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General framework

INDEPENDENT INVESTMENT ADVISOR

General Framework for Action

Introduction

Financialag by Vector Independent Investment Advisor. (hereinafter "Financialag"), in compliance with the "General provisions applicable to financial entities and other persons that provide investment services (hereinafter" Provisions "), establishes this General Framework of Action, which must be adjusted at all times.

Financialag in the performance of its functions, in the provision of advised investment services called Investment Management, understood by this when the client authorizes Financialag to act at its discretion, as prudence dictates, carrying out only reasonable operations and complying with the present general framework of action. Its content is as follows:

  1. The nature and scope of the powers or discretion of the attorney-in-fact to carry out operations with the public in relation to the operations carried out in the name and on behalf of the Client.
  2. Any significant risk associated with the nature and scope of the attorney-in-fact's discretion to carry out operations with the public derived from the provision of the Investment Management service, as well as the form and terms under which such discretion will be exercised.
  3. The way in which the Client may modify the agreed discretion in the Investment Management service.
  4. Characteristics of the Securities and / or Derivative Financial Instruments that could make up the account in question; including, possible market, credit, liquidity, operational, counterparty and legal risks.
  5. Investment Strategies to be followed when providing Investment Management.
    • The investment policy that Financialag will follow.
    • The policy that Financialag will follow regarding:
      1. The liquidity of the investment portfolio, and
      2. The contracting of securities loans, short sales and leverage operations
    • The selection criteria to be followed regarding investments in debt securities, in relation to:
      1. The target duration of the investment portfolio,
      2. The conformation of the probable investments by type of Issuer, indicating if they are governmental, state, municipal, banking, of companies or trusts or if it will be made up of a mixture of such securities, and
      3. The credit rating granted by a securities rating institution.
    • The investment in the Securities and derivative financial instruments that are indicated in Section B of Annex 4 of the Provisions, stating:
      1. The underlying assets to be considered;
      2. The assumptions under which the Security or derivative financial Instrument could be canceled or amortized early, and
      3. The markets where said Securities or derivative financial instruments are traded.
    • The policy to be followed in the face of conditions of high volatility in the financial markets, or of economic or political uncertainty;
    • The type of operations with Securities that you will be able to carry out.
  6. OTHERS

Definiciones

Duration: Corresponds to the time the investment is maintained.

Investment Management: To make investment decisions on behalf of clients through the administration of accounts carried out by the Financial Institution or the Investment Advisor, under cover of stock brokerage contracts, trusts, commissions or mandates, in the that in any case the discretionary management of said accounts be agreed.

I. The Nature and Scope of the Powers or Discretion of the Attorney to carry out operations with the public in relation to the operations carried out in the name and on behalf of the client.

The proxies (the “Proxies”) of Financialag to carry out operations with the investing public are duly certified to carry out operations with the public for advice, promotion, purchase and sale of Securities with the public, in accordance with the Securities Market Law and The Provisions, in addition to being in constant training and empowered to handle discretionary contracts, they have the knowledge and technical capabilities to provide the Investment Management service, based on the policies established by Financialag, which are mentioned in the following points.

The Agent has the powers to carry out operations on behalf of the Client according to his discretion and prudence, without the need for prior authorization or ratification by the Client for each operation, but always adhering to this General Framework of Action. the Client's profile, the profile of the financial products with which it will operate, the evaluation of the reasonableness of the operations, of which documentary evidence is kept, the diversification policy established by Financialag and the standardized strategies offered to Clients that have similar investment profiles, not affecting other Clients who maintain their investment in the same strategy.

II. Risks associated with the nature and scope of the Power of Attorney's discretion to carry out operations with the public, derived from the provision of the Investment Management service, as well as the form and terms under which such discretion will be exercised

Due to the nature of investments in the stock market that are the subject of Investment Management, including those made in mutual fund shares, it is not possible to ensure any return or guarantee rates other than those that issuers are obliged to cover. Therefore, their investments are subject to losses or gains, generally due to market fluctuations.

  1. From the investment
    • Risk

      • That the attorney-in-fact invests in an unauthorized instrument or an authorized asset, but outside the parameters stipulated in “Annex 1” of this General Framework of Action.

    • Shape

      • The attorney-in-fact makes the determined investment, which is distributed in an automated way proportionally among the Clients signed for the same Strategy.

    • Scope

      • The allocation is made uniformly among all Clients participating in the same Strategy, so there is no possibility of permanent distortion in the allocation of values between participants.

  2. Divestment or Withdrawal of investment
    • Risk

      • That at the Clients' request for withdrawal or divestment there is no adequate liquidity of the securities and investments that are maintained in the Strategy in which it participates.

    • Shape

      • Pre-established investment and divestment dates are stipulated that allow planning the investment term of the securities in question.

    • Scope

      • Do not make investments in illiquid securities for a term greater than the divestment dates.

  3. Rebalancing
    • Risk

      • Rebalances imply modifications to the composition and proportion of the securities that make up the Investment Strategy of all Clients. Securities classified as "Non-Liquid or Low Liquidity" will not be included in the rebalancing.

    • Shape

      • All Rebalances must be carried out with the system developed for this purpose, which does so automatically and consistently for all Clients. In no case are manual or individual adjustments made.

    • Scope

      • This is carried out every day and its objective is to keep the Investment Strategies of each client aligned with the parameters that are stipulated in the “Annex 1” signed by each Client.

III. Way in which the Client may modify the discretion agreed in the Investment Management service.

The Client may at any time request through their session on the web platform or by means of a letter signed by the client, to change the management of their account, canceling the discretion in the Investment Management service, which implies canceling the Contract of Provision of Services, Mandates, Annexes of Strategies or Investment Strategies and therefore will cease to be a client of Financialag.

IV. Characteristics of the Securities and / or Derivative Financial Instruments that could make up Investment Management; including, possible market, credit, liquidity, operational, counterparty and legal risks.

According to the strategies defined by Financialag through the Investment Committee, Clients' portfolios under the Investment Management service may be invested, by type of market, in:

For debt instruments: shares representing the capital stock of investment funds (in debt or hedge instruments), investment funds known as Mutual Funds, commercial paper, bank acceptances, Stock certificates, bank certificates of deposit, development bonds, monetary regulation bonds, bank bonds, in general bonds issued by any type of issuer, or any type of debt instruments issued by a credit institution, corporation, company or entity, short and medium-term promissory notes, obligations, subordinated obligations, collective investment vehicles, listed and listed throughout the trading sessions on the stock exchanges, whose primary objective is to seek to reproduce the behavior of one or more indices, financial assets or benchmarks (tradable funds, commonly referred to as “exchange-trad ed fund ”or ETF's for its acronym in English), whose underlying is predominantly debt instruments.

For variable income instruments: shares of variable income investment funds, investment funds known as Mutual Funds, collective investment vehicles, listed and quoted throughout the trading sessions in the Stock exchanges, whose primary objective is to seek to reproduce the behavior of one or more indices, financial assets or benchmarks (negotiable funds, commonly called "exchange-traded fund" or ETF's for its acronym in English), whose underlying is predominantly equity instruments.

In a complementary way, it is possible to invest in ETFs referenced to raw materials.s

It will not be invested in derivative financial instruments.

It is important to mention that the aforementioned securities have exposure to different types of risks, and that the sensitivity of each of them depends on the risk factors of the instrument in question.

Market risk: Discretionary quantifiable risk that implies the potential loss due to changes in the risk factors that affect the valuation or the expected results in the Client's investments, among which are the movements of prices, interest rates, exchange rates and indexes of prices. If the movements of these factors are contrary to those expected in the strategy, it may imply losses or impairment in the returns of the Client's portfolio.

Liquidity risk: Discretionary quantifiable risk that implies the potential loss due to the anticipated or forced sale of assets at unusual discounts to meet its obligations, or due to the fact that a position cannot be timely disposed of, acquired or hedged through the establishment of a equivalent opposite position. Therefore, if a Client requires the anticipated or forced sale of an asset to be carried out before the investment horizon foreseen in the strategy or derived from an atypical movement in prices, rates or indices, the selling position will be below the prices dictated by the market, which implies a potential loss in portfolio returns.

Counterparty Risk: Risk related to the potential loss due to total or partial lack of payment by the issuer, the securities or documents in which the Client invests, can also be produced by the downgrading of a security within the strategy or the counterparty. with which operations are held. In other words, the performance of the investment portfolio will be adversely affected in the event that any counterpart of the operations that make up the Client's investment portfolio fails to comply with its payment obligations.

Legal Risk: It refers to the affectation that is suffered in the event that there is a breach of a counterparty and it cannot be demanded, by legal means, to comply with the payment commitments. It refers to operations that imply an error of legal interpretation or some omission in the documentation.

Regulatory Risk: One where operators, promoters and administrators do not comply with the provisions due to ignorance or bad faith, established in the laws, circulars and operation manuals.

Systemic Risk: Risk that the bankruptcies of major institutions could provide a series of chain bankruptcies and finally a total collapse of the entire financial system.

Human Factor Risk: One where the professionals who participate in the promotion, operation and administration have a deconcentration in their activities and present errors that generate losses to the Client.

Technological Risk: The potential loss due to damage, interruption, alteration or failures derived from the use or dependence on hardware, software, systems, applications, networks or any other information distribution channel.

Reputational Risk: It is related to the losses that could result as a consequence of not realizing business opportunities, attributable to the loss of prestige of a financial institution.

Sovereign Risk: It refers to the possibility that a sovereign entity does not meet its debt payments mainly for economic and financial reasons.

Operational Risk: Potential loss due to failures, deficiencies or errors in the processing and storage of operations or in the transmission of information that may cause an opportunity cost handicap in the market; as well as adverse administrative and judicial resolutions, fraud or theft (legal risk).

V. Investment Strategies and Profiles to be followed when providing the Investment Management service

Ultra-Cautious

  1. Ultra-Cautious
    1. The Security Type, the maximum investment limit, the term and restrictions of the Eligible Securities themselves that are presented in Annex 1.
    2. The risk level of this Strategy will be low and it is suitable for any type of investor, as long as the proportion it represents of its total investment is in accordance with its profile.
    3. The term that is estimated or considered adequate for the Client to maintain his investment is at least one month.
  2. The investment policy of this Investment Portfolio will be "Active", since risks will be taken with the purpose of obtaining returns above the reference base.
  3. The policies that Financialag will follow are:
    1. The liquidity of the Investment Strategy will be daily from the request.
    2. No securities loans or short sales will be contracted.
  4. The selection criteria to be followed regarding investments in debt securities, in relation to the Investment Strategy:
    1. The investment strategy does not have a Target Duration since there is an “Active” Investment Strategy that implies the conclusion of operations according to changing market conditions.
    2. The conformation of the probable investments is contained in Annex 1.
    3. The credit rating requirements granted by any securities rating institution for the securities that make up the Strategy are contained in Annex 1.
  5. Investments in the Securities of the Investment Strategy are:
    1. It will only be invested in ETFs whose primary objective is to seek to reproduce the behavior of an index and are not located in the case indicated in Section B of Annex 4 of the Investment Services Circular
    2. The conformation of the probable investments in ETF's is contained in Annex 1.
    3. It will not be invested in Derivative Financial Instruments.
  6. Due to the nature of the investments made by this Strategy by investing its resources in government debt securities with a maturity of less than one year, it is not necessary to adopt defensive strategies in the face of high volatility in financial markets, or economic or political uncertainty.
  7. Purchase and sale and repurchase operations may be carried out with the values indicated in Annex 1.

Precavido

  1. The type of Securities in which it will be possible to invest:

      2. d) The Security Type, the maximum investment limit, the term and restrictions of the Eligible Securities themselves that are presented in Annex 1.

      e) The risk level of this Strategy will be low and it is suitable for any type of investor, as long as the proportion it represents of its total investment is in accordance with its profile.

      f) The term that is estimated or considered adequate for the Client to maintain his investment is at least six months.

  2. The investment policy of this Investment Portfolio will be "Active", since risks will be taken with the purpose of obtaining returns above the reference base.
  3. The policies that Financialag will follow are:

      4. c) The liquidity of the Investment Strategy will be 72 hours from the request.

      d) No securities loans or short sales will be contracted.

  4. The selection criteria to be followed regarding investments in debt securities, in relation to the Investment Strategy:

      5. The investment strategy does not have a Target Duration since there is an “Active” Investment Strategy that implies the conclusion of operations according to changing market conditions.

      The conformation of the probable investments is contained in Annex 1.

      The credit rating requirements granted by any securities rating institution for the securities that make up the Strategy are contained in Annex 1.

  5. Investments in the Securities of the Investment Strategy are:

      6. d) It will only be invested in ETFs whose primary objective is to seek to reproduce the behavior of an index and are not located in the case indicated in Section B of Annex 4 of the Investment Services Circular

      e) The conformation of the probable investments in ETF's is contained in Annex 1.

      f) It will not be invested in Derivative Financial Instruments.

  6. Due to the nature of the investments made by this Strategy by investing its resources in government debt securities with a maturity of less than one year, it is not necessary to adopt defensive strategies in the face of high volatility in financial markets, or economic or political uncertainty.
  7. Purchase and sale and repurchase operations may be carried out with the values indicated in Annex 1.

Conservative

  1. The type of Securities in which it will be possible to invest:
    1. The Security Type, the maximum investment limit, the term and restrictions of the eligible Securities are presented in Annex 1.
    2. The risk level of this Investment Strategy will be moderate and it is suitable for any type of investor as long as the proportion it represents of its total investment is in accordance with its profile.
    3. The term that is estimated or considered adequate for the Client to maintain his investment is at least one year.
  2. The investment policy of this Investment Portfolio will be "Active", since risks will be taken with the purpose of obtaining returns above the reference base.
  3. The policies that Financialag will follow are:
    1. The liquidity of the Investment Strategy will be 5 business days from the request.
    2. No securities loans or short sales will be contracted.
  4. The selection criteria to be followed regarding investments in debt securities, in relation to the Investment Strategy:
    1. The investment strategy does not have a Target Duration since there is an “Active” Investment Strategy that implies the conclusion of operations according to changing market conditions.
    2. The conformation of the probable investments is contained in Annex 1.
    3. The credit rating requirements granted by any securities rating institution for the securities that make up the Strategy are contained in Annex 1.
  5. Investments in the Securities of the Investment Strategy are:
    1. It will only invest in ETFs whose primary objective is to seek to reproduce the behavior of an index and are not located in the case indicated in Section B of Annex 4 of the Investment Services Circular
    2. The conformation of the probable investments in ETF's is contained in Annex 1.
    3. It will not be invested in Derivative Financial Instruments.
  6. Faced with conditions of high volatility in the financial markets, or economic or political uncertainty, the Investment Strategy may adopt a defensive strategy by reducing its positions in Equity and long-term securities.
  7. Purchase and sale and repurchase operations may be carried out with the values indicated in Annex 1.

Confiado

  1. The type of Securities in which it will be possible to invest:
    1. The Security Type, the maximum investment limit, the term and restrictions of the eligible Securities are presented in the Annex 1.
    2. The risk level of this Investment Strategy will be moderate and it is suitable for any type of investor as long as the proportion it represents of its total investment is in accordance with its profile.
    3. The term that is estimated or considered adequate for the Client to maintain his investment is at least one year.
  2. The investment policy of this Investment Portfolio will be "Active", since risks will be taken with the purpose of obtaining returns above the reference base.
  3. The policies that Financialag will follow are:
    1. The liquidity of the Investment Strategy will be 5 business days from the request.
    2. No securities loans or short sales will be contracted.
  4. The selection criteria to be followed regarding investments in debt securities, in relation to the Investment Strategy:
    1. The investment strategy does not have a Target Duration since there is an “Active” Investment Strategy that implies the conclusion of operations according to changing market conditions.
    2. The conformation of the probable investments is contained in Annex 1.
    3. The credit rating requirements granted by any securities rating institution for the securities that make up the Strategy are contained in Annex 1.
  5. Investments in the Securities of the Investment Strategy are:
    1. It will only invest in ETFs whose primary objective is to seek to reproduce the behavior of an index and are not located in the case indicated in Section B of Annex 4 of the Investment Services Circular
    2. The conformation of the probable investments in ETF's is contained in Annex 1.
    3. It will not be invested in Derivative Financial Instruments.
  6. Faced with conditions of high volatility in the financial markets, or economic or political uncertainty, the Investment Strategy may adopt a defensive strategy by reducing its positions in Equity and long-term securities.
  7. Purchase-sale and repurchase operations may be carried out with the values indicated in Annex 1.

Ambitious

  1. The type of Securities in which it will be possible to invest:

      2. d) The Security Type, the maximum investment limit, the term and restrictions of the eligible Securities are presented in Annex 1.

      e) The risk level of this Investment Strategy will be high and is suitable for any type of investor as long as the proportion it represents of its total investment is in accordance with its profile..

      The term that is estimated or considered adequate for the Client to maintain his investment is at least two years.

  2. The investment policy of this Investment Portfolio will be "Active", since risks will be taken with the purpose of obtaining returns above the reference base.
  3. The policies that Financialag will follow are:

      4. c) The liquidity of the Investment Strategy will be 5 business days from the request.

      d) No securities loans or short sales will be contracted.

  4. The selection criteria to be followed regarding investments in debt securities, in relation to the Investment Strategy:
    1. The investment strategy does not have a Target Duration since there is an “Active” Investment Strategy that implies the conclusion of operations according to changing market conditions.
    2. The conformation of the probable investments is contained in Annex 1.
    3. The credit rating requirements granted by any securities rating institution for the securities that make up the Strategy are contained in Annex 1.
  5. Investments in the Securities of the Investment Strategy are:
    1. It will only invest in ETFs whose primary objective is to seek to reproduce the behavior of an index and are not located in the case indicated in Section B of Annex 4 of the Investment Services Circular
    2. The conformation of the probable investments in ETF's is contained in Annex 1.
    3. It will not be invested in Derivative Financial Instruments.
  6. Faced with conditions of high volatility in the financial markets, or economic or political uncertainty, the Investment Strategy may adopt a defensive strategy by reducing its positions in Equity and long-term securities.
  7. Purchase-sale and repurchase operations may be carried out with the values indicated in Annex 1.

Adventurous

  • The type of Securities in which it will be possible to invest:
    1. The Security Type, the maximum investment limit, the term and restrictions of the eligible Securities are presented in Annex 1.
    2. The risk level of this Investment Strategy will be high and it is suitable for any type of investor as long as the proportion it represents of its total investment is in accordance with its profile.
    3. The term that is estimated or considered adequate for the Client to maintain his investment is at least three years.
  • The investment policy of this Investment Portfolio will be "Active", since risks will be taken with the purpose of obtaining returns above the reference base.
  • The policies that Financialag will follow are:
    1. The liquidity of the Investment Strategy will be 5 business days from the request.
    2. No securities loans or short sales will be contracted.
  • The selection criteria to be followed regarding investments in debt securities, in relation to the Investment Strategy:
    1. The investment strategy does not have a Target Duration since there is an “Active” Investment Strategy that implies the conclusion of operations according to changing market conditions.
    2. The conformation of the probable investments is contained in Annex 1.
    3. The credit rating requirements granted by any securities rating institution for the securities that make up the Strategy are contained in Annex 1.
  • Investments in the Securities of the Investment Strategy are:
    1. It will only invest in ETFs whose primary objective is to seek to reproduce the behavior of an index and are not located in the case indicated in Section B of Annex 4 of the Investment Services Circular
    2. The conformation of the probable investments in ETF's is contained in Annex 1.
    3. It will not be invested in Derivative Financial Instruments.
  • Faced with conditions of high volatility in the financial markets, or economic or political uncertainty, the Investment Strategy may adopt a defensive strategy by reducing its positions in Equity and long-term securities.
  • Purchase-sale and repurchase operations may be carried out with the values indicated in Annex 1.

VI. Others.

Financialag will not invest directly in shares of Limited Companies, so it will only make investments in ETFs, therefore, it does not currently have criteria on the following:

    The selection criteria that will be followed regarding investments in shares of stock market companies or stock investment promotion companies, in relation to:

    1. The objective economic sectors;
    2. The marketability;
    3. The share's membership in a certain stock index;
    4. The dividend policy of the company;
    5. The nationality of the company;
    6. The size of the companies, and
    7. Any other aspect that is relevant to the client.

Likewise, Financialag may modify this General Framework of action only when at least six months have elapsed from the last reform, except in situations previously determined by the Committee Responsible for the Analysis of Financial Products, or in situations that previously determined and documented by Financialag.

Financialag will notify its clients in case of any modification to this Framework via email.