MiFID II Disclosures

1. Regulatory status and scope

ASTEO LUXEMBOURG S.A. is authorised by the CSSF under firm number P00000438 to provide the reception and transmission of orders in relation to one or more financial instruments, the execution of orders on behalf of clients, portfolio management and investment advice, together with the ancillary services of foreign exchange services connected to the provision of investment services and investment research and financial analysis. The firm is classified as a Class 3 (small and non-interconnected) investment firm under Regulation (EU) 2019/2033 and holds authorised Family Office status.

Under the MiFID II freedom to provide services, the firm is entered under number 4129 in the CONSOB register of EU investment firms operating in Italy without a branch and may provide there the reception and transmission of orders, portfolio management, investment advice and investment research.

2. Client categorisation

Every client is categorised in writing before services are provided, as a retail client, a professional client or an eligible counterparty, in accordance with Annex II of MiFID II. Retail clients benefit from the highest level of protection, including full suitability and appropriateness assessment, detailed cost disclosure, best execution protections and the strongest reporting obligations.

Clients may request a different categorisation. A request to be treated as a professional client is accepted only where the quantitative and qualitative criteria of Annex II are met and only after the client has been informed in writing of the protections that will be lost. We reserve the right to refuse such requests.

3. Suitability and appropriateness

Where we provide investment advice or portfolio management, we obtain the information necessary to assess suitability: knowledge and experience, financial situation including the ability to bear losses, investment objectives including risk tolerance, and sustainability preferences. A suitability report is provided to retail clients before the transaction is concluded.

Where we receive, transmit or execute orders without advice, we assess the appropriateness of complex instruments such as CFDs and warn the client where the product is assessed as inappropriate or where insufficient information has been provided.

4. Order handling and best execution

We take all sufficient steps to obtain the best possible result for our clients on a consistent basis. The execution factors considered are price, cost, speed, likelihood of execution and settlement, size, nature of the order and any other consideration relevant to its execution. For retail clients, the best possible result is determined by reference to total consideration, being the price of the instrument together with all execution-related costs.

Comparable client orders are executed sequentially and promptly unless the characteristics of the order or prevailing market conditions make this impracticable, or the interests of the client require otherwise. Client orders are not aggregated with own-account orders in a manner detrimental to any client. Specific client instructions may prevent us from applying our execution policy and may result in a different outcome.

The Order Execution Policy identifies the execution venues and brokers on which we place significant reliance, is reviewed at least annually and whenever a material change occurs, and is available on request.

5. Costs and charges

Before the provision of services, clients receive an aggregated ex-ante disclosure of all costs and associated charges, comprising service costs, financial instrument costs and any third-party payments, expressed both as a cash amount and as a percentage, together with an illustration of the cumulative effect of costs on return. An annual ex-post statement of costs actually incurred is provided to all clients receiving an ongoing service.

For CFDs, costs may include spread, commission, overnight financing adjustments and currency conversion charges. These are set out in the applicable tariff schedule.

6. Conflicts of interest

We maintain and operate an effective Conflicts of Interest Policy designed to identify, prevent and manage conflicts between the firm, its managers, employees, tied agents and clients, and between clients. Measures include organisational separation of functions and information barriers, a remuneration framework that does not create incentives to act contrary to clients' best interests, restrictions on personal transactions, a register of conflicts, and gifts and inducements rules.

Where organisational and administrative arrangements are not sufficient to ensure with reasonable confidence that the risk of damage to a client's interests will be prevented, the nature and source of the conflict, and the steps taken to mitigate it, are disclosed to the client before acting on their behalf.

7. Inducements and research

We do not accept or retain any fee, commission or non-monetary benefit paid by a third party in relation to the provision of portfolio management or independent investment advice. Where minor non-monetary benefits are received in other contexts, they are capable of enhancing the quality of service to the client, are of a scale and nature that could not impair compliance with our duty to act in the client's best interest, and are disclosed. Investment research produced under our ancillary authorisation constitutes general recommendation and does not amount to a personal recommendation.

8. Client assets and investor compensation

Client funds are held with credit institutions in segregated accounts, separately identifiable from the firm's own assets, subject to daily reconciliation. Clients are covered by the Système d'indemnisation des investisseurs Luxembourg (SIIL) for eligible investment claims up to EUR 20,000 per investor, and by the Fonds de garantie des dépôts Luxembourg (FGDL) for eligible cash deposits up to EUR 100,000 per depositor, subject to the conditions and exclusions of the Luxembourg law of 18 December 2015 as amended.

9. Reporting to clients

Clients receive prompt confirmation of executed orders, quarterly statements of financial instruments and funds held, and, for portfolio management, periodic performance reporting. Where the overall value of a leveraged portfolio depreciates by 10 percent and thereafter at multiples of 10 percent, clients are notified. Holders of CFD positions are notified when the value of each instrument depreciates by 10 percent and thereafter at multiples of 10 percent.

10. Product governance and target market

As a distributor of financial instruments, we obtain and assess the target market information determined by manufacturers, define our distribution strategy accordingly, and periodically review whether the products distributed remain consistent with the needs, characteristics and objectives of the identified target market. Sales outside the positive target market are monitored and documented.

11. Complaints handling

Complaints are handled free of charge under a documented procedure overseen by a member of authorised management, in accordance with CSSF Regulation N° 16-07. Complaints may be sent to complaints@asteo.eu. Receipt is acknowledged within ten business days and a substantive response is provided within one month. Clients who remain dissatisfied may submit a request for out-of-court resolution to the CSSF within one year of filing their complaint with the firm.