FinSA client information

Information about Prio Partners

The following information serves to fulfil the obligations of financial service providers to provide information to their clients pursuant to Art. 8 et seq. of the Financial Services Act («FinSA»). It is neither intended for advertising purposes nor does it constitute an offer of financial services or financial instruments. The current version of this information sheet is available on our website at https://www.priopartners.ch/fidleg-kundeninformation or may be obtained in physical form from our business address.

1. General Information and Authorisation Status

Prio Partners AG (the «Company») is a financial service provider within the meaning of FinSA. Its registered office is located at Stockerstrasse 12, 8002 Zurich, Switzerland. It is registered in the Commercial Register of the Canton of Zurich under the number CHE-349.498.861.

The Company is primarily engaged in asset management on a commercial basis for individual clients and collective investment schemes.

The Swiss Financial Market Supervisory Authority FINMA has granted the Company a licence as a manager of collective assets pursuant to Art. 5 para. 1 in conjunction with Art. 24 of the Financial Institutions Act («FinIA»).

The Company is subject to ongoing supervision by FINMA.

2. Ombudsman’s Office

In accordance with Art. 74 et seq. FinSA, the Company is affiliated with the ombudsman’s office OFS Ombud Finance Switzerland (https://ombudfinance.ch/kontakt). In the event of disputes with the Company, private clients within the meaning of Art. 4 para. 2 FinSA and professional clients within the meaning of Art. 5 para. 1 FinSA may initiate mediation proceedings through the ombudsman’s office.

3. Executive Management

The Company has three qualified executive managers within the meaning of Art. 20 para. 1 FinIA.

4. Business Activities

The Company’s business activities include, in particular, the following areas:

  • The Company provides discretionary asset management on a commercial basis within the meaning of Art. 3 lit. c no. 3 FinSA for individual clients. In the context of asset management, the Company manages assets held by the client with a custodian bank in the client’s name and for the client’s account and at the client’s risk. Based on a power of attorney granted by the client, the Company executes transactions at its own discretion and without consulting the client. In doing so, the Company ensures that the investment strategy agreed with the client is implemented.
  • As part of portfolio-related investment advice, the Company advises clients on transactions involving financial instruments, taking into account a defined client portfolio. For this purpose, the Company ensures that the recommended transactions comply with the investment strategy agreed with the client. The client decides whether to implement the Company’s recommendations and instructs the client’s custodian bank to execute the transactions. The client may also authorise the Company to instruct the custodian bank to execute the transactions after the client has approved them vis-à-vis the Company.
  • The Company manages assets of foreign collective investment schemes and may provide investment advisory and asset management services to issuers of structured products.

The Company provides its financial services on the basis of written agreements concluded with its clients, which contain all information regarding the essential characteristics, functioning, rights and obligations of the parties and the risks associated with the financial services provided.

5. Risks Relating to Financial Services

The risks associated with the financial services provided are explained to clients before an agreement is concluded. Clients are requested to read the information provided carefully, in particular the brochure «Risks Involved in Trading Financial Instruments» published by the Swiss Bankers Association (https://www.swissbanking.ch/de/downloads), and to contact the Company if they have any questions.

6. Cost Information

Costs and fees are incurred in connection with the services provided by the Company. These are disclosed to clients before an agreement is concluded and are regulated in detail in the relevant agreements.

7. Equity Interests and Economic Ties to Third Parties

The Company has no economic ties to third parties that could result in a conflict of interest vis-à-vis clients in connection with the provision of financial services.

8. Market Offering Considered

When providing financial services, the Company primarily considers financial instruments from third parties. The Company may offer collective investment schemes managed by it and structured products managed or advised by it to its clients or third parties or consider them when providing discretionary asset management services. It will inform investors or clients if proprietary products are offered, recommended or used in asset management.

9. Conflicts of Interest

9.1 In General

Conflicts of interest may arise if a financial institution or its employees:

  • can obtain a financial benefit or avoid a financial loss for themselves at the expense of clients;
  • have an interest in the outcome of a financial service provided to clients that conflicts with the clients’ interests;
  • have a financial or other incentive, when providing financial services, to place the interests of certain clients above the interests of other clients; or
  • receive financial or non-financial compensation or services from a third party in connection with a financial service provided to a client.

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9.2 Specific Conflicts
9.2.1 Proprietary Products

When managing client assets and making investment recommendations, the Company may also consider proprietary products. «Proprietary Products» include, among others, products issued by the Company or by companies closely associated with the Company. Products from third-party providers that have been designed according to the Company’s specifications or for which the Company provides asset management or investment advisory services are also deemed to be proprietary products.

Due to the Company’s close association with its proprietary products, it is convinced of their quality and believes that their use is in the best interests of its clients. Nevertheless, the Company may have incentives to favour its proprietary products over third-party products, for example because higher investment volumes may generally promote the distribution of proprietary products.

9.2.2 Compensation from Third Parties

Art. 26 FinSA defines how compensation from third parties received by the Company in connection with the provision of financial services must be handled. This includes, in particular, brokerage fees, commissions, fees, rebates or other financial benefits such as «soft commissions» (e.g. the provision of financial analyses and market and price information systems). If a financial institution retains compensation from third parties instead of passing it on to the client, it exposes itself to a conflict of interest that could potentially disadvantage the client. This is because the appointment of the third party or the selection of its financial products may serve not only the interests of the client but also those of the financial institution or its employees.

9.2.3 Other Potential Conflicts of Interest

When new securities are issued, the Company may also subscribe for them on its own behalf. In the event of oversubscription, this may result in allocations to clients being reduced. The same applies if employees of the Company subscribe for securities in connection with an issuance.

The Company reports to its clients on its activities exclusively on the basis of bank statements. In the statements and records issued by the custodian banks, the Company’s fee is shown as a withdrawal rather than as a cost of asset management or investment advice. Performance expressed in percentage points is therefore reported as being slightly higher than the effective performance after costs.

The Company may pay compensation to intermediaries who refer clients or individual transactions to it. If the intermediary is itself in a contractual relationship with the client, the Company informs the intermediary that such compensation must either be passed on to the client or disclosed to the client.

9.3 Management of Conflicts of Interest

To prevent unrelated interests from influencing its services, the Company has taken the following measures, among others:

  • The Company does not accept compensation from third parties when providing financial services. Should the Company exceptionally receive such compensation, it passes it on to its clients (see section 10.2.2 above).
  • Compliance with the laws and regulatory standards applicable to FINMA-authorised managers of collective assets.
  • The following principles apply when proprietary products are used (see section 9.2.1 above):
    • The Company avoids «double dipping» by excluding proprietary products when calculating the assets relevant for determining investment advisory or asset management fees.
    • Employees have no specific incentives that promote the use or recommendation of proprietary products.
    • The Company maintains a process for selecting proprietary products based on customary and objective industry criteria, such as expected performance, compatibility with the risk profile, desired diversification and costs.
    • Where possible, the Company ensures a functional and personnel-related separation between the operating units responsible for creating or managing financial instruments and those responsible for their distribution.
  • The Company maintains a compliance function responsible for identifying, preventing and managing potential conflicts of interest and taking appropriate measures where necessary.
  • The Company has established organisational arrangements to safeguard clients’ interests in investment advice and asset management, for example through approval procedures for new products.
  • The Company regulates own-account transactions by its governing bodies and employees.
  • The Company regulates the acceptance of gifts and other benefits by its employees.
  • The Company complies with best execution standards in accordance with legal requirements and its internal directives.
  • The Company has established an internal remuneration system that does not create incentives to disregard obligations or act contrary to clients’ interests.
  • The Company provides ongoing training to its employees.
  • The Company discloses specific conflicts where a disadvantage to clients’ interests cannot be ruled out.

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10. Privacy Policy

The current version of the Company’s Privacy Policy is available on our website at http://www.priopartners.ch/datenschutzerklarung.

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