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Investment Terms EEA clients
Transfer of ETFmatic Ltd accounts to Aion Bank NV/SA
Terms of Website Use
Investment Terms EEA clients
- Welcome to our Terms and Conditions for ETFmatic users (“Terms”). They are important so please read them carefully and ensure that you properly understand them prior to using our Services. If you have any questions please contact us for further information. You can email us at firstname.lastname@example.org or contact us by post or telephone using the details on our Website. References to “us”, “we” and “our” mean Aion Bank SA/NV and any of its holding companies, subsidiary companies and all the subsidiary companies of such holding companies. The terms “client”, “you” and “your” mean the person or company having an account with us and, where applicable, their duly authorised representatives, legal representatives and successors.
- Aion Bank SA/NV is a credit institution incorporated as a limited liability company (“société anonyme”/”naamloze vennootschap”) under the laws of Belgium, having its registered office at Avenue de la Toison d’Or – Guldenvlieslaan 26/28, 1050 Brussels, Belgium, and registered with the Crossroad Bank of Enterprises under number 0403.199.306. The Bank is licensed by the National Bank of Belgium (“NBB”), whose address is 14 boulevard de Berlaimont/de Berlaimontlaan, 1000 Brussels, Belgium, https://www.nbb.be/en, as a credit institution under the Belgian banking law of 25 April 2014 (“Aion Bank ” ).
- This Agreement will become legally binding and we will start providing the Services to you as soon as you have passed our know your customer (“KYC”) and anti-money laundering (“AML”) checks. We’re obligated to run these checks by law.
- For reasons beyond our control (e.g. your bank, location, method of payment etc.) it may take a few days for your money to reach us. So don’t worry if there’s a delay! We’ll confirm receipt of your money via email and via an in-app notification.
- We do not provide advice. We will use our discretion to make investments on your behalf by acting on the information you have provided or will provide to us from time to time.
- By entering this Agreement you acknowledge that there are risks associated with investing, and that
you accept those risks. Below we have listed some of the most common risks associated with our
proposition. This is not a comprehensive list of all the risks to which investors might be exposed –
there may be others that exist now, or which may arise in future.
- Past performance is not an indicator of future performance;
- The value of investments may go down as well as up;
- You are not certain to make a profit;
- You may make a loss;
- You may lose your entire investment;
- The price or value of investments may fluctuate significantly; and
- Any income distributions may fluctuate significantly.
- We offer our Services to residents in the European Economic Area (“EEA”), provided they are not also tax residents in the United States of America.
- To open an Account with us, you must be a natural person over 18 and a named holder of a bank account (“Bank Account”).
4. Our Services
- Under these Terms, we will provide you with some or all of the following services:
- Discretionary portfolio management;
- Safe custody of your assets;
- Trade execution.
- In conjunction with additional terms and conditions we may provide you with the Portfolio Gliding.
5. Discretionary Portfolio Management
- We will manage your portfolio(s) (“Goal(s)”) in accordance with the instructions you provide us with so long as they are clear, reasonable and consistent with any applicable laws. Where we can act on your instructions we will do so promptly and with reasonable care and skill. We have the right to treat any information that you provide us with as accurate and complete. You may change your information at any time by updating the settings in your Account or by contacting us directly.
- You authorise us to enter into any type of arrangement or transaction on your behalf and to invest any amount or any proportion of your Goal in any one investment or investment type, and we may do so in any currency and on any market. We reserve the right to exercise our discretion when deciding on or altering your asset allocation and/or instrument selection, and you acknowledge that we may make common investment decisions, which apply to a number of client Goals, including yours.
- When you have more than one active Goal with us and you send us money without informing us of which Goal you would like to fund, we shall select one for you and allocate the funds accordingly.
6. Trade Execution
- The base currency of your Goal will be:
- GBP if you choose to operate your portfolio in GBP;
- EUR if you choose to operate your portfolio in EUR; and/or
- USD if you choose to operate your portfolio in USD.
- We invest primarily in Exchange Traded Products (“ETPs”) such as Exchange Traded Funds (“ETFs”), Exchange Traded Notes (“ETNs”) Equities and Bonds.
- We will invest in ETPs that have the same base currency as the currency you have selected for your Goal (i.e. GBP, EUR or USD). However, it is important to note that although the instruments’ base currency will match the currency you have selected for your Goal, the underlying securities held by the ETP could be in any region, country or currency.
7. Personal Information
- Consistent with Anti-Money Laundering Regulations and to provide you with services, we collect, use, share and store certain information about you including personal information. We may use this information in order to carry out electronic searches on private and public databases. We will keep records of any information we obtain. We may use credit reference agencies which will record that we have made an enquiry about you. Such credit reference agencies may record, use and share any information we give them about you with other financial institutions, organisations and fraud prevention agencies, as the case may be. By entering into this Agreement, you agree to our use of credit reference agencies.
- In some instances, we may require you to provide us with additional information and/or documents. You agree to provide us with such information and/or documents within a reasonable period of time. You agree that, if you do not provide us with the information/documents that we request from you, we may suspend your Account or take any other action against you in respect of your Account as necessary for us to further our legitimate business purpose or comply with any relevant law, rule or regulation.
- We may use your personal information to provide you with an improved user experience and/or further information and/or marketing materials. You have the right to ask us not to process your personal data for marketing purposes and you may exercise this right at any time by amending your preferences in your Account via the Website or Applications or by notifying us directly.
- You can request copies of your personal information that we hold or that are held by any of the service provider we work with by communicating with us directly. We may charge a fee for providing you with this information, as permitted by the relevant jurisdiction’s law and regulation. Our current fee is published in the section Fees and Charges of this Agreement.
8. ‘Retail Client’ Status
- We will provide our services on the basis that you are a Retail Client as defined in the Directive 2014/65/EU on markets in financial instruments (“MiFID II”). This means that you are entitled to the protections provided for Retail Clients under the MiFID II rules and under relevant national legislation. If you would like further information on the nature of these protections, please contact us.
- We may communicate with you from time to time including by telephone, email, app notification or by “text” / SMS message. All communications between you and us will be in the English language.
- We may act on any communication that we believe to be from you without first acknowledging receipt nor carrying out any verification processes. We will not be liable for acting on a disingenuous or fraudulent request. We will not be liable for any loss arising from any error of transmission or misunderstanding, or from the fraud of any other party unless caused by our negligence, wilful default or fraud.
- You will be solely liable for any and all losses arising from unauthorised transactions where:
- You have with intent or gross negligence compromised the security of your Account or failed to comply with your obligations to use your Account in a way prescribed by this Agreement; or
- You fail to notify us about an unauthorised or incorrect transaction within twelve (12) months of the date of that transaction.
- We cannot guarantee that electronic communications to you from us will be successfully delivered, or that they will be secure, uncorrupted, untampered and virus free. We will not be liable, in circumstances beyond our reasonable control, for any loss, damage, expense, harm or inconvenience caused as a result of an email being lost, not delivered, delayed, intercepted, corrupted or otherwise altered.
- You may request a copy of any legally required disclosures (including this Agreement) from us. Following request, we will provide it to you in a form which allows for storage and reproducing of the information (including by email).
- You may request that we stop sending you notifications. However if you request that we stop sending you
any of the notifications that we deem necessary for the provision of our services to you, we reserve
the right to terminate this Agreement and with it your Account. You may amend your preferences in
respect of which electronic communications you want to receive at any time by logging in to your
Account and using the tool available for this purpose.
- We will send all notices, information and other correspondence to you by email at the email
address you have provided in your Account (and such other email address as you may designate
from time to time) or by sending you a “text” / SMS message. You must have internet access
and an active email account to receive communications and information (including notices)
relating to your Account. With the exception of amendments to this Agreement, any notice will
be considered to have been received by you twenty-four (24) hours after the time at which it
is posted on our Website, emailed or texted to you. In the event that any notice, information
or other correspondence is sent to you by post, the letter will be sent to the current postal
address which you have recorded in your Account and will be deemed to be delivered:
- For Belgian residents, on the second business day after posting; or
- For residents of any other country, on the fifth business day after posting.
- We will send all notices, information and other correspondence to you by email at the email address you have provided in your Account (and such other email address as you may designate from time to time) or by sending you a “text” / SMS message. You must have internet access and an active email account to receive communications and information (including notices) relating to your Account. With the exception of amendments to this Agreement, any notice will be considered to have been received by you twenty-four (24) hours after the time at which it is posted on our Website, emailed or texted to you. In the event that any notice, information or other correspondence is sent to you by post, the letter will be sent to the current postal address which you have recorded in your Account and will be deemed to be delivered:
10. Account Security
- We take security seriously, and we advise that you do too. Among other things, you are responsible for:
- Frequently changing your password;
- Notifying us immediately should you have reason to suspect that your Account is being accessed without your permission and/or that a transaction is incorrect;
- Ensuring that you follow sound online practices for creating and/or storing your passwords;
- Enabling 2-step authentication for accessing your Account;
- Notifying us immediately should you suspect an email address that you have provided us with has become compromised; and,
- Taking all reasonable steps to ensure that no one accesses your account without permission.
11. Third Parties
- You may request that third parties be permitted to access your Account to provide services to you, including account information services (“AIS”) and/or payment initiation services (“PIS”). You acknowledge that should you do so, we may disclose certain information about your Account to it. We are not responsible for any third party’s use of your Account, or any information that we share with it. Giving permission to a third party does not relieve you of your responsibilities under this Agreement.
- We may refuse a third-party’s access to your Account if we have reason to suspect it is not acting in your best interests.
- We will notify you if:
- We have reasons to believe that the security of your Account has become compromised;
- We have reasonable concerns or suspicions about a third party’s access to your account;
- We refuse access to one, some or all of the third parties who you have requested access for.
- We reserve the right to perform any of our obligations to you through the agency of an associate or any third party of our choosing. We will take all reasonable steps to ensure that any third party that we appoint to provide a service to you is competent.
- Providing notice to us in respect of this Agreement must be made by email or by post using the details on our Website.
13. Client Money
- We will take reasonable steps to identify a bank with a competitive interest rate (determined by that bank) and deposit any of your uninvested money with that bank (the “Deposit Bank”), together with other clients’ money. You acknowledge that we also may decide to deposit the client money on our Aion Bank accounts and act as the Deposit Bank. We will exercise due skill, care and diligence and review periodically the adequacy and appropriateness of the Deposit Bank or any other bank/credit institution where your money is deposited and of our arrangements with it. We will not be responsible for any acts, omissions or default of a bank/credit institution chosen other than for exercising care in its choice and/or monitoring.
- You accept that your money may get deposited in an account with our other clients’ money and, if so, you will not have a claim for a specific sum in a specific account. In such an event, given that your claim would be against the pool, if there is a shortfall, you would share pro rata in that loss.
- We will inform you from time to time of the amount credited to your Account (determined by the Deposit Bank and us). No interest will accrue on your Account and you accept that we are not under any obligation to pay interest on any amount credited to your Account.
- We reserve the right to pay away your client money balance to a registered charity of our choice if the balance is of 25 EUR/GBP/USD or less, those balances remain unclaimed at least six years following the last movement on your account and we have taken reasonable steps to trace you and you have not responded to such communication within 28 days of the communication having been made. As a result the released balance will cease to be client money.
- We are under no obligation to tell you before terminating our relationship with the Deposit Bank and appointing a replacement.
14. Compensation Scheme
- Aion Bank is a member of the Belgian Guarantee Fund.
- All sums held in accounts with Aion, savings certificates and financial instruments are respectively
protected under deposit guarantee and investor compensation schemes:
- All sums held in accounts with the Aion Bank and savings certificates are covered by the Guarantee Fund up to EUR 100.000 (regardless of the currency) per depositor; and
- Financial instruments are covered by the Guarantee Fund up to EUR 20.000 (regardless of the currency of the financial instruments).
- For more information, please consult: https://www.fondsdegarantie.belgium.be/fr (French version) or https://garantiefonds.belgium.be/nl (Dutch version).
15. Client Assets
- Client Assets are segregated in special bank or custody accounts, which are designated for the exclusive benefit of our clients. By properly segregating the client’s assets, if no money or stock is borrowed and no futures positions are held, the client’s assets are available to be returned to the client in the event of the company’s default. Aion Bank reserves the right to decide whether it will carry out an asset transfer, or whether it will liquidate the client’s portfolio and return cash. For the removal of doubt, should Aion decide to return cash it will not assume any of the client’s tax liabilities.
16. Your Investment Profile
- You will provide us with information about yourself, your attitude to risk, your goals and your attitude to savings and investments by answering a series of questions on our Website or Applications. You must update such information as necessary.
17. Investment Thresholds
- We require a minimum Account value of £1,000 / €1,000 / $1,000. If you subsequently withdraw money to bring the value of your Account below that minimum investment, we reserve the right to sell your assets and to hold your investment as cash, or to return the proceeds to you. For the removal of doubt, one may have several portfolios with values less than £1,000 / €1,000 / $1,000 provided that in aggregate they are valued at more than £1,000 / €1,000 / $1,000.
- We will provide you with:
- Transaction statements following each transaction;
- Account statements detailing your holdings on a periodic basis;
- Annual statements (position, summary of dividends, transactions);
- Invoices with details of the fees charged.
19. Withdrawal Requests
- When you make a Withdrawal Request, we may limit the destination Bank Account to the Bank Account that you used to fund your Account.
- In exceptional circumstances, we may not be able to sell all the assets required to satisfy your Withdrawal Request in full (for example, where the order book for a particular ETF is below the minimum size required for execution on exchanges). When this happens, we will use our best efforts to sell the rest of the assets up to the Withdrawal Request during our subsequent trading sessions. We may have to make one or more transfers to your Bank Account in respect of the same Withdrawal Request.
- The money will be transferred in the currency of your Goal/Portfolio and, where that currency differs from the currency of your Bank Account, you accept responsibility for any foreign exchange (“FX”) fees and other fees associated with the transaction, which means that you may receive less money than you expected. It may take up to fourteen (14) business days for the money you have requested to arrive in your account.
- We may pool (also known as aggregating) your transactions with those of other clients. We will only do so where we believe that it is unlikely to disadvantage your overall net position.
21. Fees and Charges
- All fees stated herein include VAT. Unless explicitly stated otherwise, you may be charged:
- Our management fee
- Our standard management fee is equal to 0.48% and for adaptive portfolios is equal to 0.75% of your assets under management (AUM) per
year calculated on a daily basis. Our management fee covers any other fees associated
- Portfolio management
- Our standard management fee is equal to 0.48% and for adaptive portfolios is equal to 0.75% of your assets under management (AUM) per year calculated on a daily basis. Our management fee covers any other fees associated with:
- The ETF issuers’ management fees (collectively known as the Total Expense Ratio or
- Your TER is charged in addition to our management fee and varies depending on your asset allocation.
- For requesting reports:
- Transmitted electronically are free of charge.
- Where requested in paper format, we will charge £20 / 20€ / $20 per report.
- Transfer fees
- Within the European Economic Area NIL (0%)*
- For transfers to accounts outside of the European Economic Area we will charge £25 / 25€ / $25*
- Our management fee
- We may change these rates from time to time and will notify you of any such changes by publication on our Website and by email at least fourteen (14) calendar days prior to making the change.
- We may deduct any amounts payable by you to us from your Account. If the available funds are insufficient, we may sell assets held as part of your Account to cover such charges. We may pay (or receive from third parties), fees in relation to referrals of business. We may receive payment from or share charges with a third party. If you require a service from us which is not listed in the section Fees and Charges of this Agreement, you should first enquire about the charge before instructing us to carry out the service.
22. Cash Deposits
- All cash you deposit with us will be held in segregated accounts with Aion Bank or an approved bank (the “Custodian”) and may include the deposits of more than one client but without being mixed with our assets or the assets of the Custodian.
- Income earned on the investments held in your Portfolio will be remitted to your Portfolio and may be reinvested. We will not pay or credit interest to you where we hold cash in your Account.
- The Custodian may, at times, receive dividends, interest and other rights or payments in respect of the investments you hold and may, when required: (i) withhold or deduct tax or other amounts from such payments and (ii) deduct any costs incurred by it when complying with these obligations, from your Account. It will be your sole responsibility to reclaim any such withholdings or deductions where you are eligible to do so.
- We are under no obligation to tell you before terminating our relationship with the Custodian and appointing a replacement.
23. Conflicts of Interest
- We, or anyone connected with us, may carry out certain transactions for you where we, or another client of ours, have a duty that may conflict with our duty to you. We have developed protocols to manage conflicts of interest that enable us to act without bias or damage to your interests. Our employees are provided with training about the protocols and the standards of conduct to which they must adhere. Our management is responsible for ensuring the protocols are adhered to and to deal with any conflict that may arise. We will inform you if we reasonably believe that we cannot adequately manage a conflict.
- We are committed to taking measures to recognise, supervise, examine and resolve conflicts of interest. We recognise that it is not possible to eliminate all sources of conflict of interest; however, safeguarding clients’ welfare remains our primary objective.
- Examples of conflicts of interest include:
- Where we have a direct or indirect financial interest in a commercial undertaking you are connected to;
- Where we have a personal association or relationship with those affected, or likely to be affected, by the information or issue in question;
- Where we have an expectation of a future interest (eg, future employment);
- Where we have a previous association with a person affected or likely to be affected by the information or issue in question;
- Where we have an interest arising from a common interest group, such as a trade association or other public or private society;
- Where we accept gifts and/or hospitality or entertainment; and
- Where we have a close personal relationship with someone who has an interest as described above.
- We maintain a log of conflicts that arise and note in it how each conflict was monitored and how a solution was developed and applied to resolve the problem and to prevent the client’s interests being affected. The effectiveness of our protocols is assessed by internal audit staff members who execute their duties in a wholly independent capacity.
- Where our functions could create an internal conflict we separate the duties appropriately. The operations functions are maintained and conducted separately from the front office functions and an appropriate level of qualification, expertise and supervision is applied.
- Staff remuneration is by means of a basic salary which is not linked to the underlying performance of the company. A remuneration committee agrees and monitors awards to achieve consistency and equitability and does not lead to conditions that may foster conflict.
- We accept responsibility for any loss, damages or costs suffered or incurred by you only to the extent that such loss arises directly from our gross negligence, wilful default, fraud, and/or our deliberate and wilful breach of any duties which we owe you under the MiFID II rules of conduct as applied in Belgium . We will not be liable for any other losses, damages or costs suffered or incurred by you.
- We will take reasonable care in the assessment and appointment of sub-custodians, bankers, counterparties, agents and other third parties. We accept responsibility for any loss, damages or costs incurred by you only where they arise directly from our negligence, wilful default or fraud in the assessment or appointment of such persons. We will not be responsible for the actions of any third parties. We do not accept responsibility for any loss, damages or costs you may incur as a result of any cause beyond our reasonable control.
- Our duties to you are expressly stated in this Agreement or provided for in the MiFID II rules of conduct as applied in Belgium. We do not owe you any other duties.
- You will indemnify us against any liability, cost, expense, loss or any damage incurred by us (including but not limited to professional advisors’ fees) arising from your breach of this Agreement, negligence, wilful default or fraud.
25. Amendments to this Agreement
- We may amend or replace this Agreement. Should we opt to do so we will give you fourteen (14) calendar days’ notice via publication on our website, email or any other communication channels agreed upon with you from time to time. We will provide you a link to a revised version of this Agreement.
- If we are required to amend this Agreement for reasons of (i) compliance with MiFID II rules of conduct, (ii) any other applicable law or regulation, (iii) adding new services or functionalities to your Account or (iv) any other changes which do not reduce your rights nor increase your liabilities, we may do so with immediate effect provided we inform you in advance. Any unilateral change that we make would be deemed accepted by you upon receipt of notice from us.
- Should you not accept an amendment, you may object by closing your Account following the procedure in the section Closing Your Account. If you have not closed your Account within 14 days from the date of the notice of amendment, you will be deemed to have accepted it. If you close your Account, please note that you remain liable to us in respect of any fees, charges and other liabilities pursuant to the section Termination of this Agreement.
- Should you have any major issues with our website, applications, or services, please contact us and clearly indicate that you have a complaint. This helps us to distinguish a ‘complaint’ from a mere ‘query’. We aim to acknowledge your complaint promptly, investigate the circumstances and report the results to you.
- If your complaint remains unresolved after 8 weeks from the date when you first made the complaint you may refer it directly to the competent Ombudsman for financial services, Ombudsfin, North gate II, Boulevard du Roi Albert II, 8 box 2, 1000 Brussels. Details on their complaints procedure can be found at: https://www.ombudsfin.be/en/individuals/introduce-complaint
27. Termination / Account Closure
- You may close your Account and thus terminate this agreement at any time by providing 30 days written notice via email to email@example.com. Account closure is subject to the settlement of all outstanding transactions.
- We may close your Account at any time at our discretion. Common reasons for closing an Account held with
- You are in breach of any terms of this Agreement;
- You have not accessed your Account within the past five years;
- We suspect you of having ill intentions;
- You have not funded your account for more than one year;
- We have reasons to suspect that your Account was accessed without authorisation.
- Where we decide to close your Account, we will provide you with notice of closure and where relevant,
the reasons for doing so, together with the procedure to follow in order to withdraw any funds under
our management. We may:
- Keep your Account’s personal information in our records in order to fulfil our legal obligations;
- Suspend, limit or deny your access to, or use of, our services, software, systems (including any networks and servers used to provide any of the services) operated by us or on our behalf or some or all of the services in respect of your Account;
- Retain your funds after closure, to the extent and until such time we may reasonably require them, in order to protect ourselves and/or a third party against risks, including but not limited to, claims, fines, fees, charges and any other liabilities; and/or
- Attempts to contact you after we have closed your Account for any reason.
- If you are the legal representative of an incapacitated or deceased Account holder, please contact us.
28. Assignment and Transfer
- You do not have the right to assign or otherwise transfer to any other party your rights or obligations under this Agreement.
- We reserve the right to assign our rights and obligations under this Agreement at any time and will send you notice by email of any such assignment prior to its taking effect. This does not affect your right to terminate this Agreement under the section Termination of this Agreement.
29. Dormant Accounts
- Your account will become “dormant” if you have not accessed it for at least five years. To protect both you and us, you will be unable to access a dormant Account. Contact us should you be unable to access your account and we shall activate it accordingly.
- We comply with the applicable EU laws and regulations on reporting and sharing of financial information for tax purposes. At the end of each tax year, we will provide you with a summary of all the taxable events on your Account, such as dividend distributions and capital gains or losses (“Account Tax Certificate”).
- By entering into this Agreement, you acknowledge and agree that it will be your obligation to complete and submit the appropriate tax filings in your country of tax residence.
31. Governing Language
- This Agreement has been drafted in English. If this Agreement is translated into another language and there is a conflict or inconsistency between the English language text and the translated text, the English language text prevails.
32. Governing Law and Jurisdiction
- This Agreement and any non-contractual obligations or claims arising out of or in connection with it are governed by Belgian law. You and we irrevocably agree that the courts of Belgium will have exclusive jurisdiction to settle any dispute or claim that arises out of or in connection with this Agreement (including non-contractual disputes or claims), without prejudice to mandatory rules of law stating otherwise.
33. Cancellation Rights
- You have a period of fourteen (14) days, beginning on the date on which your Account is opened or the date on which you receive a copy of this Agreement, whichever is the latest, within which to cancel your Account. We will sell any investments made on your behalf but will not be responsible for any market loss that you may incur as a result.
34. Force Majeure
- We will not be responsible for any failure in fulfilling a contractual obligation as a result of any situation, condition or event beyond our reasonable control (a “Force Majeure Event”), which may include, without limitation, an act of Parliament, an act of God, acts of terrorism, strike or riot, extreme fluctuations in the price of a security, failure of communication or electronic equipment or anything else that may reasonably impede our ability to act in line with this Agreement.
- We will continue to take all reasonable steps to act in your best interests when a Force Majeure Event occurs and, to the extent that we can no longer comply with the term(s) in question, we may suspend or alter any part or all of the Agreement.
35. Third Party Rights
- A person who is not a party to this agreement cannot enforce or enjoy the benefit of any term of this Agreement.
36. Effective Date
- These Investment Terms take effect from 1 April 2021, and will not apply to services provided prior to 1 April 2021. Please contact us at Our Support Desk if you require a copy of any prior version.
37. Instrument Risks
- Some specific risks associated with investing in shares include:
- Dividend payment and growth is not guaranteed;
- Companies in which you invest are not obliged to pay dividends;
- Companies may go into liquidation or receivership which may result in the shares becoming worthless;
- Equity markets may decline in value;
- Corporate earnings and financial markets may be volatile;
- If there is no recognised market for shares, then these will be difficult to sell and accurate information about their value may be hard to obtain;
- Smaller company investments may be difficult to sell if there is little liquidity in the market for such shares and there may be substantial differences between the buying price and the selling price;
- Shares on overseas markets may involve different risks from EEA shares; and
- Investments in overseas companies depend not only on the performance of the shares but also upon foreign exchange rates which may change adversely affecting the value of the shares in your base currency.
- Our fixed income securities (government bonds) are issued by governments, governmental
bodies, quasi-governmental bodies, UK local authorities, and companies in the UK and in other
countries. The main risks associated with these securities includes:
- There are few recognised markets in which such securities are traded because they are traded between the issuers, their brokers, and the banks and securities houses making a market in the securities;
- Capital may be lost if the issuer defaults;
- Capital may be eroded due to the effects of inflation; and,
- The value of fixed income securities may fall as well as rise.
- Collective investment funds may be authorised by an approved regulator or unauthorised and unapproved.
We will only invest your money in authorised funds quoted on recognised leading exchanges. The main
risks associated with investing in collective investment funds are:
- There may be no recognised market for collective investment funds as units/shares are issued and redeemed by the managers of the funds;
- Funds may be valued for pricing and dealing purposes either daily, weekly, fortnightly, monthly or even less frequently by the fund managers;
- The prices of the underlying investments of the funds will vary according to the markets on which these are listed or traded;
- Some authorised funds are subject to greater supervision than others; and
- Funds in currencies other than the Client’s currency may be affected if foreign exchange rates move in an unfavourable direction thus reducing the valuation of investments in base currency terms.
- We may from time to time carry out certain transactions on your behalf where the price may have been influenced by measures taken to stabilise it. Stabilisation enables the market price of a security to be maintained artificially during the period throughout which new securities are being sold to the public. Stabilisation may affect not only the price of the new issue but also the price of other securities. The Financial Services and Markets Authority allows stabilisation in certain circumstances. The effect of stabilisation may be to keep the price of certain securities at a higher level than they would otherwise be during the period of stabilisation. We will endeavour not to take part in stabilisation. The fact that a new issue or a related security is being stabilised should not be taken as any indication of the level of interest from investors, nor of the price at which they are prepared to buy the securities.
- We may buy an investment denominated in a currency other than the agreed base currency of your Portfolio
on your behalf. The main risks associated with this include:
- A movement in exchange rates may have a separate effect, favourable or unfavourable, on the gain or loss otherwise experienced on the investment;
- If depositing collateral denominated in one currency, you may be subject to margin calls in circumstances where the obligations are denominated in another currency (in addition to the risk of margin calls for fluctuations in relative values); and
- Some currencies are not freely convertible and restrictions may be placed on the conversion and/or repatriation of your funds including profits or dividends.
38. Best Execution Policy
- We are bound by MiFID II rules to undertake transactions without disadvantaging our clients. Under MiFID II rules, we “must take sufficient steps to obtain the best possible result, taking into account price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order.” When trading, we provide best execution (applied equally to single bargains or aggregated/grouped orders), meaning that transactions should be on the best terms reasonably available.
- We are a discretionary investment manager that treats all clients fairly and makes all decisions on
which instruments to purchase and when to trade on behalf of our clients. We aggregate and net all
client orders, trading on a consolidated basis. The steps of the process are:
- Our algorithm reviews each client’s goal to generate orders;
- All orders are executed according to the aforementioned best execution practices; and
- After execution and payment settlement the transactions are recorded on the client’s account and a trade confirmation is sent to the client.
- To ensure best execution, we periodically review our procedures, trading system choices, arrangements, and any other relevant execution factors to ensure that there is sufficient liquidity in each of the instruments, and that we are able to deal on more than one market.
- Factors to achieve best execution include, in the following priority: size and type of order, likelihood of execution, price, and any other relevant consideration. We determine the best possible result, summing the price of the financial instrument and the costs related to execution (which include all the expenses incurred and directly related to the execution of the order, i.e. execution venue fees, clearing and settlement fees, and any other fees paid to third parties involved in the execution of the order). All particular trade conditions which may restrict our ability to achieve best execution will be informed to the clients.
- We transact trades in various manners, including by electronic order books, retail service providers, agency crosses, telephone and electronic algorithmic systems and, where relevant, make use of appointed representatives committed to achieving best execution for clients. We will keep a record of all previously mentioned trades. Those which do not fall into the above categories may have restricted liquidity or trade venues. We will assume best execution has been achieved with reference to any information provided by the market counterparty at each transaction.
- We will execute the trade as soon as reasonably practicable unless a delay will better serve the client’s interest. Trades will be transacted in the same order as they were generated by our system unless specific trades have conditions attached which may alter the order of priority.
- We use our discretion to determine the execution venue for a trade, which may include an exchange, multilateral trading facility (“MTF”), organised trading facility (“OTF”) or a broker. We will provide annual reports revealing the top five (5) execution venues for that year.
- We typically trade on a biweekly basis, yet we reserve the right to change the days on which we trade or to trade less frequently if, in our discretion, we regard it as necessary or desirable to do so.
39. Fractional Investing
- To provide you with a balanced portfolio regardless of the amount invested, our system can attribute you a proportion of an ETF. This means that where the amount invested does not allow us to construct a portfolio that is consistent with your risk appetite using whole shares, we will round down to the nearest number of whole shares and create fractional entitlements. Your portfolio will subsequently always be in line with your risk level and our rebalancing policy.
- Where you hold fractional entitlements, the beneficial interest to them will be yours alone. As with your whole ETF shares, we will safeguard them for you as per our permissions and the MiFID II rules.
40. Additional Portfolio Gliding Terms and Conditions
- These are additional terms (“Additional Terms”) and conditions which apply when you opt in to our Portfolio Gliding feature. Opting in grants us authority to gradually adjust the target asset allocation of your Portfolio, with an aim to decrease your exposure to risk as your Portfolio progresses towards its designated end date (“Gliding”).
- When you activate Gliding for any of the Portfolios in your Account, you agree to these Additional Terms. For the avoidance of doubt, if there is any inconsistency between these Additional Terms and the Agreement, these Additional Terms shall prevail.
- When you opt in to Gliding, you authorise us to adjust the target asset allocation of your
Portfolio over time pursuant to the settings you have selected which include:
- The asset allocation which you want to start Gliding from (“Starting Asset Allocation”);
- The desired asset allocation you want to achieve at the end of the Gliding period (“Target Asset Allocation”); and
- The period of time over which you want Gliding to occur (“Time Horizon”); (“Additional Mandate”).
- To opt in to Gliding, you must have an Account and at least one Portfolio open, active, and funded.
- We reserve the right to terminate Gliding for your Account if you cease to meet any of the conditions for eligibility in the section Availability of these Additional Terms.
- These Additional Terms will apply from the moment you opt in to Gliding by clicking the toggle
bar in the edit portfolio/portfolio creation screen until the earlier of:
- Us fulfilling the Additional Mandate;
- Your opting out of Gliding by clicking the toggle bar in the edit portfolio/portfolio creation section;
- Your Account/Portfolio ceasing to meet the conditions for eligibility in the section Availability of these Additional Terms;
- Your Account/Portfolio suspension or closure, either by you or us in accordance with our Agreement.
- When Gliding is deactivated for your Portfolio, you agree to and accept the following actions:
- Your Portfolio will default to a Starter Portfolio with an asset allocation which most closely matches the current asset allocation on the Gliding path at the relevant time;
- The asset allocation of the Starter Portfolio referred to in this clause will be static and rebalanced periodically to the relevant static weights; and
- You will need to review and sign off on the starter portfolio’s asset allocation to ensure that you are satisfied that it meets your requirements.
- By opting in to Gliding, you agree to and accept that we will not be liable for any losses arising in relation to profits, taxation, fiscal affairs, or otherwise, which you may incur as a result of us gradually adjusting the target asset allocation of your Portfolio, except if such losses are caused by our gross negligence, wilful deceit, or fraud.
41. Glossary of TermsBusiness Day means all days except for every Saturday, every Sunday, public holiday and days where the company seat of Aion Bank in Belgium is not open. Anti-Money Laundering Regulations means the Law of 18 September 2017 on the prevention of money laundering and terrorist financing and on the restriction of the use of cash. Netting means either of: (i) consolidating the value of two or more transactions, payments or positions in order to create a single value or (ii) offsetting a position in one security or currency with another position either in the same security or another one with the object of offsetting gains in one position against losses in another. Website means our website together with our app(s) and their functionalities, as developed from time to time.
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