the following rights:

- the right to participate and the right to vote at the general meeting of shareholders,

- the right to dividend payment,

- the right to participate in the distribution of the liquidation balance or the bankruptcy estate

in accordance with the law governing bankruptcy,

- the right of pre-emptive acquisition of ordinary shares and other financial instruments

exchangeable for ordinary shares, from new issues,

- other rights in accordance with the Law on Capital Market and the Articles of Association of

the joint stock company.

Ordinary shares cannot be converted into preferred shares or other financial instruments.

Preference shares give the legal holder one or more privileged rights determined by the

statute and the decision to issue shares:

- the right to a dividend in a pre-determined monetary amount or a percentage of its nominal

value, which is paid as a priority in relation to the holders of ordinary shares,

- the right to have the unpaid dividend accumulated and paid before the payment of dividends

to holders of ordinary shares,

- the right to participate in the dividend belonging to the holders of ordinary shares, in all cases

of payment of dividends to the holders of ordinary shares, or

• upon fulfilment of certain conditions (participatory preferential action),
• the right of priority of collection from the liquidation balance or bankruptcy estate

in relation to the holders of ordinary shares,

• the right to convert these shares into ordinary or another class of preferred shares

(convertible preference shares),

• the right to sell these shares to a joint stock company at a pre-determined price.

 

 

Bonds

 

Bonds are long-term transferable and dematerialized financial instruments issued by states,

 

local governments, banks and companies to finance long-term investments. By issuing the

bonds, the issuer undertakes to pay the legal bondholder a certain amount of money (interest

and principal) in the manner and in accordance with the conditions under which the bond was

issued.

Bonds can be divided according to their many characteristics, and are most often divided:

- according to the issuer:

• state - the issuer is the state, ie the Ministry of Finance or the Treasury,
• municipal - the issuer is a unit of local self-government, corporate - the issuer is a

company,

- according to the interest rate:

• bonds without interest (coupon), bonds with a fixed interest rate (coupon),
• bonds with variable (coupon) interest rate,

- according to the repayment of the principal:

• bonds with one-time maturity of principal - the issuer pays the principal on

maturity,

• bonds with amortized principal repayment.

 

Money market instruments

 

Money market instruments are financial instruments that are commonly traded in the money

market, such as treasury, treasury and commercial papers and certificates of deposit, with the

exception of payment instruments.

- Treasury bills - Financial instruments issued by the Ministry of Finance in order to finance the

state budget. They are bought at auctions published by the Ministry of Finance.

- Treasury bills - Transferable financial instruments with a maturity of up to one year. They are

considered a risk-free instrument, and their main characteristics are safety and lower yield.

- Commercial papers - Transferable financial instruments issued by companies (issuer), in

dematerialized form and registered. They enable the short-term needs of the company to be

met so that the issuer, depending on the market situation, issues tranches of bills that are within

the limits of the established program. A commercial paper is usually an unsecured (unsecured)

financial instrument.

- Certificates of deposit - Transferable financial instruments by which banks obtain short-term

funds.

 

Units of collective investment institutions

 

Units of collective investment institutions are units in collective investment entities that have

received the approval of the Capital Market Authority, in accordance with the laws governing

the operations of investment and pension funds.

 

Derivatives

 

Derivative financial instruments include:

 

1. options, futures, swaps, interest rate forwards and other derivative financial instruments

related to securities, currencies, interest rates or interest yields, greenhouse gas emission

units, as well as other derivative financial instruments, financial indices or financial units

that can be settled in cash or in exchange,

2. options, futures, swaps, interest rate forwards and other derivative financial instruments

related to commodities that are obligatorily settled in cash or may be settled in cash at the

request of one of the counterparties, for reasons not related to default or contract

termination,

3. options, futures, swaps and other derivative financial contracts related to commodities that

can be physically settled, provided that those commodities are traded on a regulated

market and / or MTP and / or OTP, except for wholesale energy products traded on OTP

which must be settled by exchange,

4. options, futures, swaps, forwards and other derivative financial instruments related to

commodities that can be physically settled, in a manner not provided for in sub-item of this

item, which are not intended for trading and have the characteristics of derivative financial

instruments,

5. Derivative financial instruments for credit risk transfer;
6. financial agreements on differences;
7. options, futures, swaps, interest rate forwards and other derivative financial instruments

related to climate change, transportation costs, greenhouse gas emission units or inflation

rates or other official economic statistics that must be settled in cash at the request of one

from counterparties for reasons not related to default or termination of the contract, as

well as other derivative financial contracts related to assets, rights, liabilities, indices and

 

other units of measure that have the characteristics of other derivative financial

instruments traded on a regulated market , MTP or OTP;

8. greenhouse gas emission units.

 

• Risks of investing in financial instruments

 

• General risks in dealing with financial instruments

 

- currency risk, i.e. exchange rate risk;

- interest rate risk, i.e. the risk of loss due to changes in interest rates;

- the risk of a change in a country's credit rating, such as: the risk of inability to pay a country's

debt, political risk, including the risk of unexpected regulatory changes affecting the capital

market and the position of investors;

- inflation risk, i.e. the risk of impairment of financial instruments due to general price increases

- liquidity risk, i.e. the risk of inability to sell financial instruments on the secondary capital

market due to reduced demand or market inefficiency;

- issuer risk, i.e. the risk of impairment of financial instruments due to the fall in the issuer's

credit rating;

- bankruptcy risk, i.e. the risk of reduction or complete loss of value of financial instruments

due to the opening of bankruptcy proceedings against the issuer of financial instruments;

- market psychology risk, i.e. the risk of changes in the value of financial instruments due to

speculative activities of investors;

- risk of failure of information systems and / or risk of interruption of communication links

between authorized banks, registers, depots and clearing of securities, market organizers and

/ or regulated public markets of financial instruments;

- risk of financial leverage, purchase of financial instruments by borrowing significantly

increases the risk of loss;

- day trading risk, i.e. the risk of the possibility of daily or immediate loss due to the execution

of transactions on the same day;

- market segment risk (risk of individual market segments in the country or abroad).

 

• Special risks in dealing with financial instruments

 

Special risks in dealing with financial instruments are:

in stock business:

- market risk, volatility risk, i.e. the risk of a fall in the value of a share due to normal periodic

movements in market prices;

- yield risk, i.e. the risk of the relationship between the market price and dividend payment, or

the risk of non-payment of dividends;

- the risk of bankruptcy or liquidation of a joint stock company may lead to a complete loss

for the client;

in bond business:

- market risk, volatility risk, i.e. the risk of a fall in the value of the bond due to the usual

periodic movements of market prices,

- reinvestment risk,

- the risk of a change in the credit rating of the issuer, i.e. the risk that the issuer will not be

able to settle its due obligations on the basis of issued bonds,

- yield risk, i.e. the risk of change in yield due to the sale of the bond before maturity,

- interest rate risk, i.e. the risk of changes in the interest rate on the market in relation to the

interest rate on the bond, e.g. If the market interest rate rises more than the interest rate

on the bond,

- liquidity risk, i.e. the risk that supply and / or demand for an individual bond will decrease

or disappear completely,

- currency risk, i.e. the risk that the value of bonds denominated in one currency or with a

currency clause, and denominated in another currency due to changes in the exchange

rate of those currencies, will decrease.

in business with collective investment units:

- currency risk is the risk that is possible if the fund's assets consist of financial instruments

denominated in different currencies. Changes in the interrelation of these currencies may

affect the increase or decrease of the fund's assets, and thus the value of investors' roles in

the fund;

- market risk, i.e. the risk of a decline in the value of the fund's assets due to a fall in the value

of the prices of financial instruments in which the fund's assets are invested;

- credit risk is the risk that the issuers of financial instruments in which the fund's assets are

invested are unable to perform their financial obligations, which causes a decline in the value

of the fund's assets;

- liquidity risk is the risk that the market of financial instruments in which the fund's assets are

invested is illiquid, that the fund cannot sell financial instruments quickly and at a fair price in

 

order to meet the requirements for redemption of deposits.

in dealing with derivative financial instruments:

- position risk is the risk of loss due to a change in the price (increase or decrease) of a financial

instrument or in the case of a financial instrument derived from a change in the price of the

relevant variable;

- general position risk as a risk of loss based on a change in the price of a financial instrument

due to changes in interest rates or major changes in the capital market, regardless of any

specific characteristics of that financial instrument;

- specific position risk as a risk of loss based on a change in the price of a financial instrument

due to facts relating to the issuer of the instrument, or in the case of a derivative financial

instrument, due to facts relating to the issuer of the underlying financial instrument;

- exchange rate risk is the risk of losses arising from changes in exchange rates;

- commodity risk is the risk of loss arising from changes in commodity prices;

- liquidity risk is the risk of loss arising from the existing or expected inability of an investment

firm to settle its financial obligations within maturity.

Information on costs and related expenses

The company is obliged to provide existing and potential small investors with information on

costs, in particular:

1. the total price paid by the client in connection with a financial instrument or investment

or ancillary service, including fees, commissions, expenses and other expenses, as well as

taxes paid through the investment firm, i.e. the basis for calculating the total price, in which

the client can check if it is not possible to specify the exact price,

2. an indication of the currency and the applicable conversion rate and costs, if the amount

of the price is to be paid in a foreign currency,

3. the possibility of incurring other costs or tax liabilities related to transactions related to

a financial instrument or investment service, which are not determined and which are not

paid through the investment company,

4. method of payment or other method of fulfilment of obligations to pay costs from item.

1 and 3 of this paragraph.

The company is obliged to make a specification of commissions, which is calculated by items

separately in each case.

All data on costs and fees are listed in the Price List of the investment company.

 

 

3. Final regulations

 

This Rulebook, as well as its amendments, shall enter into force on the day of issuance of the

license for the provision of investment services to the Company by the Capital Market Authority

and shall apply from the first following day.

INTRODUCTORY PROVISIONS

 

This Policy regulates measures and procedures for identifying, monitoring and preventing the

negative impact of conflicts of interest that may occur when providing investment and ancillary

services and performing investment activities between

- the interests of the Company, persons running the Company, employees, related agents,

related agents, persons through control on the one hand and the interests of the Company's

Clients on the other hand or

- the interests of the Company's Clients to each other.

If the measures and procedures provided by this Policy will not be sufficient to reasonably

prevent the previously described negative conflict of interest, the Company will apply additional

measures and procedures in such an individual situation, and if that is not enough, the Company

will on the Permanent Media, unambiguously inform the Client about the type and / or source

of the conflict of interest, stating sufficient information on the basis of which the Client will be

able to make decisions related to the investment and / or ancillary services in which the conflict

of interest arises. All Relevant Persons in relation to the Company are obliged to act in

accordance with the provisions of this Policy. Failure to comply with the provisions of this Policy

by the Relevant Persons employed in the Company or third parties to whom certain business

processes have been assigned (delegated) within the group constitutes a serious breach of

employment obligations.

 

CIRCUMSTANCES OF CONFLICT OF INTEREST

 

When determining the types of conflicts of interest, it is assumed that the following situations

always lead to conflicts of interest:

• The Company and / or the Relevant Person could make a financial gain or avoid a

financial loss to the detriment of the Client;

• The Company and / or the Relevant Person has an interest or benefit in the outcome of

the service provided to the Client or a transaction performed on behalf of the Client that

differs from the Client's interest;

• The Company and / or the Relevant Person have a financial or other motive for favoring

the interests of another Client or a group of Clients to the detriment of the Client's

interests;

• the subject of business of the Company or the Relevant Person is the same as the subject

of business of the Client;

• The Company and / or the Relevant Person receives or will receive from a person other

than the Client an additional incentive in connection with the service provided to the Client,

in the form of monetary or non-monetary benefits or services, which is not the usual

commission or fee for that service.

 

PROCEDURES AND MEASURES FOR MANAGEMENT OF CONFLICT OF INTEREST

 

In order to prevent situations that may lead to conflicts of interest, the following procedures and

measures are applied:

• Avoiding conflicts of interest and complying with this Policy. The Company and Relevant

Persons are obliged to avoid situations that may lead to a conflict of interest, and if it already

exists or cannot be avoided, they are obliged to adhere to all measures and procedures provided

for in this Policy.

• Obligation to report conflicts of interest. Each Relevant Person is obliged, for the purpose of

recording and determining further measures and procedures, to report any circumstance that

could lead to a conflict of interest of either the Relevant Person or the Company. The mentioned

circumstances are reported to the Business Compliance Monitoring Officer, if the Company has

one, in the opposite executive director of the Company.

• Special rules related to the Organizational structure of the Company. The Company's

management will take all reasonable measures to prevent or control conflicts of interest. In

situations where the Relevant Person would be involved in various business activities, which

involve a potential conflict of interest, the Company will take all reasonable steps to establish an

adequate system of control of conflicts of interest between employees and management.

 

TRADING FOR OWN ACCOUNT OF THE COMPANY

 

The Company is allowed to acquire and dispose financial instruments for its own account, in

accordance with the provisions of the Law on capital Market and other regulations and in

compliance with the provisions of this Policy. When trading for its own account, the Company

 

may be a participant in the so-called cross transactions, i.e. such transactions in which, directly

or indirectly through third parties, certain organizational units of the Company act as buyers and

sellers of the same financial instruments.

The Company will endeavor to avoid such transactions if it is aware that the Company's Client

would be harmed.

 

OWN ACCOUNT TRADING OF THE RELEVANT PERSON

 

Relevant persons are obliged - from the beginning of taking office twice a year to the

Compliance Officer or the Director of the Company, in the period between 1st and 15th of January

and 1st and 15th of July to make and submit to the Company a signed Statement of financial

instruments at their disposal.

 

TRADING OF RELEVANT PERSONS, PERMISSIBILITY, FREQUENCY

 

Relevant persons are allowed to acquire and dispose of financial instruments for their own

account, but in accordance with all applicable laws and regulations and this Policy and other

applicable internal acts of the Company.

 

When trading for their own account, the Relevant Persons shall comply with the rules on avoiding

frequent trading.

 

CLIENT NOTIFICATION

 

Disclosure to clients is an ultimate measure that is used only if effective organizational and

administrative measures established by the Company to prevent and / or manage its conflicts

of interest are not sufficient to reasonably prevent the risk of harm to clients' interests.

 

FINAL PROVISIONS

 

This Policy applies from the day of issuing the operating license to the Investment Services

Company.

The Company's policy of managing conflicts of interest is constantly reviewed, and measures

are taken at least once a year to eliminate possible shortcomings.

CONFLICT OF INTEREST MANAGEMENT POLICY

RSI GLOBAL PODGORICA

INTRODUCTORY PROVISIONS

 

This Policy regulates measures and procedures for identifying, monitoring and preventing the

negative impact of conflicts of interest that may occur when providing investment and ancillary

services and performing investment activities between

- the interests of the Company, persons running the Company, employees, related agents,

related agents, persons through control on the one hand and the interests of the Company's

Clients on the other hand or

- the interests of the Company's Clients to each other.

If the measures and procedures provided by this Policy will not be sufficient to reasonably

prevent the previously described negative conflict of interest, the Company will apply additional

measures and procedures in such an individual situation, and if that is not enough, the Company

will on the Permanent Media, unambiguously inform the Client about the type and / or source

of the conflict of interest, stating sufficient information on the basis of which the Client will be

able to make decisions related to the investment and / or ancillary services in which the conflict

of interest arises. All Relevant Persons in relation to the Company are obliged to act in

accordance with the provisions of this Policy. Failure to comply with the provisions of this Policy

by the Relevant Persons employed in the Company or third parties to whom certain business

processes have been assigned (delegated) within the group constitutes a serious breach of

employment obligations.

 

CIRCUMSTANCES OF CONFLICT OF INTEREST

 

When determining the types of conflicts of interest, it is assumed that the following situations

always lead to conflicts of interest:

• The Company and / or the Relevant Person could make a financial gain or avoid a

financial loss to the detriment of the Client;

• The Company and / or the Relevant Person has an interest or benefit in the outcome of

the service provided to the Client or a transaction performed on behalf of the Client that

differs from the Client's interest;

• The Company and / or the Relevant Person have a financial or other motive for favoring

the interests of another Client or a group of Clients to the detriment of the Client's

interests;

• the subject of business of the Company or the Relevant Person is the same as the subject

of business of the Client;

• The Company and / or the Relevant Person receives or will receive from a person other

than the Client an additional incentive in connection with the service provided to the Client,

in the form of monetary or non-monetary benefits or services, which is not the usual

commission or fee for that service.

 

PROCEDURES AND MEASURES FOR MANAGEMENT OF CONFLICT OF INTEREST

 

In order to prevent situations that may lead to conflicts of interest, the following procedures and

measures are applied:

• Avoiding conflicts of interest and complying with this Policy. The Company and Relevant

Persons are obliged to avoid situations that may lead to a conflict of interest, and if it already

exists or cannot be avoided, they are obliged to adhere to all measures and procedures provided

for in this Policy.

• Obligation to report conflicts of interest. Each Relevant Person is obliged, for the purpose of

recording and determining further measures and procedures, to report any circumstance that

could lead to a conflict of interest of either the Relevant Person or the Company. The mentioned

circumstances are reported to the Business Compliance Monitoring Officer, if the Company has

one, in the opposite executive director of the Company.

• Special rules related to the Organizational structure of the Company. The Company's

management will take all reasonable measures to prevent or control conflicts of interest. In

situations where the Relevant Person would be involved in various business activities, which

involve a potential conflict of interest, the Company will take all reasonable steps to establish an

adequate system of control of conflicts of interest between employees and management.

 

TRADING FOR OWN ACCOUNT OF THE COMPANY

 

The Company is allowed to acquire and dispose financial instruments for its own account, in

accordance with the provisions of the Law on capital Market and other regulations and in

compliance with the provisions of this Policy. When trading for its own account, the Company

 

may be a participant in the so-called cross transactions, i.e. such transactions in which, directly

or indirectly through third parties, certain organizational units of the Company act as buyers and

sellers of the same financial instruments.

The Company will endeavor to avoid such transactions if it is aware that the Company's Client

would be harmed.

 

OWN ACCOUNT TRADING OF THE RELEVANT PERSON

 

Relevant persons are obliged - from the beginning of taking office twice a year to the

Compliance Officer or the Director of the Company, in the period between 1st and 15th of January

and 1st and 15th of July to make and submit to the Company a signed Statement of financial

instruments at their disposal.

 

TRADING OF RELEVANT PERSONS, PERMISSIBILITY, FREQUENCY

 

Relevant persons are allowed to acquire and dispose of financial instruments for their own

account, but in accordance with all applicable laws and regulations and this Policy and other

applicable internal acts of the Company.

 

When trading for their own account, the Relevant Persons shall comply with the rules on avoiding

frequent trading.

 

CLIENT NOTIFICATION

 

Disclosure to clients is an ultimate measure that is used only if effective organizational and

administrative measures established by the Company to prevent and / or manage its conflicts

of interest are not sufficient to reasonably prevent the risk of harm to clients' interests.

 

FINAL PROVISIONS

 

This Policy applies from the day of issuing the operating license to the Investment Services

Company.

The Company's policy of managing conflicts of interest is constantly reviewed, and measures

are taken at least once a year to eliminate possible shortcomings.

CONFLICT OF INTEREST MANAGEMENT POLICY

RSI GLOBAL PODGORICA

INTRODUCTORY PROVISIONS

 

This Policy regulates measures and procedures for identifying, monitoring and preventing the

negative impact of conflicts of interest that may occur when providing investment and ancillary

services and performing investment activities between

- the interests of the Company, persons running the Company, employees, related agents,

related agents, persons through control on the one hand and the interests of the Company's

Clients on the other hand or

- the interests of the Company's Clients to each other.

If the measures and procedures provided by this Policy will not be sufficient to reasonably

prevent the previously described negative conflict of interest, the Company will apply additional

measures and procedures in such an individual situation, and if that is not enough, the Company

will on the Permanent Media, unambiguously inform the Client about the type and / or source

of the conflict of interest, stating sufficient information on the basis of which the Client will be

able to make decisions related to the investment and / or ancillary services in which the conflict

of interest arises. All Relevant Persons in relation to the Company are obliged to act in

accordance with the provisions of this Policy. Failure to comply with the provisions of this Policy

by the Relevant Persons employed in the Company or third parties to whom certain business

processes have been assigned (delegated) within the group constitutes a serious breach of

employment obligations.

 

CIRCUMSTANCES OF CONFLICT OF INTEREST

 

When determining the types of conflicts of interest, it is assumed that the following situations

always lead to conflicts of interest:

• The Company and / or the Relevant Person could make a financial gain or avoid a

financial loss to the detriment of the Client;

• The Company and / or the Relevant Person has an interest or benefit in the outcome of

the service provided to the Client or a transaction performed on behalf of the Client that

differs from the Client's interest;

• The Company and / or the Relevant Person have a financial or other motive for favoring

the interests of another Client or a group of Clients to the detriment of the Client's

interests;

• the subject of business of the Company or the Relevant Person is the same as the subject

of business of the Client;

• The Company and / or the Relevant Person receives or will receive from a person other

than the Client an additional incentive in connection with the service provided to the Client,

in the form of monetary or non-monetary benefits or services, which is not the usual

commission or fee for that service.

 

PROCEDURES AND MEASURES FOR MANAGEMENT OF CONFLICT OF INTEREST

 

In order to prevent situations that may lead to conflicts of interest, the following procedures and

measures are applied:

• Avoiding conflicts of interest and complying with this Policy. The Company and Relevant

Persons are obliged to avoid situations that may lead to a conflict of interest, and if it already

exists or cannot be avoided, they are obliged to adhere to all measures and procedures provided

for in this Policy.

• Obligation to report conflicts of interest. Each Relevant Person is obliged, for the purpose of

recording and determining further measures and procedures, to report any circumstance that

could lead to a conflict of interest of either the Relevant Person or the Company. The mentioned

circumstances are reported to the Business Compliance Monitoring Officer, if the Company has

one, in the opposite executive director of the Company.

• Special rules related to the Organizational structure of the Company. The Company's

management will take all reasonable measures to prevent or control conflicts of interest. In

situations where the Relevant Person would be involved in various business activities, which

involve a potential conflict of interest, the Company will take all reasonable steps to establish an

adequate system of control of conflicts of interest between employees and management.

 

TRADING FOR OWN ACCOUNT OF THE COMPANY

 

The Company is allowed to acquire and dispose financial instruments for its own account, in

accordance with the provisions of the Law on capital Market and other regulations and in

compliance with the provisions of this Policy. When trading for its own account, the Company

 

may be a participant in the so-called cross transactions, i.e. such transactions in which, directly

or indirectly through third parties, certain organizational units of the Company act as buyers and

sellers of the same financial instruments.

The Company will endeavor to avoid such transactions if it is aware that the Company's Client

would be harmed.

 

OWN ACCOUNT TRADING OF THE RELEVANT PERSON

 

Relevant persons are obliged - from the beginning of taking office twice a year to the

Compliance Officer or the Director of the Company, in the period between 1st and 15th of January

and 1st and 15th of July to make and submit to the Company a signed Statement of financial

instruments at their disposal.

 

TRADING OF RELEVANT PERSONS, PERMISSIBILITY, FREQUENCY

 

Relevant persons are allowed to acquire and dispose of financial instruments for their own

account, but in accordance with all applicable laws and regulations and this Policy and other

applicable internal acts of the Company.

 

When trading for their own account, the Relevant Persons shall comply with the rules on avoiding

frequent trading.

 

CLIENT NOTIFICATION

 

Disclosure to clients is an ultimate measure that is used only if effective organizational and

administrative measures established by the Company to prevent and / or manage its conflicts

of interest are not sufficient to reasonably prevent the risk of harm to clients' interests.

 

FINAL PROVISIONS

 

This Policy applies from the day of issuing the operating license to the Investment Services

Company.

The Company's policy of managing conflicts of interest is constantly reviewed, and measures

are taken at least once a year to eliminate possible shortcomings.

 INTRODUCTORY PROVISIONS

 

This Policy regulates measures and procedures for identifying, monitoring and preventing the

negative impact of conflicts of interest that may occur when providing investment and ancillary

services and performing investment activities between

- the interests of the Company, persons running the Company, employees, related agents,

related agents, persons through control on the one hand and the interests of the Company's

Clients on the other hand or

- the interests of the Company's Clients to each other.

If the measures and procedures provided by this Policy will not be sufficient to reasonably

prevent the previously described negative conflict of interest, the Company will apply additional

measures and procedures in such an individual situation, and if that is not enough, the Company

will on the Permanent Media, unambiguously inform the Client about the type and / or source

of the conflict of interest, stating sufficient information on the basis of which the Client will be

able to make decisions related to the investment and / or ancillary services in which the conflict

of interest arises. All Relevant Persons in relation to the Company are obliged to act in

accordance with the provisions of this Policy. Failure to comply with the provisions of this Policy

by the Relevant Persons employed in the Company or third parties to whom certain business

processes have been assigned (delegated) within the group constitutes a serious breach of

employment obligations.

 

CIRCUMSTANCES OF CONFLICT OF INTEREST

 

When determining the types of conflicts of interest, it is assumed that the following situations

always lead to conflicts of interest:

• The Company and / or the Relevant Person could make a financial gain or avoid a

financial loss to the detriment of the Client;

• The Company and / or the Relevant Person has an interest or benefit in the outcome of

the service provided to the Client or a transaction performed on behalf of the Client that

differs from the Client's interest;

• The Company and / or the Relevant Person have a financial or other motive for favoring

the interests of another Client or a group of Clients to the detriment of the Client's

interests;

• the subject of business of the Company or the Relevant Person is the same as the subject

of business of the Client;

• The Company and / or the Relevant Person receives or will receive from a person other

than the Client an additional incentive in connection with the service provided to the Client,

in the form of monetary or non-monetary benefits or services, which is not the usual

commission or fee for that service.

 

PROCEDURES AND MEASURES FOR MANAGEMENT OF CONFLICT OF INTEREST

 

In order to prevent situations that may lead to conflicts of interest, the following procedures and

measures are applied:

• Avoiding conflicts of interest and complying with this Policy. The Company and Relevant

Persons are obliged to avoid situations that may lead to a conflict of interest, and if it already

exists or cannot be avoided, they are obliged to adhere to all measures and procedures provided

for in this Policy.

• Obligation to report conflicts of interest. Each Relevant Person is obliged, for the purpose of

recording and determining further measures and procedures, to report any circumstance that

could lead to a conflict of interest of either the Relevant Person or the Company. The mentioned

circumstances are reported to the Business Compliance Monitoring Officer, if the Company has

one, in the opposite executive director of the Company.

• Special rules related to the Organizational structure of the Company. The Company's

management will take all reasonable measures to prevent or control conflicts of interest. In

situations where the Relevant Person would be involved in various business activities, which

involve a potential conflict of interest, the Company will take all reasonable steps to establish an

adequate system of control of conflicts of interest between employees and management.

 

TRADING FOR OWN ACCOUNT OF THE COMPANY

 

The Company is allowed to acquire and dispose financial instruments for its own account, in

accordance with the provisions of the Law on capital Market and other regulations and in

compliance with the provisions of this Policy. When trading for its own account, the Company

 

may be a participant in the so-called cross transactions, i.e. such transactions in which, directly

or indirectly through third parties, certain organizational units of the Company act as buyers and

sellers of the same financial instruments.

The Company will endeavor to avoid such transactions if it is aware that the Company's Client

would be harmed.

 

OWN ACCOUNT TRADING OF THE RELEVANT PERSON

 

Relevant persons are obliged - from the beginning of taking office twice a year to the

Compliance Officer or the Director of the Company, in the period between 1st and 15th of January

and 1st and 15th of July to make and submit to the Company a signed Statement of financial

instruments at their disposal.

 

TRADING OF RELEVANT PERSONS, PERMISSIBILITY, FREQUENCY

 

Relevant persons are allowed to acquire and dispose of financial instruments for their own

account, but in accordance with all applicable laws and regulations and this Policy and other

applicable internal acts of the Company.

 

When trading for their own account, the Relevant Persons shall comply with the rules on avoiding

frequent trading.

 

CLIENT NOTIFICATION

 

Disclosure to clients is an ultimate measure that is used only if effective organizational and

administrative measures established by the Company to prevent and / or manage its conflicts

of interest are not sufficient to reasonably prevent the risk of harm to clients' interests.

 

FINAL PROVISIONS

 

This Policy applies from the day of issuing the operating license to the Investment Services

Company.

The Company's policy of managing conflicts of interest is constantly reviewed, and measures

are taken at least once a year to eliminate possible shortcomings.

 INTRODUCTORY PROVISION

 

With this Policy, the Investment Company RSI GLOBAL (hereinafter: The Company) appoints

procedures for the identification, measurement and assessment of risks, as well as risk

management, in accordance with regulations, standards and rules of the profession.

Under risks are considered to be risks in which The Company is exposed in its operating

transactions, which can lead to losses, causing damage to clients or participators in transactions

with the Company.

 

Risk management is a set of actions and methods to determine, measure and monitor risks,

including reporting on risks to which The Company is exposed or could be exposed in its

operations. Main purpose of risk management is to identify, measure, limit and minimize

expected and possible risks for The Company.

 

RISK MANAGEMENT ORGANIZATIONAL STRUCTURE

 

The Company ensures functional and organizational separation of the risk management

activities and regular business activities of the Company.

In risk management, this Policy determines, based on internal structure of the Company, the

organizational structure, with allowances and responsibilities.

 

DETERMINATION OF RISK PREFERENCE

 

The tendency to take risks is a level of risk which the Company considers acceptable to take in

achieving its business strategy and goals in the existing business environment.

The tendency to take risks includes determining the intention to take risks as well as determining

risk tolerance in terms of determining the level of risk that the Company deems acceptable.

 

IDENTIFICATION OF POSSIBLE RISKS

 

The companies conduct the risk identification based on internal and external sources of

information.

Methods of risk identification used by the Company are as follows:

1. a) Environment analysis based on information from the media, regulations etc.,
2. b) Competition analysis,
3. c) Financial market analysis,
4. d) Analysis of own financial indicators,
5. e) Assessment of the financial and business position of the Company, which includes:

- assessment of the balance sheet of the Company,

- assessment of future operating and other income and expenses of the company,

1. f) Analysis of business processes and critical points in business processes,
2. g) List of critical operational points in business processes,
3. h) Analysis of the risk management sector in the placement of products / services /

instrument markets

1. i) Analysis of historical information and experiences,
2. j) Regular colleges of the Management Board,
3. k) Reports of control function,
4. l) Other internal records and reports

 

TYPES OF RISKS AND THEIR MEASUREMENT

 

The Board of Directors is convinced that it is not possible to fully and precisely predict all possible

risks in advance, but the aim of this Policy is to create guidelines for identifying risks and

formalizing them through the Policy. In its operations, the Company is exposed to the following

risks in particular:

• market risks,
• credit risks,
• liquidity risk,
• operational risks,
• risks of exposure to a single person or group of related parties
• other risks

 

1. MARKET RISKS, THEIR MEASUREMENT AND RISK MANAGEMENT

 

Market risks are price change risk, counterparty settlement risk and counterparty risk, risk of

exceeding allowed exposures, currency risk and commodity risk.

 

Price change risk is the risk of loss arising from a change in the price of a financial instrument

or, in the case of derivative financial instrument, from a change in the price of the basis from

which that instrument arises.

Price change risk is divided into:

1) general price risk is the risk of loss arising from a change in the price of a financial

instrument due to changes in interest rates or major changes in the capital market, regardless

of any specific characteristics of that financial instrument,

2) specific risk of price change is the risk of loss arising from the change in the price of a

financial instrument due to fact related to the issuer or in the case of derivative financial

instrument, facts related to the issuer of the underlying financial instrument.

 

Settlement risk and counterparty risk are risks of loss arising from default of the counterparty

based on positions in the trading book.

 

The risk of settlement may arise in the situations of concluding a transaction of purchase of a

financial instrument without coverage on the client’s account. The exposure to settlement risk is

measured as the difference between the contract price for a particular debt, equity or

commodity instrument and its current market value, but only when that difference constitutes a

loss to the Company.

 

The counterparty risk is loss risk that arises from the default of the counterparty based on

positions in the trading book. It is measured for derivative financial instruments, repo

agreements, etc.

 

Currency risk is the risk of loss arising from changes in exchange rates. When the investment is

related to foreign countries, the Company takes into account the fact that changes in the

exchange rate affect the change in property prices as well. Currency risk refers to all financial

instruments that are in a currency other than the domestic currency.

 

Commodity risk is the risk of loss arising from a change in the price of goods. Direct exposure

to commodity risk is small so the Company does not measure this level of risk at the Company

level, but from time to time when assessing the impact of changes in the price of certain financial

instruments whose issuers have this level is significant.

 

2. CREDIT RISK, ITS MEASUREMENT AND RISK MANAGEMENT

 

Credit risk is the risk of loss that occurs due to non-fulfilment of a financial obligation of a person

towards the Company.

Credit risk is reflected in the fact that the issuer of a financial instrument is unable to pay

contractual interest or principal on its debt obligations.

In assessing the credit risk of individual financial instruments, the Company shall use the ratings

of rating agencies if applicable to a specific credit risk rate. If not applicable, the Company will

use its own techniques for assessing the creditworthiness of both financial instruments and

clients, which are primarily internally developed fundamental analysis techniques for assessing

the creditworthiness of both financial instruments and clients, which are primarily internally

developed fundamental analysis techniques.

 

3. LIQUIDITY RISK, ITS MEASUREMENT AND RISK MANAGEMENT

 

Liquidity risk is the risk of the possibility of negative effects on the financial result and capital of

the Company due to the inability of the Company to meet due obligations.

The Company measures liquidity on a daily basis by comparing the balance of its liquid assets

and current liabilities.

 

4. OPERATIONAL RISK, ITS MEASUREMENT AND RISK MANAGEMENT

 

Operational risk is the risk of loss due to errors, interruptions or damage that may occur due to

inadequate internal procedures, actions of persons, systems or external events, including the risk

of changes in the legal framework.

 

5. EXPOSURE RISK, ITS MEASUREMENT AND MANAGEMENT

 

The Company's exposure to one person is the total amount of receivables related to that person

or group of related parties (loans, investments in debt securities, equity investments and

participations, issued guarantees and avails, etc.)

 

 

 

6. OTHER RISKS

 

Risk of competition

The risk of competition is the risk that there will be a decrease in profitability or a loss in the

Company's operations due to the emergence of potential new competitors, the emergence of

substitutes for services and changes in the needs of clients with whom the Company does

business.

Financial crisis and declining demand for service

A financial crisis is a situation in which the value of financial institutions or assets declines rapidly.

 

CAPITAL ADEQUACY

 

The Company maintains the Company's capital to always correspond to the amount of capital

required to cover its liabilities and possible losses due to the risks to which the Company is

exposed in its operations and in order not to harm clients or participants in transactions with the

Company. The Company's capital must be greater than or equal to the sum of capital

requirements for market risks, credit risk and operational risk.

 

INTERNAL CONTROL SYSTEM

 

The Company monitors and evaluates the suitability, comprehensiveness and effectiveness of

adopted risk management strategies, policies and procedures, as well as the adequacy and

effectiveness of the envisaged measures to address possible deficiencies in risk management

strategies, policies and procedures, including failures of relevant persons.

 I BASIC PROVISIONS

 Article 1.

These business rules of the Investment Company RSI GLOBAL Podgorica (hereinafter: The

Business Rules) regulate the mutual rights and obligations between the Investment Company

RSI GLOBAL Podgorica (hereinafter: The Investment Company), on the one hand and the client

of the Investment Company, on the other, related to the provision of investment services and

related ancillary services.

The Business Rules are an integral part of each individual contract that the Investment Company

concludes with the Client related to the provision of Investment Services, such as receiving and

transferring orders related to the sale and purchase of financial instruments, execution of orders

for on behalf of clients, trading for own account, foreign currency business services related to

the provision of investment services as well as other ancillary services in accordance with the

obtained license.

By concluding the contract with the Investment Company, that is filling in the questionnaire,

which is an essential component of the contract, the Client confirms that he has been handed

the Business Rules, Price List, Client Classification Policy, Account Execution Policy, Conflict of

Interest Management Policy, and that he is informed about the investor protection system.

If an individual contract concluded with the Client deviates from the Business Rules, the

provisions of the individual contract apply.

Applicable laws and bylaws with all amendments that will be adopted during the duration of the

business relationship will be applied to everything that is not regulated by the Business Rules

and the individual contract. If laws or by-laws adopted after the entry into force of these Rules

of Business or an individual contract resolve an issue differently, the provisions of the relevant

regulation shall apply, until the Rules of Business of the investment company are amended.

The current Business Rules are available to the Clients at the business premises of the Investment

Company and / or on the official website of the Investment Company.

 

II INFORMATION ABOUT THE INVESTMENT COMPANY

 

Article 2.

Investment company RSI GLOBAL Podgorica, with its headquarters at the address Rimski trg 4,

Building 1, floor V, Podgorica, operates in accordance with the work permit issued by the Capital

Market Authority of Montenegro, under the ordinal number: 03/2-4/1-21 from the date of September 6

, 2021, and 03/2-4/3-21 from the date October 4, 2021.

Investment company RSI GLOBAL Podgorica is in accordance with the work permit authorized to

provide investment services defined in Article 206 paragraph 1 items 1, 2,3, 4, 5, 6 and 7 and

ancillary services defined in Article 206 paragraph 2 items 1, 2, 3, 4, 5, 6 and 7 of the Law on

Capital Market, and the operating license refers to financial instruments defined in Article 3

paragraph 1 of the Law on Capital Market, which include derivative financial instruments and

contracts about the differences.

The investment company is authorized to hold financial instruments and client funds.

Investment company RSI GLOBAL Podgorica provides its services only at the Company's

headquarters and has no registered affiliates.

 

III CUSTOMER INFORMATION

 

Article 3.

In accordance with the regulations governing the operations of investment companies and

regulations governing the prevention of money laundering and terrorist financing, the

Investment Company is obliged to collect the following data and documents from the client

before establishing a business relationship:

1. From natural persons, the Investment Company collects data on name and surname,

residence, personal identity number, name and number of the identification document. In

doing so, he must keep a copy of his identification document and a copy of his utility bill.

2. From legal entities, the Investment Company collects data on the name, registered office,

tax number, persons authorized to represent, transaction account number and beneficial

owners. In the archive must be kept a certified copy of the excerpt from the register not

older than three months, a copy of identification document of the person authorized to

represent and a copy of the bank statement.

3. The investment company is obliged to collect from clients, individuals and legal entities,

data necessary for conducting in-depth analysis in accordance with regulations

governing the prevention of money laundering and terrorist financing, as well as data on

beneficial owners and political exposure of natural or legal owners. For this purpose, the

Investment Company collects data that are mandatory prescribed by the Law and the

Rules of Business of Investment Companies, and the data range differs depending on the

degree of risk of an individual client. The statement on the real owner of the legal entity

is given by the authorized person for representation under material and criminal liability.

4. In order to implement the classification of clients into Small Investors and Professional

Investors, the Investment Company collects the necessary data on individuals and legal

entities through the Questionnaire.

The data referred to in items 3) and 4) of paragraph 1 of this Article shall be collected through

forms or questionnaires for natural and legal persons.

If the Client is represented by an attorney, he is obliged to enclose the original power of attorney

certified by a notary or the competent state authority.

Warning: If the Investment Company is not able to collect all necessary data and documentation

from this Article of the Rules due to the client's fault, before establishing or during the business

relationship, it is not obliged to provide the Investment Service to the client, therefore it is

necessary to terminate the contract.

Information on the knowledge and experience of the client, i.e., the potential client is given in

writing.

The information from the previous paragraph can be given in a standardized form.

Article 4.

An investment company before provide services request from the client or potential client data

on his knowledge and experience in the investment area relevant to the financial instrument or

service, which is offered or requested, in order to assess the extent to which an investment

service or financial instrument appropriate to the client is envisaged.

Information regarding the knowledge and experience of the client referred to in paragraph 1 of

this Article, appropriate to the type of client, type and scope of service, type of transaction,

including complexity and risks, shall include in particular:

• the type of services, transactions and financial instruments with which the client is

familiar,

• the type, quantity and frequency of the client's transactions with financial instruments,

as well as the period in which the transactions were performed,

• the level of education and profession of the existing or potential client.

Notwithstanding the previous paragraph of this article, and in accordance with Article 267 of the

Law, a Company that provides investment services related only to the execution, i.e. receipt and

transfer of client orders without providing additional services, may provide these services to its

clients without obtaining data, provided the following conditions are met:

• services relate to shares involved in trading on a regulated or third country market,

money market instruments, institutions of collective investment in transferable securities

and other simple financial instruments, bonds and other forms of securitized debt, except

bonds and securitized instruments debt containing derivative financial instruments,

• the service is provided at the request of a client or potential client,
• the client or potential client has been clearly informed that, during the provision of a

particular service, the Company has no obligation to assess the suitability of the offered

financial instrument or service,

• The Company fulfils the obligations under Article 301 of the Capital Market Act which

regulate the prevention of conflicts of interest between the Company and its clients.

Article 5.

When investment services are provided to professional investors, the Company may consider

that the client has sufficient knowledge and experience in the field of investing and

understanding the risks associated with the financial instrument or transaction.

The Company has no obligation to provide the following services to a professional investor:

• provides appropriate information to understand the nature and risks of investment

services and the type of financial instruments in order to make an adequate investment

decision. It previously includes trading in derivative / complex financial instruments,

• notifies in writing that the financial instrument or service is not suitable for the client,
• to obtain written consent from the professional client to the Order Execution Policy.

Professional investors are considered to be investors from Article 53, paragraph 1 of the Law on

Capital Market.

Before providing services, the Company will inform the client that based on the available data,

the client is considered a professional investor.

 

IV CLIENT CLASSIFICATION

 

Article 6.

The investment company is obliged to classify the client, based on his knowledge, experience,

financial position and investment goals, as a small investor or professional investor, and to

inform him about the category in which he is classified. Clients who are considered Professional

Investors as well as clients who are considered Qualified Clients are defined in Article 53

paragraph 1 and Article 282 paragraph 2 of the Capital Market Law, and all other clients will be

classified by the Investment Company as small investors. The investment company may, at its

request, provide the Professional Investor with the higher level of protection it provides to small

investors.

In performing all business with a small investor, the Investment Company will apply the rules of

business conduct which provide the client with a higher level of protection and information.

When providing investment and related ancillary services to Qualified Clients, the Investment

Company shall apply the business rules in accordance with the applicable Capital Market Law,

whereby it may classify a Qualified Client, on its own initiative or at its request, as a professional

investor or small investor.

 

V RIGHT TO CLASSIFICATION INTO THE SECOND CATEGORY

 

Article 7.

If a client classified as a small investor wants a change of status in relation to all or only some

products and services, he is obliged to request in writing the treatment of a professional investor,

generally or only for a particular investment service, transaction, type of transaction or product.

Prior to the status change, the investment company will conduct an assessment of knowledge

and experience to determine whether the client meets at least two of the following three

conditions:

• The client has performed over 10 transactions per quarter in the last year,
• The size of the client's portfolio of financial instruments exceeds EUR 500,000,
• The client has at least one year of work experience in the financial sector, in positions that

require knowledge of planned transactions or services.

Prior to granting the status of a Professional Investor, the Client is obliged to confirm in writing

(by a special act) that he accepts the consequences of a different classification.

Before being classified in the second category, the investment company will warn the client in

writing what level of protection and rights provided by the investor protection system may be

lost.

Clients who are considered professional investors and have been granted the status of small

investors by the Investment Company may request a change of category without prior

procedure.

If a client classified as a Professional Investor or a qualified client wants a change of status and

treatment with a higher degree of protection than small investors, he is obliged to send a written

request to the Investment Company requesting a higher level of protection (related to all or only

certain services or products). and proceed to the conclusion of a Small Investor Status

Agreement, in respect of all or only certain products and services or transactions.

 

VI TRADING IN FINANCIAL INSTRUMENTS BY ORDER OF CLIENTS

 

Article 8.

This service includes receiving and forwarding orders for the purchase or sale of financial

instruments in the event that the Investment Company executes the order and receiving and

forwarding orders for execution to another Investment company.

The Small Investor and the Investment Company enter into a Brokerage Services Agreement, of

which the Questionnaire is an integral part, by which the Investment Company undertakes in its

own name, and on behalf of the Client performs the purchase and sale of financial instruments,

in accordance with the given orders. pay brokerage commission and other transaction costs. By

concluding a general agreement on representation in brokerage business, the client is enabled

to trade on the Montenegrin capital market, as well as on foreign markets if the Investment

Company has previously provided the necessary conditions for that.

The Order obliges the investment firm to buy or sell certain financial instruments for the Client

for an agreed fee in accordance with the conditions contained in the Order, and the Client

simultaneously authorizes the Investment Firm to undertake these activities in accordance with

these Investment Company Rules and individual contract.

The order refers to a precisely determined number of Financial Instruments.

 

VII OBLIGATORY ORDER CONTENT

 

Article 9.

One order may require the buy / sale of only one type of financial instrument and at one price

on both the regulated and the MTP, i.e., OTC capital market.

Regardless of the method of issuance, the order must contain the following elements:

1. type of order (buy / sale),
2. order number
3. date and time of issuing the order,
4. name and registered office of the client who is a natural person, telephone number,

identification document, and basic data for the Client who is a legal entity (name of the legal

entity, tax number, registered office, and name and surname of the authorized representative);

5. Account number of the investor in the Central security depository and clearing company of

Montenegro or some other equivalent register or depository (optional depending on which order

is issued for which type of financial instrument)

6. designation of the financial instrument (name, type, class, series, CFI code or ISIN number, or

some other internationally recognized mark),

7. quantity,
8. price
9. deadline by which the order is valid
10. password specified in the agreement.

 

VIII PRICE OF THE FINANCIAL INSTRUMENT IN THE ORDER

 

Article 10.

The price at which the order is to be executed is expressed individually, as the maximum price at

which the client is willing to pay (when buying) or as the minimum price at which the client is

willing to sell the security (when selling), for shares and for bonds as a percentage of their face

value. The price is expressed in the currency according to the place of execution of the order,

which the client marked in the order.

The limited order is displayed on the relevant market at the price stated in the order, while in the

case of a market order the price is not determined but it is executed according to the most

favourable offer on the market at that moment.

Trading with financial contracts on differences, several types of orders can be offered to the

client, as follows:

• Market order: a sales / purchase order in relation to a purchase / sale price,
• Limit order: a sales / purchase order in relation to the purchase / sale price until the price

reaches the appropriate limit. These orders can be for a definite period of time or for an

indefinite period of time / "valid until revoked" /,

• Stop-loss order or Take profit order: a market order in which a position is closed (via a

market order) if the loss on that position reaches a certain level defined by the contract

(stop loss level”) or if the profit reaches a certain level (“take the profit level ”) which is

determined in relation to the price at which the order was given;

• Trailing Stop-loss order: a stop-loss order in which the level at which a position closes

increases if the position becomes more profitable,

• Guaranteed stop order is a loss stop order in which it is guaranteed that the position will

be closed at the order level so that there is no “slippage” (in a regular loss stop order the

position is closed via a market order, but the following the price may be worse than the

level of stopping the loss).

 

IX DURATION OF ORDERS

 

Article 11.

The order lasts from the moment the client issues it via the trading platform, until he closes it via

the trading platform too.

The order ceases to be valid after full realization or after the expiration of the time period for

which it was issued.

The order will be automatically closed if the client has come to a position to lose the invested

funds, in order to not to enter in negative position.

In the case of a Limited Purchase and Sale Order, if the expiration date is not specified, the order

is considered to be revoked. While the market order in the part in which it was not realized on

that day is cancelled immediately, for the part in which it was not realized.

Orders for the purchase and sale of financial instruments in foreign markets can be received

only as daily orders.

When providing the service of execution and / or receipt and transfer of orders on behalf of the

client, the Company will choose the place of execution that enables execution under the most

favourable conditions.

 

X MANNER OF GIVING ORDERS

 

Article 12.

The client can place an order in the following ways:

1. In writing by registered mail or fax,
2. Electronically to the broker of the Investment Company,
3. Orally by telephone,
4. In person at the premises of the Investment Company and
5. Through an internet trading platform.
6. In writing, the Order is given by registered mail or fax. Such Order must be signed by the

Principal and it is necessary, for identification purposes, to contain the password specified

in the Brokerage Agreement.

2. The Client may electronically place Orders only from the e-mail address specified in the

Brokerage Agreement. This e-mail address is considered the personal e-mail address of

the Client and the Investment Company will consider all Orders that come from that

address and which contain the password from the Brokerage Agreement, as Client

Orders.

3. An oral order can be given by telephone directly to the broker in the Investment

Company. All telephone conversations are recorded and the obtained recording of the

telephone conversation can be used exclusively for the purpose of proving the Order. The

investment firm undertakes not to use the recording for any other purpose. The Client

expressly agrees to record telephone conversations with the Investment Company.

4. Personally, in the premises of the Investment Company, where the Client must identify

himself with an identification document (ID card, passport (for individuals) or an excerpt

from the CRPS with the identification document of an authorized representative (for legal

entities))

5. Through an internet trading platform. The Client logs in via the platform using the

username and password, which the Investment Company has assigned to the Client. The

Investment Company will accept all Orders submitted through the platform, by the Client

who is logged on to the platform. The client is responsible for keeping his username and

password.

 

XI RECEIPT AND EXECUTION OF ORDERS

 

Article 13.

The investment company is obliged to confirm to the client that the order was received without

delay, and no later than the next working day after receiving the order.

The investment company reserves the right not to accept the client's order, in the following cases:

1. a) If the order is not given in the manner provided by these Rules of Business of the

Investment Company,

1. b) if the order does not contain the essential elements prescribed by these Rules of Business,
2. c) in case of blocking the trading of a certain financial instrument on the market on which

the order is executed,

1. d) if the preconditions for trading on the market of the country indicated in the order are

not provided, and if the client does not pay the funds necessary for the purchase of

financial instruments,

1. e) If he considers that there is a reasonable suspicion:

• To illicit manipulation of the price of a financial instrument or other illicit action,
• In order for the Investment Company to suffer damage by executing the order,
• That the execution of the order could result in a criminal offence or misdemeanour.

The Investment Company is not authorized to establish a business relationship, and thus not

execute the client's order, if it is unable to collect all data and documentation referred to in Article

2 of these Rules of the Investment Company or additional data and documentation in

accordance with applicable regulations with the client’s contract documentation or was unable

to perform a product or service suitability assessment.

Accepted orders, which are executed on the regulated market or MTP, managed by the

Montenegro Stock Exchange AD Podgorica, or which are executed outside the regulated market

or MTP, are executed by the Investment Company, while orders for purchase or sale of securities

executed on to one of the foreign markets on the regulated market or MTP, ie outside the

regulated market and MTP, and in relation to which the Investment Company has provided

preconditions for trading, the Investment Company forwards to an authorized company abroad,

which has access to the market in abroad, directly or indirectly, in accordance with the order

execution procedure.

XII AMENDMENT AND REVOCATION OF ORDERS

Article 14.

A change in an order is considered to be a change in the requested quantity or price of a financial

instrument in relation to the original order. If the original order has already been executed, the

Investment Company is not able to accept the requested change or revocation of the order.

In case of partial execution of the order, the order can be changed for the remaining number of

securities from the order. Each change of order results in a new order.

The request for modification or revocation of the order is sent to the Investment Company in the

manner provided for the issuance of the order.

 

XIII EXECUTION OF ORDERS

 

Article 15.

Accepted orders, which are executed on the regulated market or MTP, managed by the

Montenegro Stock Exchange AD Podgorica, or which are executed outside the regulated market

or MTP, are executed by the Investment Company, while orders for purchase or sale of securities

executed on to one of the foreign markets on the regulated market or MTP, i.e. outside the

regulated market and MTP, and in relation to which the Investment Company has provided

preconditions for trading, the Investment Company forwards to an authorized company abroad,

which has access to the market in abroad, directly or indirectly, in accordance with the order

execution procedure.

 

XIV FEE FOR EXECUTION OF ORDERS

 

Article 16.

The Investment Company is entitled to charge for the execution of the Order in accordance with

the Price List valid at the time of issuing the Order. The price list is displayed in the premises of

 the Investment Company or on the company’s website. The Investment Company is obliged to

deliver it to the Client at his request. By giving the Order, the Client confirms that he is familiar

with the Price List.

 

XV BOOK OF ORDERS

 

Article 17.

Orders are entered in the order book. The order book is kept in electronic form. The information

contained in the Order Book is a business secret. The data contained in the Order Book may be

disclosed only to judicial and regulatory bodies in accordance with applicable regulations. The

data contained in the Order Book may be disclosed to persons who perform internal or external

audit and control of the Investment Company, perform accounting services, or maintain

software Back Office of the Investment Company and other persons who may access this data

as a result of functions and tasks performed in Investment Company or for the Investment

Company, provided that these persons have been previously warned of the obligation to keep

business secrets of the data contained in the Order Book.

 

XVI ORDER PRIORITY

 

Article 18.

When performing its obligations arising from the Order, the Investment Company is obliged to

adhere to the priorities from the Order Book. The priority of individual Orders is determined in

the order from the Order Book, so that the Order that was previously submitted to the Investment

Company has priority over the Order that is submitted later.

The Investment Company forwards to the Exchange system bids for purchase and / or sale

related to the fulfilment of a specific Order in accordance with the order thus determined. The

order of execution of the Order (concluding transactions with Financial Instruments executing

the Order) depends on market conditions, instructions given to the Investment Company by the

Client in the Order and the strategy used by the Investment Company to fulfil the Order in the

most favourable way for the Client.

 

XVII TRANSFER OF ORDERS FOR EXECUTION TO THIRD PARTIES

 

Article 19.

Orders for purchase and sale of financial instruments on the foreign market, which are not able

to be executed independently, are forwarded by the Investment Company to the foreign

authorized participant - the investment company.

By placing an order for the purchase or sale of financial instruments of foreign issuers, which

are not listed for trading on a regulated market or MTP managed by Montenegro Stock

Exchange AD, the Client expressly authorizes the Investment Company to entrust the execution

of the order to another investment company authorized to conduct business with financial

instruments in accordance with the regulations of the country in which it has its registered office.

In case of entrusting the execution of the Order to another, the Investment Company is obliged

to check that the Deputy has a valid license to perform operations with Financial Instruments,

and when giving instructions to forward to the Deputy the same Order as received from the

Client.

The list of foreign markets in which clients can trade through the Investment Company, as well

as the list of foreign authorized companies, to which the Investment Company transfers the order

for execution, are an integral part of the Order Execution Policy, located on the Investment

Company's business premises or website Investment company.

 

XVIII ORDER PERFORMANCE POLICY

 

Article 20.

When executing an order or forwarding an order to another authorized company, the investment

company shall act in accordance with its own Order Execution Policy. When establishing a

business relationship, the Company will obtain the client's consent to the Order Execution Policy.

Upon each significant change in the elements on the basis of which the most favorable

outcome for the client is determined, the Investment Company will deliver the Order Execution

Policy to active clients.

 

XVIX RIGHTS AND OBLIGATIONS OF THE INVESTMENT COMPANY AND THE CLIENT

REGARDING THE RECEIPT AND EXECUTION OF ORDERS

 

1. Information provided by the Company to clients prior to the conclusion of the contract

Article 21.

The Company is obliged to provide the client or potential client with insight into the Business

Rules and Price List, as well as insight into changes to these acts, in one of the following ways:

1. in business premises where work with clients is performed,
2. by publishing on the Company's website.

Insight into the changes to the Business Rules and the Price List of the Investment Company, the

Company is obliged to provide within 8 days before the beginning of the application of these

changes.

All information provided by the Company to the client or potential client must be:

1. true, clear and easily understood by the average client of the group to which they are

addressed,

2. the potential benefits of the service or financial instrument must not be emphasized without

at the same time impartially warning of the risks associated with them,

3. they must not obscure, diminish or make incomprehensible important details, allegations or

warnings,

4. they must not contain the name of a competent authority in a manner that would indicate

or suggest the approval of the instrument or service of the Company by that authority,

5. information must not be misleading,
6. must be given in an understandable form so that clients can understand the nature and risks

of investment services and the type of financial instrument on which to base their investment

decision.

2. Information on the characteristics and risks of financial instruments

Article 22.

The investment company shall provide clients with detailed information on the characteristics

and risks of financial instruments, appropriate to the categorization of the client as a small or

professional investor, which will enable the client to make an appropriate investment decision.

The risk information referred to in paragraph 1 of this Article shall include in particular:

• risks associated with the type of financial instrument, including clarification of financial

leverage and its effect, as well as the risk of loss of investment,

• price volatility of a financial instrument and possible restrictions on the existing market

for those instruments,

• financial and other additional obligations of the investor in case of transaction with these

financial instruments,

• margin data and other liabilities related to the financial instrument.

When trading financial contracts on differences, the Company will define all risks related to

trading in these financial instruments in the contract with the client and inform the client about

the risks related to:

• leverage
• financing costs.

Article 23.

When there is a possibility for the client's order to be executed outside the regulated market, i.e.,

MTP, the Company is obliged to inform the client about this possibility, before proceeding with

the execution of the order, obtain prior explicit written consent from the client, except in the case

of professional clients. Necessary.

The client's consent may be part of the contract or a separate statement and may be given for

all transactions or for each individual transaction.

Article 24.

• before executing the order, receives written consent from the client on the order

execution policy, if it is not given at the time of signing the contract, whereby for

professional clients’ consent is not required,

• monitors the efficiency of the adopted policies and procedures of order execution, i.e. to

monitor whether the best results are achieved for the client in the execution of the order,

in order to identify and eliminate deficiencies in a timely manner,

• informs its clients about the ways and procedures of order execution,
• notifies its clients of significant changes in the manner of order execution or changes in

order execution procedures,

• to prove at the client's request that he has executed orders in accordance with the

adopted procedures of execution of the order.

The investment company is required to establish and implement a policy for the execution of

client orders, which for each class of financial instrument must contain information on the

different places for execution of client orders and elements that affect the choice of appropriate

place of execution of orders.

3.Information on financial instruments

Article 25.

The investment company is required to provide existing and potential clients with detailed

information on the characteristics and risks of financial instruments, appropriate to the

categorization of the client as a small or professional investor, which will enable the client to

make an appropriate investment decision.

The risk information referred to in paragraph 1 of this Article shall include in particular:

1. risks associated with the type of financial instrument, including clarification of financial

leverage and its effect, as well as the risk of losing the entire investment,

2. the volatility of the price of a financial instrument and any restrictions on existing markets

for those instruments,

3. an explanation that a transaction in such an instrument, in addition to the cost of

acquiring the instrument itself, could include additional financial and other liabilities,

including contingent liabilities,

4. margin data and other liabilities related to the financial instrument,
5. any condition arising from the loan under which the instrument was purchased or similar

obligations applicable to a particular type of instrument.

The Company is obliged to, when providing information on the financial instrument:

 

1. which is the subject of the ongoing public offering and for which the prospectus has been

issued - informs the client and the potential client about the manner in which the

prospectus is available,

2. which includes a third-party guarantee - provides the client and the potential client with

sufficient details about the guarantor and the guarantee on the basis of which he can

make a correct assessment of the guarantee,

3. consisting of two or more different instruments or services and for which it is obvious that

the risk associated with that instrument will outweigh the risks associated with each

individual component of that instrument - provide the client and potential client with an

appropriate description of the individual components of such instrument which

interaction increases the risk.

When trading financial contracts on differences, the Company will define in the contract with the

client all the risks related to trading in these financial instruments and inform the client about:

• leverage effect,
• financing costs,
• spread and
• the types of orders it can give.

In the case referred to in paragraph 4 of this Article, the Company shall indicate to the client that

in case the client holds only part of the funds in a special investment account (margin), the

increase or decrease of the instrument which is the basis for concluding the difference

agreement shall result in a percentage, lower or higher profit compared to direct investment

based on value.

In the case of trading financial difference contracts, the contract with the client agrees on the

minimum margin that the client must have in order to conclude a financial difference contract,

notifying the client that the lower the margin, the greater the potential leverage effect.

The Company will trade financial contracts on differences based on:

• indexes,
• shares,
• goods,
• currencies,
• bonds and
• cryptocurrencies.

An investment company that provides investment services or performs investment activities

referred to in Article 206 of the Law in connection with financial instruments referred to in Article

3, paragraph 1, item 4 of the Law, and uses leverage is obliged to provide protection against

negative balance.

The protection against negative balance referred to in paragraph 5 of this Article shall ensure

that the investment company does not allow the occurrence of a negative balance position on

the client's account and may not claim funds from the client based on a possible negative

balance position.

A negative balance sheet position implies that the client cannot lose more funds than those in

the account opened with the investment company.

Leverage is the use of margin in order to increase the potential return on investment which also

symmetrically increases the potential loss.

Leverage trading means that the client can trade in an amount greater than the funds he has

invested and which serve exclusively as a margin.

The Authority shall prescribe by decision the amount of leverage for trading in financial

instruments.

Article 26.

Investment company:

• executes the client's order without delay and correctly records and allocates it,
• executes the client's order according to the time of acceptance of the order and without

delay, unless this is prevented by the characteristics of the order or market conditions or

if the client's interests require different treatment,

• without delay, informs the small investor about possible difficulties for the orderly

execution of the order.

Article 27.

The Company may accept client orders:

1. directly, in writing at the Company's premises in Podgorica, every working day in the time

interval from 08. 00 - 16. 00h,

2. by mail, telephone, or electronically if agreed with the client.

Notwithstanding paragraph 1, item 1 of this Article, the Company may receive client orders

through the trading platform 5 (five) working days a week 24 hours a day.

The order can be given by telephone or other means of remote communication only if the

following conditions are met:

1. The Company and the client have signed an agreement expressly giving the client

consent to telephone communication and accepting the risks of such communication,

2. The client submits a written statement in which he explicitly states:
3. a) Telephone number by which the communication will be established and the order will

be given, i.e. the executed order and notifications will be sent;

1. b) password to use when placing an order.

In the case referred to in paragraph 3 of this Article, the client undertakes to keep the password

secret and may not disclose it or make it available to third parties.

The company identifies the client, after submitting the statement referred to in paragraph 2, item

2 of this Article exclusively on the basis of the reported password and telephone number. The

Company shall reject any telephone order that has not been forwarded using the telephone

number or password specified in the statement referred to in paragraph 2, item 2 of this Article.

The Company is obliged to inform the client at the beginning of the recorded telephone

conversation about this fact, as well as about the fact that the content of the telephone

conversation can be used in any proceedings against the client and as proof of the order and

the content of the order.

The Company does not take any responsibility for any damage that the client may suffer as a

result of unauthorized use of the password / password by a third party or communication with

the company by phone.

The Company and the client may agree that the client may issue the order by fax, in which case

the client will be allowed to place the order in this way. An order received by fax, if such an order

has been agreed, shall be deemed to have been received on the day and at the time when the

Company received the signed order.

The Company and the Client may agree that the Client may place an order by e-mail using the

Internet Service and the Client. In the event that it is agreed to place an order in this way, the

order is delivered through the client, or the person specified in the contract and from e-mail

addresses predefined by the contract.

The e-mail address from which the order is issued, and the name of the person authorized to

issue the order, is defined by the client by signing a special annex to the contract. The order in

the name and for the account of the Client may be issued by a third party on the basis of the

original and court-certified authorization to dispose of financial instruments.

Article 28.

The order may not be given, sent or transmitted and received by telephone or electronic

communication made with privately owned equipment, which the investment company may not

record or copy.

An order given contrary to paragraph 1 of this Article shall not be considered legally valid.

4.Acceptance of orders

Article 29.

The Company will accept the order for the execution of the transaction of purchase or sale of a

financial instrument, as follows:

• for the purchase, if it determines that the client's cash account has sufficient funds to

settle his obligations that would arise from the execution of the purchase order,

• for sale, if it determines that the client has sufficient securities in the securities account

required to execute the order.

The Company may refuse to execute an order for the purchase or sale of a financial instrument,

if the conditions referred to in paragraph 1 of this Article are not met.

Notwithstanding paragraph 2 of this Article, the investment company shall not refuse to execute

the order if the client's order can be executed in whole or in part:

• from realized but unsettled transactions,
• granting loans with the consent of the client, in accordance with the law,
• by lending securities in accordance with the rules governing the lending of securities.

The Company is obliged to reject any order for the execution of a transaction with a financial

instrument, as follows:

• receiving an order for purchase, i.e., sale if it determines that by executing that order,
• either a criminal offence or a misdemeanour has been committed,
• receipt of a purchase or sale order that must be executed on a particular trading day,
• when the deadline for submitting that order for its execution has expired in accordance

with the rules of the regulated market in which those securities are included in trading,

• execution of the order, if the order does not meet the conditions established by law and

the contract, or if not, all required information required for their execution has been

submitted,

• execution of orders, if there is a suspicion of money laundering and terrorist financing,
• order execution, if the investment company considers that the execution of the order may

lead to manipulation in the regulated market.

Regardless of the reason for refusing the order, the investment company shall notify the client

of the rejection of the order, in the same manner as it received the order, no later than the next

day from the day of receipt of the order, stating the reason for the order rejection.

5.Acknowledgment of receipt of the order

Article 30.

 

The Company is obliged to confirm to the client the receipt, change and withdrawal of the

received order, by submitting a notification on:

• time and place of receipt of the order, change and revocation of the order,
• accepting or refusing to execute the order, stating the reasons for refusing the order,

immediately upon receipt of the order,

The certificate referred to in paragraph 1 of this Article shall be submitted no later than the next

working day from the day of receipt of the order in the manner in which the order was received,

unless otherwise agreed at the client's request with the client.

Article 31.

The investment company will execute the order in accordance with the client's instructions and

its own Order Execution Policy, with the care of a good expert.

By accepting the order for purchase or sale of financial instruments, the investment company

undertakes:

• Buy or sell a financial instrument according to the elements of the order,
• In case of purchase, settle the purchase through CKDD or another equivalent register or

depository,

• Inform the client about the completed transaction (via a bill that can be picked up in

person at the premises of the Investment Company, be sent by e-mail or regular mail)

• In case of sale of financial instruments, make payment of the sale value of financial

instruments less commission costs to the client's account, unless the client wants to use

the funds for further purchase of financial instruments,

• Upon settlement of the sale, i.e. by the client's payment order, make the payment within

one business day from the date the client issued the payment order, unless the payment

relates to the sale of financial instruments abroad in which case the Investment Company

will make the payment within one business day. days from the date of receipt of money

from a foreign custodian bank.

The Client undertakes to the Investment Company:

• Before issuing a purchase order, pay the purchase value from the order increased by the

amount of commissions and fees in accordance with the Price List, and clients operating

through a custody bank are required to submit data on a custody account with detailed

instructions for settling financial instruments;

• Prior to issuing a sale order, provide a sufficient amount of financial instruments to settle

to the investment company's depository account,

• Pay the brokerage commission and all transaction costs such as the cost of the trading

venue, custody bank, as well as other possible trading costs in the relevant foreign

market, all in accordance with the order to buy or sell financial instruments, according to

the valid Investment Company Price List. Third party price lists,

• Reimburse the Investment Company for any amount paid to the client in the name of

taxes.

The investment company, related to the receipt and transfer of orders for execution, in relation

to clients whose assets it holds in a collective custody account with an authorized custodian

bank, has the following obligations:

• To inform the client on request about the terms of the contract with the custodian

authorized bank,

• Keeps all kept financial instruments or funds in a special client account separately from

its assets,

• Informs the client about corporate activities related to the financial instruments it holds

for the client,

• Receive dividends and other receipts from corporate activities of issuers on behalf and

for the account of the client and calculate and pay capital gains taxes in Montenegro on

behalf and for the account of the client.

A client who trades in financial instruments for safekeeping with the Investment Company

agrees, which is consent by concluding a contract on brokerage services and issuing an

individual order for purchase or sale of financial instruments, with the transfer of his assets to

third parties where the Investment Company keeps clients' assets abroad.

 

XX PAYOUTS AND PAYMENTS OF CASH FOR PURCHASE OR SALE OF FINANCIAL

INSTRUMENTS

 

Article 32.

For the purchase of financial instruments on the Montenegro Stock Exchange or abroad, the

currency to be paid is EUR, where, if necessary, the Investment Company, in accordance with

the client's request, will convert funds into another currency if required by trading conditions in

a particular market.

The Investment Company will disburse funds from the sale of financial instruments to the client's

transaction (Payment Transactions Act), i.e., at the client's request in foreign currency to the

foreign currency account. All costs of transferring funds to the client's foreign accounts are

borne by the client.

For the purchase of financial instruments on the trading platform, the payment currency is USD.

Payment of funds will be made to the transaction account with the bank, i.e. to the account with

the payment institution or to the payment card. Prior to payment, the client is required to provide

proof of ownership of the account or card. The exception is the situation when the funds arrived

from the account to which the payment is requested during the deposit.

The investment company does not pay the client interest on the funds it holds for its account.

 

XXI PORTFOLIO MANAGEMENT OF FINANCIAL INSTRUMENTS

Article 33.

The rights and obligations of the client and the investment company related to the management

of the portfolio of financial instruments are regulated in detail by the Portfolio Management

Agreement, which is standardized. For everything that is not defined by such an agreement,

these Rules of Business of the Investment Company apply, which are delivered to the client

before the conclusion of the Portfolio Management Agreement.

 

XXII INVESTMENT CONSULTING

 

Article 34.

The investment advisory service implies giving personal recommendations to the client, at his

request or at the initiative of the Investment Company, in respect of one or more transactions

with financial instruments.

A personal recommendation is a recommendation to take one of the following activities:

• Purchase, sale, subscription, exchange, repurchase, holding or undertaking to subscribe

for a particular financial instrument,

• Execution or non-execution of rights arising from a particular financial instrument.

Prior to the investment consultation, it is necessary to conduct an adequacy assessment in

accordance with Article 45 of these Rules.

After the payment of the fee is determined by the valid Price List of services, investment

consulting is performed, and the client is given a copy of the minutes which contains a personal

recommendation.

Investment consulting is performed in personal contact with an authorized investment advisor

in the business premises of the Investment Company or at the request of the client elsewhere.

Exceptionally, at the client's request, it is possible to provide investment advice by telephone if

the client's investment profile and its classification have been previously prepared. In the case of

investment consulting by telephone, the minutes will be delivered to the client by regular mail or

e-mail.

Based on the personal recommendation, the client makes the investment decision himself, and

is warned of the risks referred to in Article 42 of these Rules, as well as the possibility that the

Investment Company, employees or persons related to the Investment Company may own

financial instruments subject to personal recommendation. Investments made and distributed

by the Investment Company are not considered investment advice.

XXIII AUXILIARY SERVICES

 

Article 35.

The investment company will provide ancillary services to the Clients in an organized manner

after the fulfilment of the necessary organizational and technical conditions. The Client agrees

that the Investment Company may request the conclusion of an Agreement for the provision of

ancillary services. The Company will inform the Clients about the availability of ancillary services

through the website of the Investment Company, and other ways of communication of the

Investment Company with the Client. The Company may from time to time, through the

prescribed methods of communication, submit to the Clients investment research and financial

analysis prepared in accordance with the applicable regulations and rules of the profession.

When preparing investment research and financial analyses, the Company may rely on

information, analysis, studies and other documentation submitted to it by the analyzed entities,

and may consider them, without additional verification, accurate, true and complete. It can also

rely on publicly available information from recognized financial data sources that is not always

required to be verified. The Company emphasizes that the content of investment research and

financial analysis to be provided to Clients does not constitute explicit or tacit investment advice

or personal recommendation of any kind and nature to Client and / or third parties in terms of

any actual and / or proposed transaction, product or investment objectives. Investment research

and financial analysis do not take into account economic, financial and / or investment

circumstances related to the Client, especially in terms of his economic position, and his financial

condition and indicators, as well as investment objectives. The Company emphasizes that the

Client assumes full responsibility in connection with all decisions and transactions in its Financial

Instruments Accounts and emphasizes that the Company is not responsible for any decision on

investment and disposal of assets made by the Client. The Company is not responsible for the

accuracy or delay of investment research and financial analysis due to the occurrence of force

majeure, or IT, organizational, communication and similar problems. The Company has no

obligation to notify of changes in its opinion, information, forecasts, and projections arising from

new circumstances. The Company especially emphasizes that the Client consciously and

independently assumes all risks regarding investments in financial instruments, and that the

Investment Company is in no case liable to the Client for any damage caused by any risk related

to the purchase, sale, holding and / or safekeeping of the financial instrument. , with which the

Client was adequately acquainted, i.e. delivery of investment research, as well as other ancillary

services to enable him to conclude a transaction with one or more financial instruments, as well

as all other risks related to the provision of investment and ancillary services.

 

XXIV HOLDING AND PROTECTION OF CLIENTS 'CASH AND FINANCIAL INSTRUMENTS

 

Article 36.

The right of ownership of clients is protected within the Law on Capital Market, which implies the

separation of clients' assets from the assets of the Investment Company. For this purpose, the

Investment Company, in addition to regular accounts with commercial banks, also has special

purpose accounts which, in accordance with legal provisions, do not enter the Investment

Company's assets, bankruptcy or liquidation estate or be subject to enforcement claims against

the Investment Company. Special purpose accounts are used exclusively for the payment and

disbursement of clients' funds for the purpose of buying or selling financial instruments on the

client's order.

If investment company is a member of the Central security depository and clearing company of

Montenegro CDCC, the investment company is obliged to pay returns to the guarantee fund

given the risk of non-settlement of the transaction traded on the Montenegro Stock Exchange.

 Secrecy label,,Public''

Money from the sale of financial instruments and / or financial instruments can be used to

execute new orders, unless the client requests the payment of money, lowering the shares to a

vacant position in the CDCC or lowering the shares from the collective custody account.

The Investment Company will keep the funds paid by the client for the purchase of financial

instruments as well as the funds from the sale of financial instruments separately from its own

funds, on dedicated accounts with commercial banks in Montenegro, taking into account bank

ratings and risk dispersion. Clients are informed, when it comes to trading abroad, that the

Investment Company holds funds and financial instruments held with authorized custodian

banks abroad, collectively, i.e., in collective custody accounts (review of risks associated with

holding assets in collective custody accounts is prescribed Article 31 of these Rules).

When choosing a third party on whose accounts the financial instruments or clients' funds are

deposited, the rating, expertise and market reputation of the third party are taken into account,

as well as the legally prescribed conditions and market practices related to holding financial

instruments and funds. The investment company does not take responsibility for loss or damage

caused by failure or insolvency of a third party or their third parties but is responsible to the

client only for the choice of a third party, i.e., that the selection acted professionally and with due

care in accordance with bylaws.

 

XXV PLEDGE RIGHTS

Article 37.

The investment company has the right to block financial instruments owned by the client

according to the provisions of the ZOO as well as the right to out-of-court settlement of their

value and the right to collect from funds in a special client account under the following conditions:

• if the client has due and outstanding liabilities to the Investment Company arising from

any contract concluded in accordance with these Rules of Business of the Investment

Company.

The Investment Company shall notify the Client in advance of its intention to collect by blocking

financial instruments, withholding money or of the intention to offset the cash balance and

receivables for the amount of the Client's debt to the Investment Company.

In relation to the service of trading financial instruments abroad, when the Investment Company

holds the same in a collective custody account opened in the name of the Investment Company,

the custodian bank has the right to debit assets (financial instruments, funds) on the account in

case of outstanding, and due obligations arising from the contract on opening a custody

account.

 

XXVI REPORTING TO SMALL INVESTORS

 

Article 38.

Before providing investment services, i.e., before concluding a contract, the Company is obliged

to provide small investors and potential small investors with information on:

• The Company and the services provided by the Company,
• financial instruments with a general overview of the nature and risks characteristic of

them,

• protection of financial instruments,
• costs and associated expenses.

The Company is obliged to inform the client and the potential client about any significant change

in the information.

Information is provided through the Company's website in accordance with legal requirements

or other durable media in a standardized form.

All settlements, documents and reports are delivered to the client via a permanent medium to

the address of residence / e-mail or electronic email address via the Internet if all conditions

provided by the Investment Company Rulebook are met, which emphasizes the client's consent

to such data delivery.

The language of communication is Montenegrin. The Company may communicate with clients -

foreign legal or natural persons in English or another foreign language provided by the contract,

provided that the contract, orders and other necessary documentation exchanged with the

Company by the client are compiled bilingually.

Communication between the Company and the client is performed in a manner that is agreed

with the client, and which is most convenient for the client, in accordance with the Law on Capital

Market and the conditions prescribed by law. If the Client chooses to communicate with the

Company by telephone, application, e-mail, or other forms of distance communication, the

Company has the right to:

1) records telephone conversations or electronic communication of transactions concluded

by trading for its own account, as well as receiving, transmitting and executing client

orders, regardless of whether the transaction is concluded,

2) provides recording of telephone conversations and electronic communication with

equipment provided for use to the employee or contractor or whose use by the employee

or contractor is permitted by the investment company.

By familiarizing with these rules, the client is informed, before providing investment and ancillary

services, that telephone communication or conversations between the investment company and

its clients will be recorded.

 

XXVII BUSINESS CALCULATION

 

Article 39.

The investment company shall without delay provide the client with information related to the

execution of the order. The Investment Company shall deliver the order execution certificate to

the client no later than the first working day after the order execution, i.e., the first working day

after receiving the order execution from a third party, with the following information:

• identification code of the Investment Company, client code, trading day and time code, trading type code, trading place code, trading instrument code, financial instrument, issuer, quantity, unit price and total price, purchase or sale code, and cost specification items.

For clients who trade via the Internet, all data on executed orders are available in electronic form

within the applications for online trading and are sent on monthly basis.

 

XXVIII PORTFOLIO MANAGEMENT REPORT

 

Article 40.

For clients who have concluded a Portfolio Management Agreement with the Investment

Company, the Management Report is submitted every 6 (in words: six) months, as of 30.6. and

31.12. If the client wishes to receive the Reports every 3 (in words: three) months, he is obliged to

send a written request to the address of the seat of the Investment Company. The portfolio

management report contains:

1. a) Name of the investment company, account code of the small investor,
2. b) a report on the content and valuation (assessment) of the portfolio including details of

each financial instrument held for the client, market value or fair value of the portfolio at

the time of reporting, cash balance at the beginning and end of the reporting period, and

portfolio return during the reporting period,

1. c) review of transactions performed within the reporting period,
2. d) the total amount of fees charged to the client incurred in the reporting period, which are

management fees and costs related to the execution of transactions,

1. e) comparison of portfolio returns during the reporting period with the agreed reference

value,

1. f) the total amount of dividends and other payments received on behalf of the client during

the reporting period, arising from the ownership of securities, and information on other

corporate shares that give rights in relation to financial instruments.

The investment company performs valuation of assets in the portfolio in relation to the closing

or last price achieved on the market on the day of portfolio calculation or the last available

trading date before the date of portfolio calculation, within the report, while internally, for

investment decision purposes, portfolio assets are valued. executes as needed and more often.

If the Investment Company realizes a loss in portfolio management that exceeds the percentage

determined by the Portfolio Management Agreement, without delay, by phone or e-mail, it will

notify the client of the loss by the end of the business day in which the threshold is exceeded.

The settlement currency, regardless of the market in which the client's assets are invested, is

always EUR.

 

XXIX FEES AND ASSOCIATED COSTS

 

Article 41.

 

The investment company will charge the client fees and other costs according to the valid Price

List. For trading in all types of financial instruments, the commission of the Investment Company

is calculated, as well as the costs of the trading venue, the costs of the CDCC, as well as the

possible costs of keeping securities. Clients whose transactions are settled through custody

accounts are charged additional fees determined by the Price List. There may be other costs for

trading on foreign markets, such as the cost of returning money to Montenegro, ie. foreign bank

commission and domestic bank commission.

All costs are calculated for each individual transaction, unless otherwise specified for each

service in the Price List. In case of withdrawal of the order, no commission is charged. The

portfolio management service includes the collection of management fees, trading fees, success

fees, and fees for early termination of the Agreement (described in more detail in the Price List).

If a client incurs a cost, caused by the specifics of an individual market, which is not provided for

in the Price List, the Investment Company will calculate it separately and deliver such calculation

to the client. In addition to the above costs, there is a possibility that the client may incur other

costs associated with transactions such as. taxes on dividends from abroad, or costs of

corporate activities, whereby the Investment Company will calculate the client's tax costs as well

as all related fees.

In the case of trading in financial contracts on differences, the Company makes a profit from

the movement of instrument prices, financing costs and commissions. Inactive accounts (no

open positions or no transactions) may be subject to a penalty payment in which case the

Company is authorized to debit a certain amount, determined by the price list, from the client's

account in case of quarterly inactivity.

For access to certain markets abroad, an obligation to pay special or additional costs may be

agreed with the client.

 

XXX RISKS RELATED TO TRADING IN FINANCIAL INSTRUMENTS AND PROPERTIES OF

FINANCIAL INSTRUMENTS

 

Article 42.

Investing in financial instruments, and given their characteristics, is associated with the following

risks:

1. a) Business risk arises from the uncertainty of whether the issuer of the security will

maintain its competitive position in the market in the future, as well as business stability

and continuity of growth. Higher business risk may have a negative impact on the price

of securities of the issuer in question.

1. b) Financial risk is a consequence of the structure of financial sources of the issuer of

securities. When analyzing the stated risk, it is necessary to analyze the financial

indicators of the issuer of securities. Higher financial risk can have a negative impact on

the price of securities.

1. c) Systemic risk is the risk inherent in the entire capital market, market segment, industry,

etc., in other words, the price of a particular security can fluctuate significantly even if

financial indicators such as profit, dividends, interest payments, competitive the position

or other financial indicators of the issuer of securities have not changed (eg due to

changes in interest rates, recession, adverse weather conditions and natural disasters,

investor behavior in the market, etc.).

1. d) The risk of changes in exchange rates occurs when investing in securities denominated

in foreign currency, and their yield is also exposed to the risk of changes in the EUR

exchange rate against the currency in which part of the investment will be expressed.

Changes in the value of foreign currencies can have a significant impact on the total yield

of a security denominated in domestic currency.

1. e) Interest rate risk is the risk arising from the uncertainty of the future price of money

(future interest rates). It is characteristic of debt securities (fixed income securities). The

price of a financial instrument with a fixed yield is the opposite of the interest rate. If

market interest rates rise, the price of fixed-yield bonds falls, and conversely, if interest

rates fall, the price of fixed-yield bonds rises.

1. f) Credit risk implies the risk that the issuer of bonds will not be able to fully or partially

settle its obligations at the time of their maturity or that it will not be able to refinance

due obligations (refinancing risk). Non-fulfilment of obligations has an impact on the yield

of debt securities (e.g. bonds, commercial paper, etc.) of that issuer, but can also have a

significant impact on the yield of other securities of the issuer in question (e.g. on the yield

of shares).

1. g) Liquidity / marketability risk is the risk that a security will not be able to be sold at a

certain point in time or that it will not be able to be sold without a significant discount.

1. h) Inflation risk is the risk of a fall in the value of securities caused by a general rise in prices.
2. i) The risk of revocation or early repayment is the risk inherent in bonds. Consequences

occur when the issuer has the option to revoke the bond before its maturity under

conditions that are unfavorable for the investor at that time, or when the issuer has the

option of early repayment of the debt.

1. j) Economic risk implies the impact of cyclical and seasonal trends in the economy or

individual sector on the profitability of investments in certain industries. Securities of

cyclical activities such as e.g., construction will feel more the impact of cyclical

movements of the economy on its value, while on securities less cyclical activities such as

e.g. the food industry cyclical economic trends will not have such a big impact.

1. k) Political or country risk may have a significant impact on the yield of securities. Such risks

include e.g. the risk of changes in legal regulations, negative developments in

international relations or within the state, the risk of outbreaks of interstate or intrastate

conflicts, etc. For countries in transition where elements of modern market economy are

not present, political factors can have a significant impact on the yield of securities.

1. l) The risk of changes in tax regulations is the likelihood that the legislature will change tax

regulations in a way that would adversely affect the return on investment in securities

affected by changes in such tax regulations.

1. m) Social risk includes the possibility of changing the mood of consumers towards certain

companies or entire activities, which can arise in various ways (for example, as a result

of the movement for ecology and concern about environmental pollution). Such a social

climate can lead to the closure of a number of companies or entire activities that have

not adapted to new trends and to the opening of new ones.

1. n) Event risk includes the possibility of sudden events (natural disasters, takeovers and

restructurings, regulatory changes, etc.) that may have a significant impact on the

issuer's ability to meet its obligations (repayment of interest and principal). Business risk,

financial risk, systemic risk, economic risk and social risk are risks that are characteristic

of stock trading. Cancellation or early repayment risk, interest rate risk, credit risk and

event risk are risks specific to bonds, while exchange rate risk, liquidity / marketability

risk, political risks, regulatory risk are common risks associated with investing in stocks

and bonds.

 

XXXI RISKS RELATED TO HOLDING FINANCIAL INSTRUMENTS / CASH IN COLLECTIVE

CUSTODY ACCOUNTS

Article 43.

Clients' funds and financial instruments, which trade on foreign markets, are deposited in

collective custody accounts with custody banks, which are opened in the name of the Investment

Company, and for the account of the clients. The analysis of assets per individual client is

conducted by the Investment Company, through its own records. The investment company,

through checks that are performed automatically, through business information systems, and

double checks by various organizational units, reduces the potential risk of errors in record

keeping, which can negatively affect the assets and rights of clients.

Keeping assets in collective custody accounts can lead to the following risks:

• Impossibility to identify the ultimate owners of financial assets with the depositary - in

case of any loss there may be a problem of identification of the ultimate owners of assets

in the aggregate accounts. However, in most countries there are clear and simple legal

solutions to such problems.

• Asset protection - non-separation of assets at the level of the central depository poses a

risk that the chain intermediary, a member of the central depository or another

intermediary, is considered the ultimate owner of the securities. Failure to identify on the

custody side can lead to a situation where the ultimate owner of the securities is

threatened with foreclosure if one or more intermediaries in the chain become insolvent.

• Forced lending of assets - as a factor beyond the influence of the Investment Company,

and due to routine and unconscious action of a foreign third party where a temporary

imbalance occurs, the consequence of the shortfall may be forced lending of one client's

financial instrument to any other client. property.

• Transparency - aggregate accounts at the central depository level, together with

inappropriate identification of the ultimate owners of securities may prevent regulatory

authorities, tax authorities, issuers, and any other entity with the right to collect

information on securities positions and movements at the central depository level, to

identify the actual owners of the securities.

• Corporate activities - due to the possible existence of a large number of custody and subcustody accounts, there may be a delay between the issuer of securities and the client, ie

the inability to participate in corporate activities within the deadline.

• Corporate activities - dividend in shares or fragmentation - in case of several owners of

financial assets on a collective custody account when distributing dividends in shares or

fragmentation for certain corporate shares, there may be a problem of rounding the

number of allotted shares for individual clients in the correct ratio. property.

• Corporate activities - conflicting interests and different voting - in the case where a

custodian bank keeps securities in a collective account with a third party for several

clients, some may want to vote "for" on a particular issue, while others want to vote

"against". In theory, there may be a risk that the relevant legal system of a particular

country does not allow one investor to vote against.

• Tax processes - the structure of aggregate accounts, without the category of investors

or without the category of activities, can bring significant shortcomings in the processing

of taxes on the part of tax authorities, agents, central depositories and intermediaries. In

the form of transaction tax, for those central depositories that have a role in assessing

and collecting capital gains tax on transactions, the structure of aggregate accounts at

the central depository level may make it impossible to distinguish between taxable and

exempt transactions. Such a structure can led to problems at the level of the central

depository if the central depository, issuer or custodian bank is responsible for the

process of tax calculation and tax collection.

• Other risks - if the relevant legal system does not recognize the collective custody

account as a valid legal form of account, in the event that a third party is unable to

separate the Investment Company's assets or custody from the client's assets there may

be a risk that the client does not have ownership rights. . These risks of keeping assets in

pooled accounts may be to a greater extent in cases where the legal or regulatory

system has not developed a clear idea of pooled custody accounts.

By concluding any contract with the investment company, as well as placing orders for the

purchase or sale of financial instruments, the Client confirms that he is fully aware of the above

risks and the fact that the Investment Company is not liable for damage caused by any risk.

 

XXXII LIMITATION OF LIABILITY OF THE INVESTMENT COMPANY

Article 44.

When providing services to clients, the investment company will act with the care of a good

expert, in accordance with the rules of the profession and the prevailing business practice. In

fulfilling its obligations, the Investment Company shall be liable to the client only for actual

property damage resulting from intent or gross negligence on the part of the employees of the

Investment Company, according to the principle of proven guilt. The investment company is not

liable to the client for any damage caused by, for example, not exclusively:

• factors beyond the control of the Investment Company such as losses caused by force

majeure, natural disasters, wars, market rules, government decisions, downturns of stock

market communication systems or other circumstances beyond the control of the

Investment Company,

• own technical and organizational limitations such as congestion of telephone lines or

systems in general, inability to use any of the communication channels,

• • non-fulfilment of obligations of the Investment Company due to omission for which the

other contracting party, issuer or institution whose services the Company uses is

responsible (e.g., unavailability of SWIFT),

• failure to operate a depository of financial instruments, stock exchanges, banks whose

services the Investment Company uses, including custody of banks, as well as failure,

failure or failure in the system of any third party whose services the Investment Company

uses to fulfil obligations under the contract with the client.

• The investment company is not liable for damages if it fails to warn the client of the

harmful consequences of the execution of the order. Legal inability to fulfil an obligation

will be considered force majeure.

• The investment company is not liable to the client for the damage that occurs if it does

not receive timely notification from the client about the change of the company name,

address / headquarters, telephone number or e-mail address.

 

XXXIII ADEQUACY AND SUITABILITY OF THE INVESTMENT COMPANY'S PRODUCTS OR

SERVICES IN RELATION TO THE CLIENT

Article 45.

ASSESSMENT OF ADEQUACY

The investment company is obliged to collect from the client, a small investor, data on his

knowledge and experience necessary to understand the risks associated with the service

provided (type of services, transactions and financial instruments with which the client is familiar,

nature, volume and frequency of transactions and period in which they were performed, and the

profession and occupation of the client) in order to determine whether a particular product or

investment service is suitable for the client and warn him of their possible unsuitability, where the

Investment Company may, upon explicit request, provide the client with the requested service

without regardless of any inappropriateness. Without the required information, the Investment

Company is unable to determine whether a particular product or investment service is

appropriate for the client. It is understood that qualified clients have the necessary knowledge

and experience to invest in the capital market, and in relation to the same Investment Company

will not conduct a suitability assessment. The investment company shall not conduct an eligibility

assessment for the purchase or sale of shares listed on a regulated market or in a similar third

country market, the purchase or sale of money market instruments and all other simple financial

instruments, and the service is provided at the client's initiative. legal obligations related to the

regulation of areas of conflict of interest. In relation to trading in certificates as structured

securities, an assessment of suitability will be conducted.

 

ASSESSMENT OF SUITABILITY

Adequacy assessment involves the entire process of collecting data and information about a

client, before or during the provision of a financial instrument portfolio management or

investment advisory service.

All data or information collected by the Investment Company about the client before or during

the provision of the aforementioned services are used exclusively in the best interest of the client,

i.e., with the aim for the Investment Company to determine whether the strategy within the

standardized portfolio management service is appropriate for the client. the company could

recommend to the client suitable products or services within the investment advisory service.

Also, the importance of collecting accurate and complete data is emphasized, because only in

that way can the Investment Company adequately assess the suitability and act in the best

interest of the client.

On the other hand, the collection of data and information about the client as part of the

assessment of suitability (for example, data on the client's knowledge and experience in the field

of investment, data on financial situation, client's investment goals) is a legal obligation of the

Investment Company. are collected through the Adequacy Assessment Questionnaire

(hereinafter: The Questionnaire). Without this information, the Investment Company is not

authorized to provide the client with a portfolio management service or investment advisory

service, nor in the case when, based on the assessment of suitability, the Investment Company

determines that the requested service or product is not suitable for the client. The investment

company will consider the data presented by the client through the Questionnaire to be true,

unless it is clear from the questionnaire itself or by comparison with the data collected later that

the data is inaccurate or contradictory. The investment company will periodically, in

conversation with clients or by sending a new form of the Questionnaire, determine whether the

data stated in the Questionnaire are still relevant in relation to general data, data on investment

objectives and financial situation, and in case of data change, which is an integral part of the

Questionnaire, i.e. to archive a new Questionnaire. If the client does not submit the requested

data during the audit of the data from the questionnaire, the Company will consider that they

have not been changed or that the data at its disposal are up to date, unless the circumstances

clearly indicate that the client does not want to submit data (eg the client refuses) that is, the

client submits data that are obviously inaccurate or largely contradictory to the data on the

client that the Investment Company has at its disposal from before, in which case the client's

actions may be a reason for termination of the contractual relationship.

 

XXXIV CONTACT ADDRESS AND ACCOUNT NUMBERS OF THE INVESTMENT COMPANY

 

Article 46.

All reports, calculations and other notifications related to the work performed for the client, the

Investment Company will deliver to the address of residence / seat of the client or to the email

address of the client, which was previously verified by the contract. The working hours of the

Company are every day, from Monday to Friday, from 08:00 to 16;00 h, except for public holidays

and other non-working days in accordance with the publicly published calendar of non-working

days of the Montenegro Stock Exchange. The Client may establish contacts with the Investment

Company at the registered office address: RSI GLOBAL Podgorica, Rimski trg 4, building 1, floor V, 81000 Podgorica, Montenegro e-mail: [email protected]; Sales Department E-mail: [email protected].

The Investment Company shall notify clients of changes in the information specified in this

chapter via the Investment Company 's website, and through a notice displayed at the

Investment Company 's business premises. The Client is obliged to inform the Investment

Company about the change of address and other contact information, and especially about the

change of bank account numbers for the payment of funds. If the client fails to notify the

Company, it will be considered that the Investment Company has duly fulfilled its obligation by

using the existing contact details of the client to send the notification.

The investment company has dedicated accounts, to which clients can deposit funds at:

• Hipotekarna bank AD Podgorica

 

XXXV STORAGE AND PROCESSING OF PERSONAL DATA

 

Article 47.

The investment company will collect and further process the client's personal data only for the

purposes of the contract concluded with the client. By concluding any contract with the

Investment Company, i.e. placing an individual order, the client gives explicit consent to the

Investment Company to take all actions related to the processing and exchange of his personal

data, facts and circumstances that the Company learns and obtains in performing its obligations.

Of the Investment Company for the collection, storage, recording, organization, insight and

transfer of personal data for the purpose of performing regular activities of the Investment

Company. A client who wants to invest in foreign markets by concluding a contract agrees to

the disclosure of his personal data outside Montenegro, if the same is necessary to achieve the

purpose of the contract.

 

XXXVI POLICY OF PREVENTION OF CONFLICTS OF INTEREST

 

Article 48.

Potential conflict of interest means any situation in which the Investment Company or a relevant

person is able to use their professional or official position or authority for their personal benefit

or for the benefit of the Investment Company, and at the expense (burden) of the client, but also

any other situation is marked as a conflict of interest or prohibited action in the regulations

governing the capital market. The basic principles applied by the Investment Company in order

to prevent conflicts of interest are the principle of active prevention of conflicts of interest and

the principle of transparency.

The Investment Company shall apply the Internal Rulebook on Prevention of Conflicts of Interest,

which prescribes measures to prevent conflicts of interest, and if conflicts of interest cannot be

avoided, the Investment Company shall inform clients of circumstances that affect or may affect

their independence and objectivity, and always before doing the business on behalf of the client.

Relevant persons are, in conducting transactions, obliged to place the interests of clients and the

integrity of the capital market above their personal interest. When purchasing a certain security

/ financial instrument for its own account, the employee of the Investment Company may not

give himself priority in relation to another client or in relation to the account of the portfolio

managed by the Investment Company. If there is a conflict of interest between the clients to

whom the Investment Company provides the service of receiving and executing orders, the

Investment Company will execute the previously received order first. If there is a conflict of

interest related to the execution of several identical orders, namely the orders of clients whose

portfolios the Investment Company manages and clients to whom it provides the service of

receiving and executing orders, the Investment Company will give priority to the order with

earlier time of receipt. trading, if it was adopted earlier.

The time of receipt of the order is visible from the order book kept by the Investment Company.

The internal rulebook on the prevention of conflicts of interest is available to clients for inspection

at the business premises of the Investment Company or on the website of the Investment

Company.

The Investment Company has taken all necessary steps to identify conflicts of interest and has

adopted a rulebook on the prevention of conflicts of interest which regulates the circumstances

that represent or may lead to conflicts of interest to the detriment of the Client and the

procedures and measures taken by the Investment Company for the interests of the Client.

Circumstances that represent or may lead to a conflict of interest for the Company are as

follows:

• The investment company and / or relevant persons could make a financial gain or avoid

a loss to the detriment of the Client,

• The investment company and / or relevant persons have an interest or benefit in the

outcome of work performed for the client or transactions performed for the account of

the Client, which differs from the interest of the Client,

• The investment company and / or relevant persons have a financial or other motive for

favoring the interests of another Client or a group of Clients to the detriment of the

Client's interests.

• The subject of business of the Investment Company or relevant person is the same as

the subject of business of the Client,

• The investment company and / or relevant persons receive or will receive from a person

other than the Client additional incentives based on work performed for the Client in the

form of money, goods, services or the like, which is not the usual commission or fee for

that work.

The relevant person within the meaning of this Article is the director or manager, employee, tied

agent or majority shareholder of the Investment Company.

 

XXXVII METHOD OF COMMUNICATION

 

Article 49.

The Company may also provide information to clients electronically, if the following conditions

are met:

• the client has submitted a valid e-mail address to the Company,
• the client has chosen such a method of information delivery,
• the client is electronically informed about the website address and the place where he

can access the relevant data,

• The Company regularly updates information,
• Information is available at all times.

The Client may place orders directly, by fax, telephone and electronically, if provided for in the

contract with the Client.

In case the client performs all communication with the company electronically, it is necessary to

submit a statement that he accepts a defined email address as a means of communication with

the company and an exclusive way of submitting documentation that he considers legally valid

and waives objections to this method of delivery. such service shall be deemed to be personal

service in a legally valid manner in the event of a dispute.

 

XXXVIII CLIENT COMPLAINTS

 

Article 50.

Complaints due to possible improper work performed by the employees of the Investment

Company are submitted on a standardized Complaint Form which is available on the website of

the Investment Company in electronic form on email: [email protected] or in the business

premises of the Investment Company in physical form.

The complainant is obliged to state his name and address. Anonymous complaints will not be

considered. The investment company shall keep a Register of Complaints in electronic form and

shall inform the complainant of the manner of resolving the complaint.

 

XXXIX FINAL REGULATIONS

 

Article 51.

The valid Rules on the operations of the investment company are available in the business

premises of the Investment company or on the website of the Investment company, and the

client is obliged to be informed about them before placing an order. By giving an order for the

purchase or sale of financial instruments, the client confirms s that he has read and that he

agrees with the Business Rules of the Investment Company.

 

These general Business Rules of the investment company will be applied after obtaining the

consent of the Capital Market Authority of Montenegro.

 

Chairman of the Board of Directors

_______________________________

GENERAL PROVISIONS

The policy of execution of orders of the Investment Company RSI GLOBAL Podgorica (hereinafter:

the Policy) defines the procedures and measures that RSI GLOBAL (hereinafter: the Company)

applies when executing or receiving and transferring client orders for purchase and sale of

financial instruments in order to achieve the most favourable outcome for the client.

The Policy defines in more detail the elements that the Company takes into account when

executing, i.e. receiving and transferring orders to another authorized company, places where

orders are executed and factors influencing the choice of individual places of order execution,

and joining and allocating client orders. Clients are warned that the Policy does not guarantee

that the most favourable outcome will be achieved during the execution of each individual order,

but defines the criteria according to which in the most possible cases the most favourable

outcome per client should be achieved. The Company is obliged to obtain the client's consent to

this Policy before receiving the order, and therefore clients are advised to determine whether it

is acceptable to them.

 

POLICY APPLICATION

 

This Policy applies to all clients of the Company except to qualified principals, as defined by the

Capital Market Act.

 

ACHIEVING THE BEST OUTCOME

 

When executing the order, the Company will take all reasonable steps to achieve the most

favourable outcome for the client, taking into account the following elements relevant to the

execution of the order:

• the price of the financial instrument,
• costs, speed, probability of order execution,
• costs, speed, probability of settlement,
• the size and type of the order and all other circumstances relevant to the execution of

the order.

The following criteria are also taken into account when executing a client's order:

• characteristics of the client, including his classification as a small or professional

investor,

• client account properties,
• the characteristics of the financial instrument to which the order relates,
• the properties of the trading venue where the order can be executed.

From the aspect of order execution, we will take all necessary steps to get the best possible

result when executing client orders. We believe that the best possible result is the one that

provides the best possible total price for customers (including costs) in the shortest possible time.

 

EXECUTION OF TASKS OF SMALL INVESTORS

 

The most favourable outcome in relation to the execution of small investor orders is determined

in relation to the total transaction costs, which includes the price of the financial instrument,

trading venue commission, settlement cost and other costs that may arise related to the

transaction, such as third party fees. Other criteria such as speed and probability of realization,

speed and probability of settlement, size and type of order, the Investment Company will take

into account, but are of less importance than the total cost of the transaction.

 

PERFORMANCE OF PROFESSIONAL INVESTOR TASKS

 

For potential investors, the most favorable outcome is conditioned by the size of the order, and

the speed and probability of realization and settlement, while other elements are of less

importance.

 

EXPLICIT CLIENT INSTRUCTION

 

If the Company follows the explicit instruction of the client, it will be considered that it has fulfilled

the obligation to achieve the most favorable outcome. An order placed through an Internet

trading application shall be deemed to have been given with explicit instructions from the client

regarding the manner and place of execution.

 

PLACE AND MANNER OF EXECUTION OF ORDERS

 

The places of execution of the Company's orders are the entities to which the orders are

delivered for execution. For the purposes of executing orders submitted by the client to the

company, the Company acts as the main party to the CFD contract on behalf of the client at all

times. Therefore, the Company is the only place to execute client orders.

The Client confirms and is aware that the orders sent to the Company are not taken over or

executed on a regulated market or multilateral trading system (MTP), but are executed directly

(“OTC”) through the trading platform available to the Company and, accordingly, the client may

be exposed. higher risks. The Company may not be able to execute the order or will change the

price of opening / closing the order in case of a technical malfunction of the trading platform.

 

EXECUTION OF ORDERS OUTSIDE THE REGULATED MARKET OR MTP

 

The Company may execute the order outside the regulated market or MTP with the prior consent

of the client, whereby the client's order may be executed by merging the client's order with

another client's order, the Company's order or a third party order.

Under certain market conditions, especially during, but not limited to, market-related

announcements, weekends, out-of-hours trading, market turmoil, low liquidity and rapid market

movements, the price at which orders are executed may differ from that specified by the client

and there may be a delay.

 

TYPES OF ORDERS

 

The company accepts the following types of orders with regard to the method of determining

the price:

• Limited order – an order to buy or sell a certain number of financial instruments at the price

specified in the order or at a price that is more favourable for the client. If the limited order

is executed only partially, in the part where the order is not executed, it remains exposed on

the market until revoked.

• Market orders (purchase and sale) - orders that are placed on the stock exchange system

after fulfilling the conditions (reaching the last market price on the order). Note: The market

order is executed at the first sale price in case of purchase, or at the first purchase price in

case of sale. The duration of each order is determined by the rules of the trading venue, with

the Company retaining the possibility to prescribe shorter deadlines in the general Business

Rules or the contract. Orders placed through the Internet trading application are accepted

only as limited orders, while orders placed through the Internet trading system in certain

foreign markets can also be received as market orders. Warning: The prices displayed in the

online trading application in foreign markets are not real-time prices, but prices with a time

delay (usually 15 minutes). Orders for trading on foreign markets, with the exception of the

markets of Slovenia and Serbia, are accepted only as daily orders.

In the case of trading financial contracts on differences, several types of orders can be offered

to the client, as follows:

- market order: sales order in relation to the purchase / sale price

- limit order: a sales / purchase order in relation to the purchase / sale price until the price

reaches the appropriate limit. These orders can be for a definite period of time or for an indefinite

period of time / ’’valid until revoked ’’/;

- stop loss order or take profit order: a market order in which a position is closed (via a market

order) if the loss on that position reaches a certain level defined by the contract (stop loss level”)

or if the profit reaches a certain level (“take profit level”) which is determined in relation to the

price at which the order was given;

- Trailing Stop-loss order: a stop-loss order in which the level at which a position closes increases

if the position becomes more profitable; and

- Guaranteed stop order is a loss stop order in which it is guaranteed that the position will be

closed at the order level so that there is no “slip” (in a regular loss stop order the position is

closed via a market order, but the following the price may be worse than the level of stopping

the loss).

 

PRICES AND FORM OF FORMATION

 

The company displays a two-way price for each CFD it offers. This two-way price consists of the

bid price and the demand price. The difference between the bid price and the demand price for

each CFD offered is called the “spread”. The Company's objective is to offer competitive supply

and demand prices, including margin service costs.

The Company's margin may vary depending on market conditions and available liquidity.

Margins represent the best supply and demand prices that can be obtained from our liquidity

providers, underlying asset markets or other data providers.

 

SPREAD AND COMMISSION

 

Spread is the client's cost for opening a new position or setting up a new trading order. It is visible

on the trading platform at any time for a particular CFD.

The commission is calculated as a fixed amount for each open position and is visible immediately

after the order is issued. No commission is charged for certain price groups, as well as for certain

financial instruments offered on the trading platform.

 

SWAP

 

In addition to the fees defined by the Agreement, the Client is obliged to pay a daily roller fee

for an open position held overnight. The method of calculating the overnight fee varies

depending on the type of fixed asset or financial instrument to which the CFD applies. Also, the

amount of the overnight fee is different for different instruments depending on the interest rate

associated with a particular instrument or currency and the additional fee we determine.

 

JOINING AND ALLOCATION OF ACCOUNTS

 

Orders for purchase or sale of financial instruments of the same issuer with the same conditions

(price, type of order) may be jointly presented by the Company as one order, if such exposure

in terms of quantity does not reduce the possibility of executing orders. If the orders are exhibited

together at the same price, and the quantity of financial instruments is not sufficient for the

execution of all orders, the order of the client received earlier is executed first.

 

POLICY ASSESSMENT AND CHANGE

 

Once a year, the Company will evaluate the effectiveness of its own order execution policy,

assessing whether the places of order execution included in this Policy ensure the achievement

of the most favorable outcome for the client. If the Company determines that there is a need

to change the essential elements of this Policy, it will inform the clients about the new policy and

request consent.

 

METHOD OF ACCEPTANCE OF POLICY

 

Before providing financial instruments trading services, the Company is obliged to obtain the

consent of its clients to apply this Policy. Consent is given in one of the ways that ensures a

permanent record, ie: 1. in writing, 2. by telephone, with the implementation of undisputed

identification.

This Policy applies from the date of issuing the approval to the Investment Services Company.

 INTRODUCTORY PROVISIONS

Investment Company RSI GLOBAL Podgorica with its registered office at Rimski trg 4, building no.1, floor V, Podgorica (hereinafter: the “Company”), is an authorized investment company authorized by the Capital Market Authority to provide investment and ancillary services and to perform investment activities in accordance with the Capital Market Act (hereinafter: the “Act”).

Information in the Company and the services provided by the Company can be found in the document General Rules of Business of the Investment Company RSI GLOBAL Podgorica, which are available to Clients at the Company’s business premises and / or on the Company’s official website (www.rsiglobalinvest.com). In accordance with the Law on Capital Market, the Company prescribes measures and procedures for classifying clients in accordance with the provisions of the Law and the Rules on Business Operations of Investment Firms.

 

CLASSIFICATION

 

The Company classifies its clients based on their knowledge, experience, financial situation and investment goals. In accordance with the above, the Company classifies into small and professional investors and qualified clients.

The Company classifies on the basis of data obtained from the client, which are collected through the Questionnaire signed by the client (the client signs one copy, which remains with the Company, and at the client's request, the Company will provide the client with a copy of the Questionnaire).

The Company may consider the information obtained from the client to be credible, except when it is aware or should be aware that the information is clearly outdated, inaccurate or incomplete. The Client is obliged to inform the Company about the change of relevant data.

By signing the Questionnaire on classification into a small or professional investor, i.e. a qualified client, the client confirms that he agrees with the performed classification and that the Company has informed him of this Policy. Within the organizational structure of the Company, the collection of data from clients and the classification of clients is performed by the Compliance.

In addition to the above, the collection of data and classification of clients may be performed by the Board of Directors of the Company or the Officer for monitoring compliance with regulations.

 

 

 

 

PROFESSIONAL INVESTORS

 

In accordance with the Law, a Professional Investor is considered to be a client who has sufficient experience, knowledge and expertise to independently make investment decisions and properly assess the associated risks. Entities that are considered professional investors in the provision of all investment services and all ancillary services in relation to all financial instruments are:

• entities that are subject to the obligation of approval and / or supervision of the competent regulatory authority to operate in the financial market:

1. credit institutions,
2. b) investment companies,
3. c) other financial institutions that are licensed or subject to supervision,
4. d) insurance companies,
5. e) collective investment undertaking and their management companies,
6. f) pension funds and their management companies,
7. g) traders in goods and commodity derivatives,
8. h) other institutional investors.

• A large company that meets two of the following conditions:

1. a) has an annual net income of at least EUR 20,000,000,
2. b) has an annual net income of at least EUR 40,000,000,
3. c) has a capital of at least EUR 2,000,000.

• government, central bank, international organizations such as World Bank, International Monetary Fund, European Central Bank, European Investment Bank and other similar international organizations,
• other investors whose predominant activity is investing in financial instruments, including entities engaged in asset securitization or other financial transactions.

In addition to the clients from the previous paragraph, the Company may classify other clients as professional investors, if the criteria and procedures prescribed by this paragraph are met:

• The Company may treat clients as professional investors, solely on their request and if the Company assesses that the client, depending on the type of transaction or service, has sufficient knowledge, experience and expertise to be able to make its own investment decisions and understand the risk involved, whereas for such a client the Company cannot assume that he possesses professional knowledge

 

and experience, identical to the knowledge and experience of the client from the previous paragraph of this article.

• The assessment from the previous indent of this paragraph should meet at least two of the following criteria:

➢ the client has performed an average of 10 transactions of significant value on the relevant capital market, within each quarter individually, in the last year (the relevant market is the market where financial instruments are traded for which the client wants to obtain the status of a professional investor),

➢ the size of the client's portfolio of financial instruments exceeds EUR 500,000 (The portfolio of financial instruments includes both cash and financial instruments,

➢ The Client works or has worked in the financial sector for at least a year at jobs which require knowledge on planned transactions and services.

Clients referred to in the previous paragraph of this Article may waive a higher degree of protection arising from the rules of business conduct only if they follow the following procedure:

• requesting in written form the treatment of professional investor, in general or in relation to a specific investment services, type of transaction or product,
• a written confirmation, in a separate document separated from the contract, that the Company has warned them in writing which level of protection and rights provided by the investor protection system may be lost and that they are aware of the consequences of losing that level of protection.

Prior to the decision to accept the request for waiver of a higher level of protection arising from the General Rules of Business of the Investment Company, the Company shall take all reasonable steps to determine whether the client meets the requirements of the previous two paragraphs.

Professional investor is obliged to inform the Company about any changes that could affect its status. The Company is obliged to take appropriate measures regarding the change of the client’s status if it learns that the client no longer meets the requirements prescribed for professional investors.

 

SMALL INVESTORS

 

All clients who do not meet the requirements set out in Article 3, paragraph 1 of this Client Classification Policy, are considered small investors.

Small investors are also clients classified by the Company as small investors in accordance with the provision of this Policy on a higher degree of protection (former professional investors and qualified clients).

 

 

Before providing investment services for the first time, the Company is obliged to enter into a written contract with a small investor on a permanent medium, which regulates their mutual rights and obligations. The rights and obligations from the mentioned contract may be a part of other legal acts of the investment company. The provisions of this paragraph do not apply to the provision of investment advisory services. When concluding the contract, the Company will acquaint small investors with the term of the contract, general Rules of Business of the Investment Company and services provided by the Company, risks related to financial instruments, reporting obligations by the Company, rules of the Company regarding conflict-ofinterest management.

 

ASSESSMENT OF ADEQUACY

When providing investment advisory or portfolio management services, the Company is obliged, taking into account the nature and scope of the service, to collect data on the client’s investment objectives, its financial situation and knowledge and experience in the field of investment.

Data on clients' investment goals include data on the time horizon of the investment duration, willingness to take risks, the client's risk profile and the purpose of the investment.

Information on the client’s financial situation, where appropriate, includes information on the source and amount of regular income, and its assets, including information on liquid assets, investments, real estate and regular financial liabilities.

 

ASSESSMENT OF SUITABILITY

 

When providing investment services other than investment advisory or portfolio management services, the Investment Company is obliged to make an assessment of the suitability of the investment service for the client.

The assessment referred to in paragraph 1 of this Article is performed by the Company on the basis of collected data on the client's knowledge and experience necessary for understanding the risks associated with the service provided to him.

 

QUALIFIED CUSTOMERS

 

In terms of the Law, Qualified Clients are:

• Investment companies,
• Credit institutions,
• Insurance companies,
• Management companies for management of open-end investment funds with a public offering and open-end investment funds with a public offering,
• pension fund management companies and pension funds,
• other financial institutions that are subject to the obligation to apply for a work permit or whose operations are regulated by the regulations of the state of Montenegro,
• other financial institutions that are subject to the obligation to apply for a work permit or whose operations are regulated by EU or Member State regulations,
• entities referred to in Article 282 of the Capital Market Act (i.e., persons whose core business consists of trading for own account with commodities and / or derivatives on commodities, unless they are included in a group whose core business is the provision of other investment services in accordance with the Act or banking services in accordance with the law),
• national government and state institutions for management of public debt and central banks,
• supranational organizations.

 

HIGHER LEVEL OF CLIENT PROTECTION

 

The Client has the right to be classified in another client category in accordance with the provisions of this Policy. At the client's request, the Company will:

• classify a qualified client as a professional or small investor, or
• classify a client who is considered a professional investor in accordance with the provisions of the Law, as a small investor, which provides such a client with a higher degree of protection, as described in Article 4 of this Policy.

It is the obligation of a client who is considered a professional investor to request a higher level of protection if he considers that he cannot properly assess or manage the risks involved. In cases when a client who is considered a professional investor, in accordance with this Policy with the Company enters into a contract under which he will not be treated as a professional investor, the Company is obliged to provide a higher level of protection, and such a contract should also be in writing in Article 4, paragraph 4 of this Policy) and it is necessary to indicate in such a contract whether it refers to one or more services or transactions, or to one or more types of products or transactions.

 

 

 

 

 

FINAL REGULATIONS

 

The Law on Capital Market, the Rules on Organizational Requirements and Rules of Business Conduct for the Performance of Investment Services and Activities ("Official Gazette of Montenegro", No. 083/18 and 023/19), and the General Business Rules of Investment Company and other internal acts of the Company.

This Policy applies from the date of issuing the approval to the Investment Services Company.

In accordance with the Law on Capital Market, we classify you as a Small Investor. In accordance

with that, we will execute your orders accordingly with applicable laws and regulations. Upon

your special written request which you can send to the e-mail address: [email protected]

and in accordance with the Law on Capital Market, we will provide you with treatment with a

lower level of protection that we provide to professional investors, as a lump sum or for each

transaction separately.

Small investors can be classified as Professional Investors if they meet at least two of the

following criteria:

1. a) If the Client has realized at least 10 transactions in each quarter in the last year,
2. b) If the size of the Client's portfolio of Financial Instruments exceeds EUR 500,000.00,
3. c) If the Client is employed in the financial sector or has worked in the financial sector for at

least one year in jobs that require knowledge of the capital market.

 

Classification of a client as a professional investor implies different regulations when executing

orders under the most favorable conditions.

For professional clients, the decisive factor in the execution of the Order is the relative

importance of the criteria according to which the order will be executed (not only the price and

transaction fees as for Small Investors, but also the speed, probability of order execution and

transaction settlement).

Your classification (Small Investor) provides you with the highest level of protection under the

Capital Market Act.

 

Classifying the client as a small investor

 

Statement of consent

 

1. Classifying the client as a small investor

 I agree with the classification as a Small Investor.

I / we are explicitly warned that in case of explicit instructions of the Client, Investment

Company "RSI GLOBAL" AD Podgorica will execute the order in accordance with my instructions

and that it is not obliged to execute the order under the most favorable conditions in

accordance with its own measures and order execution policies.

 

2. Consent with the policy of execution of orders of the investment company " RSI GLOBAL " AD

Podgorica

 I agree with the policy of execution of orders of the investment company " RSI GLOBAL " AD

Podgorica stated on the company web site.

 

3. Limited orders

 If the Client's limited order for a certain regulated market cannot be executed immediately

on the relevant market, and considering the conditions from the order, the investment

company " RSI GLOBAL " has no obligation to expose the Client's limited order outside the

regulated market or MTP.

 

4. Execution of orders outside the regulated market or Multilateral Trading Platform

 I agree that the investment company RSI GLOBAL can execute orders outside the regulated

market and the Multilateral Trading Platform.

 

I agree with points 1-4.

 

Place, ________________________                                             Date ________________________

 

 

Client's signature

________________________

Investment company RSI GLOBAL Podgorica requested from the Client or potential Client information on: his education, profession, income, savings and knowledge and experience in the investment area

that is relevant to the financial instruments or services offered. The assessment of the investment

objectives of the existing or potential Client must include the period during which the Client

intends to retain the investment, willingness to take risks, risk profile and purpose of the

investment.

The investment firm has collected sufficient information about the Client to assess whether the

transaction to be recommended or concluded during the provision of the service:

 

 1) meets the investment objectives of the client,

 2) is adequate to the financial capacity to bear all associated investment risks in accordance

with its investment objectives,

 3) is appropriate to the client's ability to understand the risks associated with the transaction.

 

Based on the overall assessment, the client is provided with the following statement:

The transactions that the client plans to carry out are appropriate to his knowledge, experience,

financial condition in the investment area that is relevant to the financial instruments or services

offered or requested by the client.

CFD trading is highly speculative, involves a significant risk of loss and is not suitable for all

investors, but only for one client who:

• understand and are willing to take economic, legal and other risks,
• are experienced and familiar with trading in derivatives and basic types of assets and
• are financially capable of incurring losses significantly greater than the margin or deposit

because investors may lose the total value of the contract, not just the margin or deposit.

 

CFDs are complex instruments and come with a high risk of losing money due to leverage. A

high level of leverage can work against you as well as for you.

There is a possibility that you transfer the loss of some or all of the initial investment, so you

should not invest money that you cannot lose.

You need to be fresh about all the risks associated with trading on the margins and seek the

advice of an independent financial advisor if you have any doubts.

 

The Client accepts that commissions, fees and other fees may apply, and as such these fees will

affect / reduce profits (if any) or increase losses. Before trading financial instruments, you

should be aware of all the costs you can pay, regardless of whether those fees are a

predetermined amount or variable.

 

Risks associated with long positions of CFD, ie. for CFD buyers

 

CFD’s long position means it buys CFDs in the market speculating that the market price of the

underlying asset will rise between the time of purchase and sale. As the owner of a long position

you will make a profit if the market price of the underlying asset increases while the CFD long

position is open.

 

Risks associated with short CFD positions (short), ie. For CFD sellers

 

A short position in a CFD means that it sells CFDs in the market speculating that the market price

of the underlying asset will fall between the time of purchase and sale. As the owner of a short

position, you will make a profit if the market price of the underlying asset decreases while the

CFD short position is open.

 

Leverage

 

Leverage trading applies only to derivative financial instruments, in this case contracts of

difference (CFDs) and means that the Client can trade with the values of the underlying assets

contained in the derivatives that are significantly higher than the funds actually invested by the

Client, which serves exclusively as a margin. High leverage can significantly increase potential

earnings, but it can also significantly increase potential losses. Leverage is defined as the ratio

of the burden on the Client's assets and the total value of the underlying assets contained in the

derivatives or CFD (for clients who are citizens of Montenegro 1:100, but a client who is not a

citizen of Montenegro may be granted a higher leverage).

 

Margin requirements

 

The client must always maintain a minimum margin in their open positions. The client is

responsible for monitoring the condition of the computer.

 

Spread

 

The difference between the price and the search price is "Spread".

 

Settlement in cash

 

The investor understands that the CFD can only be settled in cash, and the difference between

the purchase and sale prices partly determines the result of the investment.

 

Conflict of interest

 

RSI GLOBAL is the other party to all transactions, concluded in accordance with the Agreement

on the provision of investment services to clients and, therefore, the interests of RSI GLOBAL

may be in conflict with yours. Our Conflict of Interest Management Policy is available at

www.rsiglobalinvest.com .

 

OTC transactions

 

When trading CFDs with us, such transactions will not be executed on a recognized or designated

exchange and known as OTC transactions.

 

Currency risk

 

Investing in CFDs with a underlying asset at a value other than your base value involves currency

risk due to the fact that, when a CFD is settled at a value other than your base value, the value

of your return may affect the conversion to the base value.

 

There is no guarantee of profit

 

There are no guarantees of profit or avoidance of losses when trading CFDs. The client did not

receive such guarantees from any representative of the representative office. The client is a

global risk associated with trading CFDs and is financially able to reduce risks and bear all

incurred losses.

 

Internet trading

 

There are risks associated with using an online trading system to enforce contracts that include,

but are not limited to, downtime of hardware, software, and Internet connections. The result of

a system failure may be that your request is not executed in accordance with the instructions or

that it is not executed at all.

Since RSI GLOBAL does not control the signal strength, its reception or routing via the Internet,

the configuration of your equipment or the reliability of its connection, we cannot be held

responsible for communication failures or delays in trading via the Internet.

 

Market opinions

 

All opinions, news, research, analyzes, prices or other information published on this website are

provided as general market comments and do not constitute investment advice.

RSI GLOBAL will not accept liability for any loss or damage, including without limitation, loss of

 

profit, which may arise directly or indirectly from the use or reliance on such information.

 

I DECLARE THAT I HAVE READ, UNDERSTAND AND ACCEPT THE RISK STATEMENT.

 Investment company RSI GLOBAL provides detailed information to existing and potential clients

on the characteristics and risks of financial instruments, appropriate to categorization of the

client as a small or professional investor, which will enable the client to bring appropriate

investment decision.

Risk information in particular includes:

 

1) risks connected to types of financial instrument, including clarification of financial

leverage and its effect, as well as risk of investment loss,

2) the volatility of the price of a financial instrument and possible restrictions on the existing

market for those instruments,

3) financial and other additional obligations of the investor in case of transaction with these

financial instruments,

4) margin data and other liabilities related to the financial instrument.

 

1. Types of financial instruments

 

In accordance with the Law on Capital Market, financial instruments are:

1) transferable securities,

2) money market instruments,

3) investment units, in terms of the law governing the establishment and operation of investment

funds and investment fund management companies,

4) derivatives, i.e. commodity derivatives, which include:

1. a) options, futures, swaps, interest rate forwards and other derivative financial instruments

which are related to securities, currencies, interest rates or interest yields, greenhouse gas

emission units, as well as other derivative financial instruments, financial indices or

financial units that can be settled in cash or in exchange,

1. b) options, futures, swaps, interest rate forwards and other derivative financial instruments

relating to commodities that are obligatorily settled in cash or may be settled in cash at

the request of one of the counterparties, for reasons not related to default or contract

termination,

1. c) options, futures, swaps and other derivative financial contracts relating to commodities

that can be physically settled, provided that those commodities are traded on a regulated

 

market and / or MTP and / or OTP, other than wholesale energy products traded on OTP

which must be settled by exchange,

1. d) options, futures, swaps, forwards and other derivative financial instruments that relate to

commodities and can be physically settled, in a manner not provided for in subparagraph

(c) of this item, which are not held for trading and have the characteristics of derivative

financial instruments,

1. e) derivative financial instruments for credit risk transfer,
2. f) financial contracts on differences,
3. g) options, futures, swaps, interest rate forwards and other derivative financial instruments

related to climate change, transportation costs, greenhouse gas emission units or

inflation rates or other official economic statistics that must be settled in cash at the

request of a from counterparties for reasons not related to non-performance or

termination of contracts, as well as other derivative financial contracts related to assets,

rights, liabilities, indices and other units of measure that have the characteristics of other

derivative financial instruments traded on a regulated market , MTP or OTP and

1. h) greenhouse gas emission units.

 

2. Handling financial instruments and entrusting businesses

 

An investment firm is obliged to regularly review financial instruments it offers or sells, taking in

consideration risks of targeted market, and in particular the adaptation of the financial

instrument of the target market as well as suitability of the strategy for its distribution.

 

3. Book of trading and book of non-trading positions

 

The book of trading contains positions in financial instruments held by an investment company

for the purpose of trading or to hedge positions in other financial instruments that held in that

book and for which there are no restrictions on trading them, nor there are restrictions to

hedge those positions.

The book of non-trading positions contains all positions of financial instruments and

commodities which are not covered by the book of trading.

 

4. Dealing with the client's financial instruments

 

In order to advantageously execute the order when there are several places of order execution

with a financial instrument, it estimates and compares expenses of its provision and expenses of

order execution at each of those places of execution.

 

5. Recording and reporting on data which are related to transactions performed by

electronic access to the trading venue

 

 

An investment company is obliged to record data referring to transactions with financial

instruments carried out by that company, for its account or clients account, with electronic asset

to the trading venue.

 

6. Financial instruments risks

 

Financial instruments transactions, including the purchase and sale of financial instruments

carry its own certain risks. By concluding the Order / or the Broker agreement contract, the

Client confirms that he is aware of risks associated with the capita market, that the company

has made available to him the data and information he has requested and that he has

satisfactorily answered in regard to the market circumstances and financial instruments to which

the order refers to.

In its operations, the company is exposed to the following risks in particular:

• market risks,
• credit risks,
• liquidity risks,
• operational risks,
• risks of exposure to one person or group of related persons and
• other risks.

1) Market risks are risk of price change, risk of settlement of obligations and risk of the other

counterparty, risk of exceeding allowed exposures, currency risk.

2) Credit risk is the risk of loss that arises due to non-fulfilment of a financial obligation of a

person towards the company. Credit risk is reflected in the fact that the issuer of a financial

instrument is unable to pay contractual interest or principal on its debt obligations. During the

assessing of the credit risk of certain financial instruments, the Company will use the ratings of

 

rating agencies if applicable to a specific credit risk assessment. If not applicable, the company

will use its own techniques for assessing the creditworthiness of both financial instruments as

well as clients, which are primarily internally developed fundamental analyze techniques.

3) Liquidity risk is the risk of possibility of negative effect on financial result and capital of the

Company due to inability of the Company to meet due obligations.

The Company measures liquidity by comparing the balance of its liquid assets and current

liabilities on a daily bases.

The investment company is obliged to calculate the amount of liquid capital in cash, risks,

exposure and qualifying holdings on a daily bases.

4) Operational risk is risk of loss due to errors, interruptions or damages that can occur due to

inadequate internal procedures, actions of persons, system or external events including the risk

of changes of the legal framework.

5) The Company’s exposure to one person is the total amount of receivables related to that

person or group of related parties (loans, investments in debt securities, participation and

investments in equity, issued guaranties, etc.).

6) Other risks are risk of competition and financial crises and reduction of demand for services.

 

Risk warning

Trading with financial instruments carries a high level to your capital because prices can move

very quickly in the opposite direction. You should consider whether you have a good

understanding of the nature of financial contracts for differences (CFDs) and whether you can

take high risk of losing money. You can lose all funds, but not more than you have on your

trading account. These products may not be suitable for all clients, so make sure you understand

the risks and look for independent advice.

 

7. Contract for differences (CFD)

 

A CFD is a complex financial instrument that carries a high amount of risk and it is not suitable

for investors who do not have appropriate level of financial knowledge and experience. A CFD is

a derivative financial instrument and is a bilateral agreement between two parties that contains

and depends on the underlying assets contained in the derivative. When the Client places and

order for the purchase or sale of a CFD, it trades exclusively with the Company as another

counterparty, unless we forward the order for sale to a third party.

 

When the Client trades in an OTC derivative instrument such as CFD, the value and payment of

related liabilities are determined with respect to the movement of the price underlying assets

contained in the derivative or the underlying financial instrument or reference point. As such,

when entering into an order to buy or sell a CFD, the Client speculated with the movement of the

price of the underlying financial instrument (underlying assets contained in derivative or CFD).

The Client declares that he understands when trading with derivative such as CFD, he does not

become the owner of the underlying assets contained in the derivative or the underlying financial

instrument, and that he will not receive a physical delivery of such a financial instrument. As the

owner of the CFD, the Client is not entitled to attend and / or vote at any general meeting of

shareholders of the financial instrument to which the CFD is linked.

 

• OTC transactions

 

When trading CFDs with us, such transactions will not be executed on a recognized or designated

exchange and are known as OTC transactions. All positions you have entered with us must be

closed with us and cannot be closed with any other entity. OTC transactions may involve a higher

investment risk because there is no stock exchange on which to close an open position. It may

be impossible to liquidate an existing position, assess the value of a position arising from an OTC

transaction, or assess risk exposure. Supply and demand prices may not be determined by us

based on the best execution policies applied in the market. There is no central clearing and no

guarantee from any other party regarding the payment obligations of RSI GLOBAL to the client.

 

• Conflict of interest

 

RSI GLOBAL is the other contracting party to all transactions concluded under the Investment

Services Agreement and, therefore, RSI GLOBAL interests may conflict with yours. Our Conflict of-Interest Management Policy is available on the website www.rsiglobalinvest.com.

 

• Risks associated with long positions of CFD, i.e. for CFD buyers

 

CFD’s long position means you are buying CFDs in the market by speculating that the market

price of the underlying asset will rise between the time of purchase and sale. As the owner of a

long position, you will make a profit if the market price of the underlying asset increases while

the CFD long position is open. On the contrary, you will suffer a loss if the market price of the

underlying asset falls while the CFD long position is open. Your potential loss may therefore be

greater than the initial margin. In addition, you may incur a loss due to the closure of your

position, in case you do not have enough cash to margin in your account to maintain an open

position.

 

• Risks associated with short CFD positions (Short), i.e. for CFD sellers

 

A short position in a CFD means that you are selling CFDs in the market speculating that the

market price of the underlying asset will fall between the time of purchase and sale. As the owner

of a short position, you will make a profit if the market price of the underlying asset decreases

while the CFD short position is open. On the contrary, you will suffer a loss if the market price of

the underlying asset increases while the CFD short position is open. Your potential loss may

therefore be greater than the initial margin. In addition, you may incur a loss due to the closure

of your position, in case you do not have enough cash to margin in your account to maintain an

open position.

 

• Currency risk

 

Investing in CFDs with underlying assets denominated in a currency other than your base

currency involves currency risk due to the fact that, when the CFD is settled in a currency other

than your base currency, the value of your return may be affected by conversion to the base

currency.

 

• No guarantee of profit

 

There are no guarantees of profit or avoidance of losses when trading CFDs. The client did not

receive such guarantees from any of the company's representatives. The client is aware of the

risks associated with trading CFDs and is financially able to bear such risks and bear any losses

incurred.

 

• Leverage

 

Leverage trading applies only to derivative financial instruments, in this case contracts of

difference (CFDs) and means that the Client can trade with the values of the underlying assets

contained in the derivative that are significantly higher than the funds actually invested by the

 

Client, which serve exclusively as a margin. High leverage can significantly increase potential

earnings, but it can also significantly increase potential losses. Leverage is defined as the ratio

of the burden on the Client's assets to the total value of the underlying assets contained in the

derivative or CFD (for clients who are citizens of Montenegro 1:100, but a client who is not a citizen

of Montenegro may be granted a higher leverage).

For example, with a leverage ratio of 1:20, a client can trade an imaginary amount 20 times his

/ her available capital (i.e. $ 20 for every $ 1).

 

• Margin

 

"Margin" represents the necessary funds in the account to maintain its current position in all

transactions collectively, at the relevant time. For example, in the default leverage ratio of 1:20,

the required “margin” or the level of money in the account in relation to the underlying assets

contained in the derivative is 5%. The “margin” level and leverage refer exclusively to trading in

derivative instruments, i.e. instruments that enable greater exposure to the underlying assets

contained in the derivative in relation to holding an open position in the underlying assets

directly.

Where the Client does not provide a margin level for open positions it holds, up to a critical

margin level that is critical (close out), the Company has the right to start closing all positions in

the Client's account in connection with transactions for which the Client did not provide the

required level of margin, starting from the position that is most unprofitable for the Client.

 Investment company RSI GLOBAL Podgorica was established on 30.07.2021. It was registered in the Central Register of Commercial Entities in Podgorica under the number 40009801, with company ID 03393429.

 

RSI GLOBAL Podgorica has a license to provide investment services, issued by Montenegro Capital Market Authority. License is issued under number: 03/2-4/1-21 from the date of September 6, 2021.

 

List of licensed companies can be found on the Montenegro Capital Market Authority website, at link: https://www.scmn.me/en/investment-firms.

LEI: 8945002DWSV6CP1I1908

Discover our fast and secure Online Identity Identification Process!

 

Thanks to Artificial Intelligence Technology that combines comprehensive Liveness Selfie check, Identity Document check and Proof of Residence check, account opening process has never been easier.

 

Wherever you are, all you need is internet access, valid ID document (ID card, Driver's license or Passport), Proof of Residence not older than three months and computer with webcam or smartphone.

 

When online identification starts you will be able to choose available languages: English, German, Spanish, Turkish, Russian, Italian, Portuguese or Arabic.

 

SUMSUB IDENTIFICATION STEPS

During the very easy and pleasant journey with Sumsub, which lasts no longer than five minutes, you will perform the following steps:

1. Choose the language and the Country that issued Identity Document

You have to fill out the questionnaire on Trader portal and go to section Upload documents.

2. Take a picture or upload ID card, driver's license or passport

You will be informed to prepare identification document and give a consent to Privacy Policy by pressing button Next, and then upload required documentation.

3. Pass Liveness Selfie check

Just take a look at your phone’s camera and Sumsub’s passive 3D liveness technology will automatically validate the your presence.

4. Take a picture or upload Proof of Residence

Show Your valid proof of residence and successfully finish KYC process!

 

 

In cooperation with Sumsub, RSI Global provides an easy and smooth identity verification process and performs ongoing user screening against global watchlists, PEP, sanction and adverse media lists to ensure full compliance.

Whole onboarding process is finished by signing a Client Agreement with RSI Global, using electronic signature provided via Docusign.

 

DEPOSIT AND WITHDRAWAL TRANSACTIONS

Users can make deposit and withdrawal transactions using any of available payment systems. Deposit transactions can be made in one of the following ways:

• Payment cards - , Maestro or MasterCard. Transactions are processed in cooperation with AllSecure doo and Hipotekarna banka ad and are made in a secure and certified manner through the AllSecure Payment Gateway. Users can use only their own card. Note that 3D secure should be enabled for the card. And online transactions should be available for the card. After entering the card information and confirming the payment, the bank authorizes the transaction and thus the order is approved and enters the further process of preparation for delivery. The amount will be reserved on the card account and will not be available for another purpose. The transaction will be completed and the amount deducted from user’s card account if the transaction is successful. In the event that the transaction is not successful the payment will not be completed, and the amount will not be deducted from the card account.
• Bank wire. Transactions are processed directly via your bank to your bank account using an invoice you are creating in your Member’s area.

Please note that all payments will be affected in Euro (EUR). If the payment is done using foreign issuers bank cards, total amount of transaction will be converted into bank settlement currency, according to the current exchange rate of Mastercard. User’s bank could apply additional commission for transactions.

Commissions applied to the transactions listed in the RSI Global web site.

In the case of a refund to a client who has previously paid by one of the payment cards, in part or in full, and regardless of the reason for the refund, the refund is made exclusively through the same , Maestro or MasterCard card used for payment. This means that our bank will, at our request, make a refund to the cardholder's account.

 

CHARGEBACK

Customer shall pay the Bank the face amount of any card transaction processed by AllSecure Payment Gateway pursuant to this Agreement whenever any card transaction is reversed in accordance with the Rules or any applicable consumer protection statute (a “Chargeback”), including by way of example, but not limited to, the following:

• The deposit transaction was not specifically authorized;
• Any card transaction is alleged by the cardholder to have been executed improperly or without authority;
• The cardholder disputes the quality of service;
• The extension of credit for services performed was in violation of law, rules or regulations of any government agency, federal, state, local, or otherwise, or in violation of this Agreement;
• Cardholder claims the EUR amount was altered after the draft was completed;
• The Transaction Card had expired before the transaction date arises from the use of a counterfeit or otherwise ineffective Transaction Card;
• The embossed name on the Transaction Card differs from or is dissimilar to the name signed on the signature panel of the Transaction Card of the draft or the signature on the signature panel of the Transaction Card differs from or is dissimilar to the signature on the draft;
• The information contained in the draft was received by AllSecure Payment Gateway more than 30 business days after the transaction date showing thereon;
• The draft is a duplicate of one previously processed or includes a charge previously paid by the cardholder;
• The draft is fraudulent or the transaction was not a bona fide transaction in User’s ordinary course of business;
• The Card issuer has information that fraud occurred at the time of the transaction, whether or not such transaction was properly authorized by the Card issuer, and the cardholder neither participated in nor authorized the transaction; and
• In any other situation where a draft was executed or depository credit given in circumstances constituting a breach of any duty, term, condition, representation, or warranty by User hereunder, or where any action or lack of action by User in violation of the Rules has resulted in the draft being charged back to the Bank by an issuing member of /MasterCard pursuant to the Rules or the draft is charged back to the Bank for any other reason. Additions and deletions to this list may occur as the Rules change.

 

APPLIED STANDARDS AND PROCESSES IN DATA PROTECTION WHEN PAYING BY CARD

When entering payment card data, confidential information is transmitted via the public network in a protected (encrypted) form using SSL protocol, using the most modern methods of tokenization of sensitive data, and in accordance with PCI-DSS standards. At no time is payment card information available to the merchant.

3D Secure protection for all merchants and customers - AllSecure Payment Gateway uses the highest global standards of data protection and privacy. All merchants using the AllSecure Payment Gateway are automatically included in 3D-Secure protection, which guarantees customers the security of their purchases. Customer payment card numbers are not stored on the merchant's system and the registration itself is protected by SSL data encryption.

PCI DSS Standards - AllSecure Payment Gateway is constantly complying with all the requirements of card organizations in order to increase the level of security of merchants and customers. From 2005 until today, without interruption, the system is certified as PCI-DSS Level 1, which is the highest standard in the industry. The PCI Data Security Standard (PCI-DSS) is a standard that defines the necessary security measures when processing, storing and transmitting sensitive card data. PCI Standards protect sensitive cardholder data throughout the payment process: from the moment data is entered at the merchant's point of sale, during communications between the merchant and relevant banks and card organizations, and the subsequent storage of such data.

COMPLAINTS

The services sold through our website are accompanied by all legal documentation in accordance with the Agreement with the client. If you want to start the complaint process, you need to fill in the document from our website "Complaint form" and send us an e-mail [email protected] Click to Download COMPLAINT FORM After you send the form, we will get back to you within 7 business days.

Data Privacy Statement

Protecting the privacy and protection of personal and financial data of our clients is one of our priorities. Investment company “RSI GLOBAL” Podgorica operates in accordance with the Law on Personal Data Protection (“Official Gazette of Montenegro”, No. 079/08, 070/09, 044/12 and 022/17) which is also harmonized with the General Regulation Of the European Union on the protection of personal data. Please read this Privacy Statement which clearly explains how the Company collects, processes, stores and protects customer information. We will periodically adjust the statement to new laws and technologies to keep it in line with business and changing circumstances. By opening an account or using the website, you give your consent to the collection and use of personal data by “RSI GLOBAL” Podgorica as explained in this Privacy Statement. The company is committed to open and transparent management of your personal data. The purpose of the use of your personal data will be stated in all cases where required in our documents and interactions with you. Collection of personal data You can use the website www.rsiglobalinvest.com without disclosing your personal data. However, “RSI GLOBAL” Podgorica requests information in order to provide you with services of account opening, order execution, safekeeping of property and privacy, as well as for the execution of all services in accordance with your request. For this purpose, “RSI GLOBAL” Podgorica may in certain circumstances collect information from relevant banks and / or credit agencies or other sources that will help us create the best possible profile and thus enable the provision of better services. The information collected by RSI GLOBAL Podgorica includes: Information contained in the application that includes personal information you provide to us in your application, such as your name, address, date of birth, email address, employment details, amount of income, source of income, etc. which are used to evaluate your application. The information you provide to us is also used for the purpose of maintaining communication with you. Transaction information that includes information for the purpose of assessing your trading experience and thus the suitability of conducting transactions with our products and services, as well as information on the expected volume and value of your transactions with us in order to build your economic profile. When you trade with us we also collect information on the volume and value of transactions you have had with us. Verification information that includes information needed to verify your identity such as ID, passport, passport number, proof of residence address. This information may also include basic information about you from public records or from other entities not related to “RSI GLOBAL” Podgorica. Please note that we record telephone conversations or electronic communications in connection with concluded transactions and the provision of services related to the receipt, transmission and execution of client orders. In accordance with the Law on Prevention of Money Laundering and Terrorist Financing ("Official Gazette of Montenegro", no. 033/14, 044/18 and 073/19), we may request verification of your identity and other personal data. Your personal data is treated strictly in accordance with the Personal Data Protection Act. Use of personal information and its disclosure The data we collect will be used only for the purposes of providing our services or for other purposes for which you have given your consent, except in cases where the law provides otherwise. They also help us improve our services, set up and manage your account, have insight into your current needs, improve customer service, tailor your search to your needs, and inform you about relevant products, services, or promotions. If for any reason you do not wish to receive notifications of this nature contact us at [email protected]. In accordance with the Law on Capital Market (“Official Gazette of Montenegro”, No. 001/18) “RSI GLOBAL” Podgorica keeps personal data on clients for a period of at least five years. “RSI GLOBAL” Podgorica reserves the right to disclose personal data to third parties when required by law, regulatory authorities, law enforcement agencies or other state bodies, competent jurisdictions in order to protect our rights and / or in case of compliance with legal procedures. In such circumstances, “RSI GLOBAL” Podgorica will explicitly inform the third party about the confidential nature of the information. We may disclose your personal information: other companies that provide financial and other services for “RSI GLOBAL” Podgorica and their clients; our affiliated bodies, agents, employees and representatives; Capital Market Commission, Police Directorate – Sector for Prevention of Money Laundering and Terrorist Financing and other reference institutions; financial institutions and other similar organizations in connection with our corporate activities or designated by you; external service providers and professional advisors who provide us with services such as invoice processing, customer service, conducting customer satisfaction surveys or other activities to collect relevant data for our business; credit institutions, collection agencies, courts, regulatory bodies as agreed or authorized by law; any organization at your request or an authorized person, including your financial advisor, broker, lawyer or accountant; partners, branches and unions and brokers with whom we cooperate; the person responsible for your application. You hereby unambiguously agree to exchange information with that person and to an authorized individual, as specified by that individual or contract. “RSI GLOBAL” Podgorica does not sell, license, lease or in any other way disclose personal data to third parties, except as described in this Statement. Integrity and protection of personal data In order to collect and store current, accurate and complete information, please notify us immediately of any changes in personal data that " RSI GLOBAL " Podgorica has about you. Personal information is securely stored on servers accessed only by authorized personnel via a password. All personal data is encrypted and " RSI GLOBAL" Podgorica takes all possible protection measures in order to prevent unauthorized access to the same. Statistics and cookies " RSI GLOBAL " Podgorica uses cookies in order to collect statistical information about visitors to our websites. The data collected are: number of visitors, pages visited, types of transactions performed, time spent online and downloaded documents, name of your ISP, IP address, date and time of access, difference in time zone compared to the mean time per Greenwich Mean Time (GMT), content of the request, access status / HTTP status for the amount of data transferred, browser, language setting, browser version, operating system and screen area, website through which you linked to our website, websites you visited from our pages. This information is used to evaluate and improve the performance of our websites. Apart from statistical information, we do not collect any information about you through our website, unless you provide it to us. “RSI GLOBAL” may share statistics on the use of websites with reputable advertising and marketing companies. The information does not reveal the identity of the user. The right to insight and correction You have the right to inspect all your personal data stored with us, the right to correct, supplement and delete them when they are incomplete, inaccurate and out of date. For the above, it is enough to send an e-mail to our address [email protected]. Limitation of liability “RSI GLOBAL” Podgorica is not responsible for the content of the privacy policies of the websites to which it is linked. “RSI GLOBAL” Podgorica has no control over the use or protection of information provided by the Client to these sites. Whenever the Client decides to link to a cobranded website or a linked website, he may be required to register or provide other information. Please note that in this case the information will be recorded and regulated by third parties and their privacy policy. Client's consent By accessing our website or submitting a request to open an account in “RSI GLOBAL” Podgorica, you agree that “RSI GLOBAL” Podgorica collects, maintains, uses and discloses personal information about you that you or another person has provided as described above. Contact us For all questions about our Privacy Statement, how to update personal data, their access, contact us by phone or email [email protected]. Amendments to this Privacy Statement “RSI GLOBAL” Podgorica reserves the right to amend this Statement in accordance with the dynamics of regulations and operations. You agree and accept all changes that will be submitted to you for inspection on our website. Any dispute regarding our Privacy Statement is subject to our Terms and Conditions. “RSI GLOBAL” Podgorica advises its clients to periodically check and review this Privacy Statement.