Laurion Group | Terms of Business
16655
page-template-default,page,page-id-16655,ajax_fade,page_not_loaded,,qode-theme-ver-16.8,qode-theme-bridge,wpb-js-composer js-comp-ver-5.5.2,vc_responsive
 

Terms of Business

These Terms of Business form the core of our relationship with our stakeholders. They include legal notices, conditions of use and limitations of responsibility from Laurion in relation to its stakeholders. Please familiarize yourself with these terms prior to interact with Laurion.

 

Any interaction with Laurion in whatever capacity will include the acceptance of these Terms of Business without limitation.

 

Laurion carries regulated and non-regulated activities in the financial and investment markets. It is its strong commitment to act to the benefit of its stakeholders, taking into account the social dimension of responsible corporate development.

 

These Terms of Business are composed of:

 

  • Identification of the Parties and Affiliated Companies – we state who is bound by and must comply with the terms of business herein;
  • Identification of the Websites, terms and conditions applicable to the Websites, including to restricted client areas;
  • Information regarding Laurion, its code of ethics, confidentiality and limitation of liability by Laurion; and
  • How regulated parties (when applicable) fulfil its fiduciary duties of executing investments, protect clients and allow them to give feedback and complains regarding the services that are provided.

 

These Terms of Business do not supersede any contractual documentation between Laurion and Limited Partners (as defined herein, when applicable), or between Laurion and any of its clients or service providers. Their main purpose is to give all Stakeholders a firm commitment of how Laurion handles and manages relationships.

 

  1. Identification of the Parties

 

  • Laurion Financial Enterprises, SL

 

This document (herein after the “Terms of Business”) establishes the terms and conditions of business of the companies affiliated to Laurion Financial Enterprises, SL, the holding company of LAURION GROUP. Laurion is a registered brand (register number 018040713 of the EUIPO) held by the holding company (the “Holding”) which also owns the companies below, all part of and protected under the brand Laurion Group.

 

For the avoidance of doubt, the Holding does not have any clients nor develops any commercial activity, notwithstanding any contracts (including Non-Disclosure Agreements or management agreements) entered into on behalf of, and for the benefit of, the affiliated companies.

 

Laurion Financial Enterprises is incorporated under the laws of the Kingdom of Spain, with registered number B-67252841 and registered address at Ronda General Mitre 40 1 Planta 08017 Barcelona (Spain).

 

These Terms of Business are applicable to online and offline interactions and business units of Laurion.

 

  • Scope

 

These Terms of Business apply to the activities of the Holding and its affiliated companies (herein after, the “Affiliated Companies”) and are the baseline of the services that Affiliated Companies provide to its customers.

 

In case one or more Affiliated Companies have further obligations by force of law (e.g. in case of regulatory obligations or further legal obligations) those shall complete and complement the Terms of Business herein. Nothing in these Terms of Business shall be understood has an attempt to reduce or diminish the legal protection afforded to customers; in case where the regulatory obligations contradict these Terms of Business, the regulations shall apply, derogating any applicable provisions herein.

 

These Terms of Business shall apply to all companies held by Laurion Financial Enterprises, bar White Rock (Europe) Limited PCC – Cell A43 (the “Captive Insurance Structure”) which is governed by its own applicable terms and conditions.

 

 

  1. Identification of the Affiliated Companies

 

  • Laurion AM, SARL

 

AIFM registered under the CSSF (reg) number A0002493

25C Boulevard Royal L-2449 Luxembourg (Grand Duchy of Luxembourg)

 

  • Laurion Systems, SL

 

Register Number B-67144477

Ronda General Mitre 40 1 Planta 08017 Barcelona (Spain)

 

 

  1. Identification of the Websites

 

The Terms of Business set herein are applicable to the websites (hereinafter the “Websites”) owned by Laurion Financial Enterprises, SL (“Laurion Group”) and the Affiliated Companies:

 

 

The Terms of business shall also apply to the Websites of the Investment Vehicles managed by Laurion AM, SARL, as long as clearly stated therein. Access to said websites may be limited by regulatory or legal reasons, and a password may be requested to enter into such Websites.

 

Notwithstanding the above, access to and use of any information therein represents full acceptance of the Terms of Business, including agreement with any Disclaimers proper of each Website. Access to said Websites supposes acceptance of, and compliance with, any specific terms and conditions of access, as per the relevant Disclaimer.

 

  • Applicable Law

 

Websites are ultimately managed by Laurion, including Affiliated Companies. Any dispute arising from its use shall be subject to the laws of the Kingdom of Spain, especially Law 34/2002 of 11th of July.

 

  • Purpose of the Websites

 

The Websites’ content seeks to establish a communication channel between the owner(s) of the Website (Laurion Group) and the person(s) accessing it (henceforth, the “Users”), regarding the activity, information and services of the several companies integrating Laurion Group.

 

The Websites may include references to other websites, references to other works or information that may be proprietary or not. Laurion shall take all reasonable steps to ensure the correct use of materials protected by Intellectual Property Law (henceforth, the “IPR”) and its source, as well as to ensure the proprietary information includes references to external sources, when applicable.

 

Where information displayed results from an opinion, no rights can be derived therein in accordance with section 3.6. of these Terms of Business.

 

  • Social Media

 

Laurion may be active in Social Media, using posts, shares or referencing third party content, under the terms applicable to the social media platform used. Private Data processing shall be done in accordance with the terms of use of the social media platform.

 

For the avoidance of doubt, in case a User discloses Personal Data in such platform, its treatment and responsibility shall fall outside the Privacy Policy of Laurion Group. Laurion Group accepts no responsibility for data provided to third parties, even if the User has reach said third party via a hyperlink of Laurion.

 

 

 

  • Print Media, Radio and Advertising

 

The use of Laurion’s IPR by any third party must be understood as being dully authorized by Laurion. However, Laurion does not accept responsibility for any opinions, comments or general data that is conveyed by third parties, even when using IPR attributed to Laurion, and warrants no assurance the data is correct, accurate or fit for purpose.

 

  • Advertising and hyperlinks

 

If the Website has links or hyperlinks to other Internet sites (from third parties), Laurion will not exercise any control over such sites and content. Laurion shall not be liable for the contents of any link or hyperlink going to a website outside Laurion Group (not owned by Laurion and not referenced in this document).

 

Websites may contain sponsored content or advertising content. Sponsors and advertisers shall bear the responsibility for the content therein, provided it does not portray anything that is flagrantly illegal, unlawful or contrary to public order, public morals or any of its own ethical principles.

 

Users shall hold Laurion Group harmless for any eventual losses or damages that may arise from the use of information contained therein.

 

  • Conditions of Use

 

Accessing and browsing the Website(s) and using its content(s) does not constitute a contractual relationship in any shape or form.

 

Accessing and browsing the Website(s) does not constitute advice, assessment, consulting or any other kind of services provided by the Holding or its Affiliated Companies to the User(s). Laurion takes no responsibility for the use of contents of the website, provided it does not portray anything that is flagrantly illegal, unlawful or contrary to public order, public morals or any of its own ethical principles.

 

  • Quality of the information displayed

 

Information is displayed as is with no guarantee of accurateness.

 

  • Limitation of liability

 

Users bear full responsibility for the use of the information contained in each Website, including any losses or penalties resulting of the use of said information, under the terms of section 10.

 

Laurion is not, and shall not, in no case or circumstance, be held responsible for eventual losses, damages, direct or indirect claims that may arise over the use of the information in its Website, including any errors or of said information, except when such errors or omissions are negligent, wilfully misleading or in direct contravention of the Law.

 

  • Subjective views and issue of opinions

 

Laurion may post content in its Websites that reflects an opinion or a given view about a topic or a group of topics.

 

The content of these opinions or posts (together the “Articles”) is proprietary and, when applicable, protected by Intellectual Property Rights as applicable. Its reproduction or dissemination is not permitted without clear written consent of Laurion, regarding of the purpose of reproduction of dissemination (including for non-commercial and/or academic purposes).

 

Articles may be concentrated in a section of one of the Websites or may be spread across the Website(s) without limitation. Opinion articles are clearly flagged and, when applicable, reference all sources applicable.

 

  • Updates, modifications & replacements

 

Laurion holds the exclusive and unlimited right to update, modify or eliminate the contents of the Website(s) without limitation or prior warning.

 

Laurion may update its Terms of Business, Privacy Policy, Corporate Governance and other documentation (together the “Legal Documents”) without limitation and it may, at its sole discretion, limit public access to its content, by means of access control as applicable and technologically possible.

 

  • Obligation of Notification

 

In case of update of any Legal Documents, Laurion shall notify its registered Users and known stakeholders in advance. Laurion is under no obligation to issue a general warning or change notification to the public or to unregistered Users.

 

These rights are unlimited and may be exercised at any time, to the extent permitted by law, regulations and existing contractual rights.

 

 

  1. Cookies

 

Please refer to our Cookie Policy which sets out the use of cookies and other web tracking technology via our website.

 

 

  1. Legal Warning related to the use of Websites

 

By accessing and browsing through any of the Websites mentioned herein, User(s) unconditionally accept(s) the Terms of Business and the Privacy Policy applicable to Laurion – which is, for the avoidance of doubt, applicable to all online and offline business of Laurion, unless otherwise clearly stated.

 

Some Websites may, additionally, have disclaimers, risk warnings, controlled access (together the “Disclaimers”) or restricted areas (the “Backoffice Client Access”) only accessible to certain registered Users.

 

By accessing such websites, the User unconditionally accepts any additional terms of business without limitation.

 

Please note that in the course of browsing, under the terms of section 3.4., User(s) may be sent, through a hyperlink, to external websites that don’t apply the same Privacy Policy or Terms of Business, and may, eventually, offer a lesser degree of protection. Although Laurion takes all reasonable steps to prevent such events, it may not be held responsible for the use of a website not explicitly subject to the Terms of Business of Laurion. Users shall bear the risk.

 

Certain Website(s) may contain information regarding specific items or matters, as way of information only, including items or matters governed by especial law or regulation. Please note that said information is not intended to be construed as advice or assessment, and no warranty can be given of the completeness or adequacy of such information for your personal situation. Users are clearly warned and advised not to take any personal or business decision based on this information. Any use shall be at the Users’ own risk.

 

No information may be construed as an invitation, business proposal or instruction to act in a certain way. Prior to take any decisions Laurion strongly suggests its Users to seek professional advice.

 

  • Laurion does not accept responsibility for any decision taken based on the sole reliance on the information contained in each Website; and
  • Laurion shall not be held liable for any specific or generic damage, direct or indirect derived from the access, use and browse on each Website as well as the use of the information contained therein.

 

  • Intellectual Property Rights

 

Laurion holds the IPR rights of the contents of the Websites, both images and texts, as well as any related content that is used in external web pages and social media.

 

No party may use or dispose of any Laurion Group content, including, but not limited to, images, design, works, brands, logo, fonts or any other IP, unless it has been authorized to do so in writing.

 

 

 

  • Private Use only

 

Users undertake to use the content of the Website(s) for their own use and according to their needs. Nothing in these terms of Business shall be understood as a covenant or authorization for commercial or academic use.

 

  • Purposes of Use and limitations

 

Users who visit the Website will find and access content related to the activity, products and services offered by Laurion. Users undertake not to engage conducts that could harm the image, rights and interest of Laurion Group.

 

The content of the Website includes proprietary as well as third-party sources, containing verified, renewed and quality information. However, Laurion cannot guarantee its accuracy and/or timely update of the contents. The existing and subsequent contents on the Website(s) do not constitute, and cannot be understood as, source of financial advice.

 

  • Personal Data

 

Laurion takes all reasonable steps to protect, update and secure the information on the Websites, as well as the information that each Registered User provides upon request, when applicable. Laurion uses tools in line with market practice to avoid any misuse of its data, as well as data relayed by its clients that may categorize as Personal Data. We ensure that only authorized personnel may have access to the information the User provides us.

 

In the terms of subsection 6.1.1., stakeholders and service providers shall undergo a process of CDD & KYC prior to a business relationship being established. For the purposes of complying with its own legal obligations, Laurion may, via the appropriate business unit, undergo all checks and verifications in public and private databases for verification of identity, source of funds, sanctions and reputation.

 

For more information on how we process your data, please consult our Privacy Policy.

 

  • Conditions of use for Registered Users

 

Registered Users accept without limitation that the Website’s access through the Backoffice Client Access constitutes the main contact point between them and the relevant company of Laurion, including their contractual relationship with any AIF (Alternative Investment Fund) managed by Laurion AM, SARL as identified herein. For further information please see Section 6.

 

 

  1. Specific Terms of Business for Client Backoffice Access

 

These Terms of Business don’t supersede the Issuing Documentation of each Investment vehicle (or “Partnership”) nor the generic terms of business herein.

 

They are generic terms of business from Laurion towards its stakeholders, covering administrative and communication areas pertinent to the relationship of each investor with the relevant Alternative Investment Vehicle, managed by Laurion AM, SARL, under the terms of section 6.1.

 

  • Responsible Business Unit

 

LAURION AM, SARL is a CSSF supervised AIFM (reg), with register number A00002493, incorporated in the Grand Duchy of Luxembourg. It is the GENERAL PARTNER and the MANAGER of each PARTNERSHIP or AIF.

 

  • Personal Data, CDD, KYC, AML & CFT and Data Protection

 

  • Personal Data is treated and processed in accordance with the Privacy Policy of Laurion Group.
  • Prior to enter into a business relationship with Laurion AM, SARL

 

  • Applicable Law

 

The Governing Law of Limited Partners and Limited Partnership Agreements is Luxembourg Law.

 

  • Registered User Access

 

“Backoffice Client Access” or “Backoffice” is an in-house developed Client Access Portal designed to be the main information tool of Registered Users who are Limited Partners of a given investment vehicle of Partnership (managed by Laurion AM, SARL).

 

  • Term Sheet

 

The Term Sheet of each Alternative Investment Vehicle (henceforth, the “Term Sheet”).

 

  • Access

 

  • Mean of Access

 

Access shall be granted based on the email of the Limited Partner. Limited Partners warrant to keep their email information accurate and updated at all times, and communicate immediately to Laurion any changes that may affect their continued communications with Laurion.

 

  • Time of Access

 

Access is granted from the acceptance of the investor as Limited Partner, under the terms of the Issuing Documentation applicable to each Alternative Investment Fund.

 

  • Conditions of Access

 

Access to the Backoffice is personal and granted via password.

 

Limited Partners are urged not to share the password and the password should not be shared with any third parties. Limited Partners must keep access to their Backoffice secured at all times, not sharing passwords or other identification or access keys with any unauthorized third parties. In case of loss of the password, or unauthorized access to Backoffice, Limited Partners must contact compliance@lauriongroup.com immediately.

 

  • Acceptance of terms of use

 

  • Terms of Business

 

Access to or use of the Backoffice implies the acceptance of these Terms of Business without limitation.

 

  • Privacy Policy

 

Access to or use of the Backoffice implies the acceptance of Privacy Policy without limitation.

 

The legitimate interest for the treatment and uses of said Personal Data is done under the investment of Limited Partners in the AIF, including any connected business thereto. Personal Data details may be shared with other interested parties, including other companies affiliated with Laurion AM, SARL, as well as private or public databases for the purposes of verification and confirmation of the details provided.

 

In the terms of the Privacy Policy, you may exercise your rights at any time without any constraints and even limit the use of your Persona Data; however, as you are aware, withdrawal of consent may imply the termination of the business relationship as Laurion AM, SARL would no longer be able to comply with its legal obligations.

 

For further information please contact compliance@lauriongroup.com.

 

  • Issuing Documentation

 

Access to or use of the Backoffice implies the acceptance of the Issuing Documentation, without limitation, as per the terms of the Term Sheet and Subscription Agreement executed on the relevant date.

 

 

  • Communications and Notices

 

  • Main communication channel

 

The Backoffice is deemed to be the main communication point between the Limited Partner and the Investment Manager (Laurion AM, SARL or one of its legally appointed companies), without prejudice of Laurion AM, SARL (or its lawful representatives) ability and permission to use other communication means from time to time.

 

Communication shall be done mostly, but not limited to, using tools such as

 

  • document upload,
  • notification emails; and
  • charts, embedded information, risk reports or other reports whether in exportable format (e.g. pdf) or directly embedded in the Backoffice.

 

Communications shall be done regarding, but not limited to, the following topics:

 

  • provisional asset allocation tools;
  • information on holdings, valuation tools and lock-in periods (if applicable); and
  • news that may affect the position of each Investor.

 

Please note that although every effort is made to ensure the accurate representation of holdings, income, returns, distributions, capitalization, or any other applicable monetary of non-monetary assets, no rights can be derived from its use or information conveyed by the Platform. In due course, in accordance with the Issuing Documentation, Laurion AM, SARL shall issue, on behalf of the AIF, adequate contractual confirmation of Investments and any monies due.

 

  • Notices

 

Any notices due to Limited Partners under the Issuing Documentation shall be deemed as delivered when communicated via the Backoffice, unless otherwise mandated by applicable law.

 

  • Notices related to investments

 

Any notices related to investments or underlying performance shall be deemed as delivered when communicated via the Backoffice, unless otherwise mandated by applicable law.

 

  • Notices related to changes in Terms of Business and Issuing Documentation

 

Notices related to changes in Terms of Business and Issuing Documentation shall be done by direct email or regular mail to the Limited Partner.

 

Terms of Business may be updated without limitation, with sufficient Notice.

 

Issuing Documentation may only be changed according to applicable law; any change will be communicated in due course through the lawful procedures.

 

  • Warranties of the Limited Partner (in relation to the use of the Backoffice Client Access)

 

Limited Partners understand and agree to:

 

  • Be bound by the Terms of Business herein;

 

  • Use the Backoffice as a communication and information tool only; and

 

  • Notify Laurion AM, SARL of any change in their personal circumstances that may affect the relationship with the AIF(s).

 

 

 

 

  • Duty of Confidentially

 

Under these Terms of Business, and under the terms of the Issuing Documentation, Limited Partners warrant not to disclose any information they may have been given access through being a Limited Partner in the AIF to any third parties, acknowledging that doing so could be considered a contravention of the Issuing Documentation

 

  • Change in contractual relationship

 

In the event of termination of the business relationship between the Limited Partner and the relevant AIF, Laurion may remove access to the BACKOFFICE and to hold your Personal Data under the terms of the applicable regulations.

 

In this case, Laurion shall send a copy of the relevant documentation to the Limited Partner for audit purposes.

 

 

  1. Information Regarding Laurion and its activities

 

Laurion Group is a family owned group of companies with headquarters in Barcelona. It has a multinational approach with business interest and partners across Europe and the Americas. Stemming from an industrial background, the Group focuses on alternative investments and private equity, having set up its own captive insurance structure to hedge its risks and ensure long term sustainable growth. Our success is measured by the success of our stakeholders.

 

  • Organization of the Group

 

Laurion Group is organized in four business units:

 

  • Asset Management, headed by Laurion AM, SARL, an Alternative Investment Manager supervised by the CSSF in Luxembourg (Reg) A0002493 that manages Alternative Investment Funds (AIFs);

 

  • Private Equity, where the group actively manages a portfolio of long-term financial assets, including investments in regulated and non-regulated companies;

 

  • Laurion Systems, SL entrusted with the daily management and administration for the companies of Laurion Group; and

 

  • The captive insurance structure incorporated in Malta and managed by AON, White Rock (Europe) Limited Cell A4. It is a Protected Cell incorporated according to SOLVENCY II, authorized by the MFSA to cover risk of financial losses, according to its license. This structure is used to hedge risks, effectively ensuring a satisfactory outcome.

 

  • Corporate Values

 

The Company’s three business pillars are:

 

  • Trust: To be an ethical and responsible partner to our stakeholders.

 

  • Transparency: To be transparent and act with the best interest of our stakeholders at heart.

 

  • Stakeholder Protection: To commit and to meet all expectations and necessities of our stakeholders, not incurring into unnecessary risks.

 

 

  1. Code of Ethics

 

Laurion’s code of ethics is the concretization of its business pillars in tangible principles to which agents, staff and senior management adhere.

 

  1. Liberty to do business

 

Recognizing every client’s right to engage and not engage with our services, ensuring the sale of products and services is fit for purposes and entered into freely.

 

  1. Compliance with the law and applicable regulations

 

Laurion will always act in the utmost respect of the law and applicable regulations, looking for expert legal advice when necessary.

 

  1. Client Protection

 

Laurion always searches solutions that benefit its clients, first and foremost.

 

  1. Innovation & Creativity

 

Laurion presents creative solution for recurrent problems, facing challenges with a creative spirit.

 

  1. Accountability, personal and collective

 

Laurion is a responsible company, with a compliance culture across the board to ensure every person is aware of their duties, rights and responsibilities.

 

  1. Training and professional development

 

Laurion provides its agents the training necessary to reach their professional and personal goals.

 

  1. Respect for national, cultural and personal peculiarities

 

LAURION has a zero policy towards discrimination in any aspect.

 

  1. Respect for the Environment, bet on sustainability

 

As a main challenge for current and future generations, Laurion does its part to be sustainable and support sustainable projects.

 

  1. Confidentiality

 

LAURION guarantees the confidentiality of its stakeholders and assures them the lawful treatment of personal data.

 

  1. Intellectual Property

 

LAURION guarantees the IP rights added by its clients and partners.

 

 

  1. Confidentiality

 

Laurion takes all reasonable steps to protect the information and guarantees the confidentiality of its stakeholders and assures them the lawful treatment of Personal Data. Details on how we process, keep and managed Personal Data are detailed in the Privacy Policy.

 

For more information please contact compliance@lauriongroup.com.

 

 

  1. Limitation of Liability (generic)

 

Some of the activities carried by one or more business units of Laurion may be subject to, or limited by, specific national and international regulations. These regulations are set in place to protect investors and guarantee trust in regulated markets.

 

In that sense, and to the extent provided by applicable law, Laurion is not generically authorized to:

 

  • Provide financial advice;
  • Provide fiscal or tax advice; and
  • Provide wealth management advice.

 

Some activities above may be carried, to some extent, by one or more business units. Where that is the case, business shall be carried in compliance with applicable regulations.

 

Notwithstanding the above, Laurion’s actions, communications or interactions are not, and must not be construed as:

 

  • Engagement to purchase, trade, sell or buy any products, including financial securities offered by or on behalf of Laurion, services or any other activities; and
  • Generic invitation to interact with Laurion in any shape or form.

 

Under the terms of section section 3.6, the contents and materials included in the Website(s) (as well as in offline communication) have been obtained and produced through truthful and reliable sources, taking all reasonable steps to ensure that the contents and materials are correct. However, Laurion accepts no responsibility for the use of the information it provides to Users, except in such cases where said information is due by law and contract. In such case, Laurion shall take all reasonable efforts to provide accurate information, and not omitting any factor which would be likely to affect the decision of its recipients.

 

Laurion accepts no responsibility for any loss, either materialized or to be materialized, for reliance in information provided to any Users, including Limited Partners, in the absence of fraud, negligence and wilful misconduct.

 

Laurion AM, SARL conducts business in alternative asset management which carries a high degree of risk and is not suitable for all investors. Prospective investors are strongly advised to seek external advice if necessary.

 

 

  1. Investment Execution

 

This section applies to investments executed by the Investment Manager Laurion AM, SARL as defined in section 11.3 (a).

 

This section does not supersede any Investment Policies that may apply to any specific investment vehicles. However, it does establish common ground in (a) Laurion’s approach to investments, (b) how Laurion AM, SARL manages and executes different investments and (c) how Laurion solves conflicting positions between Laurion and stakeholders and between stakeholders themselves.

 

  • Scope

 

This section sets out Laurion’s approach for carrying out investments from origination to execution and an explanation of how the different factors influence the execution approach, in order to obtain the best possible result when executing investments.

 

 

  • Purposes and Objective

 

This section defines how Laurion treats investments, how it manages them and executes them, and how it addresses conflicts of interest.

 

  • Execution of Investments

 

  • Laurion’s approach to investments

 

Laurion AM, SARL is an alternative investment manager supervised by the CSSF under the AIFMD directive under reg number A0002493 (for more information, please contact compliance@lauriongroup.com). Laurion AM, SARL is lawfully allowed to manage funds on behalf of its investors (the Limited Partners), who adhere to certain terms and conditions of the relevant Issuing Documentation of their elected investment vehicles. Laurion may, at times, delegate the daily management of said vehicles to third parties, provided they are duly authorized under the law.

 

Laurion does not take on unnecessary risk, and it has a remuneration approach which is independent from risk taking.

 

All AIFs managed by Laurion AM, SARL are considered high risk and highly concentrated; however, the risk taking of each AIF is carefully managed to ensure a balanced outcome.

 

  • How Laurion AM, SARL manages and executes different investments

 

Laurion may invest using a business unit other than Laurion AM, SARL. It can invest via private equity or via other securities that may be issued with or without guarantee, including securities issued by companies of Laurion Group. Laurion may invest monies from its own shareholders, family members of other interest parties in the investment vehicles it manages. Likewise, Laurion may manage several vehicles with the same underlying asset type, and it may, at times, face conflicts of interest.

 

Laurion executes investments considering risk, returns, fitness for purpose and investment parameters (according to each Issuing Documentation). Laurion executes and manages all investments for the benefit of the Limited Partners and the benefit of the shareholders, matching interests at all possible times.

 

  • How Laurion solves conflicting positions between Laurion and stakeholders, and between stakeholders themselves

 

To prevent conflicts of interest, and ensure the best outcome for its stakeholders, Laurion shall:

 

  • Execute investments of its external investors (or Limited Partners) first;

 

  • Not put its external investors at a disadvantage, namely by allowing them to invest and disinvest first ahead of its own proprietary investments;

 

  • In case of conflicting investment vehicles, Laurion shall execute investments on a strict time basis, following the principles of first-in-first-out.

 

Considering its relative niche size, Laurion does not enforce Chinese walls on its premises. However, to better prevent conflicts of interest, Laurion shall enforce Chinese walls if it has reasonable grounds to believe that its absence could result in stakeholders being harmed and treated unfairly.

 

 

  1. Complaints

 

Although Laurion takes all reasonable steps to ensure a satisfactory outcome for all stakeholders, at times, the result may be below the standards of service Laurion would like to provide.

 

To gather feedback and allow the correction of a situation where a stakeholder feels it has not received fair treatment from Laurion, there is a complains procedure in place. For further information, please email compliance@lauriongroup.com.

 

 

  1. Applicable Law

 

The applicable law of these Terms of Business is the Law of the Kingdom of Spain, unless otherwise applicable to Limited Partners in accordance to the Issuing Documentation.