NAO ASSET MANAGEMENT Remuneration Policy

NAO Asset Management, E.S.G., SGIIC, S.A. incorporates into its remuneration policy the fundamental principles of internal transparency, proportionality, and consistency with sound and effective risk management—including sustainability risk—as well as alignment with the company’s values and interests. Likewise, this policy has been designed and implemented in a way that avoids conflicts of interest and ensures the independence of the affected individuals.

You can find more information about our remuneration policy at the following link: NAO Remuneration Policy

Customer Service Department

NAO Asset Management, E.S.G., SGIIC, S.A. provides its clients with a Customer Service Department, created pursuant to Law 35/2003 of 4 November on Collective Investment Institutions, the Regulations of the Commissioners for the Defence of Financial Services Customers approved by Royal Decree 303/2004 of 20 February, and, in particular, Order ECO 734/2004 of 11 March, whose purpose is to handle and resolve queries and complaints. In addition, there is a Customer Defence Regulations available from this page.

To learn more about your rights, we invite you to visit the CNMV’s Investor Corner.

The functions of the Customer Service Department are to handle and resolve clients’ queries and complaints, safeguarding at all times the protection of clients’ rights and interests arising from their relationship with the company, and ensuring that such relationships are conducted at all times in accordance with the principles of good faith, fairness and trust.

The entity’s Customer Service Department is obliged to handle and resolve complaints and claims submitted by its clients within a period of two months from their presentation to the customer service department or, where applicable, the customer ombudsman.

Queries and complaints must be addressed, in the first instance, to the head of the Customer Service Department of NAO Asset Management, E.S.G., SGIIC, S.A.:

Address:	Pl. Ayuntamiento, 27 – 7º 46002 Valencia – Spain
Phone:	+34 960 454 015
Email:	Info@nao-sam.com
Contact person:	Eva Prats Ripoll eva.prats@nao-sam.com

In second instance, once the route via the Customer Service Department has been exhausted, you may contact the CNMV’s Investor Service Office:

CNMV INVESTOR SERVICE OFFICE
Edison, 4
28006 MADRID
www.cnmv.es
información@cnmv.es

Legal Notice

Welcome to the official website of NAO Asset Management (the “Website”). Access to this Website and to the information contained herein implies acceptance of the terms of use set out in this legal notice. Therefore, we recommend that you read the following terms of use carefully if you wish to access the information contained on this portal.

This Website is owned by NAO Asset Management:
NAO Asset Management SA SGIIC: Tax ID (NIF) A-40504607
Registered address: Plaza Ayuntamiento, 27 – 7ª, 46002 – Valencia
Registration details in the Commercial Registry of Valencia: volume 10,517, page 18, sheet V-182.585, entry 1
Registration with the Spanish National Securities Market Commission (CNMV): 267
Contact email: [info@nao-sam.com](mailto:info@nao-sam.com)

 

ACCESS AND RESTRICTIONS
The collective investment undertakings included on this Website are registered with the Spanish National Securities Market Commission (CNMV) for marketing in Spain.
Access to the information displayed on this Website is reserved exclusively for individuals or entities that are residents of Spain and is not directed at individuals or entities resident in other jurisdictions of States where, due to nationality, residence or other reasons, the publication or availability of this information is prohibited or whose laws require the fulfilment of other requirements for access, availability, disclosure or publication. Persons to whom these prohibitions apply must not access the information contained on this Website.
You can consult the range of NAO ASSET MANAGEMENT products registered for distribution in other countries at the following link: [*]

NO OFFER OR SOLICITATION
The contents of this Website are for information purposes only and do not constitute an offer or a solicitation to buy or sell any product or service, nor do they constitute a recommendation or personalised advice. No information contained herein should be construed as financial, tax, legal or other advice. Investors should bear in mind that investment in investment funds or other financial products contained on this Website may be subject to market, credit, issuer and counterparty, liquidity and currency risks, fluctuations in value and the possible loss of invested capital. Before making any investment decision, you should obtain appropriate and specific professional financial, tax and legal advice. Any reference to taxation should be understood as depending on personal circumstances and may vary in the future.

INFORMATION ON RESULTS AND RISKS
Past performance is not a promise or guarantee of future returns. The value of investments and the income from them may go down as well as up and an investor may not recover the amount initially invested. None of the figures corresponding to previous periods is indicative of future performance. Since the collective investment undertakings included on this Website invest in international markets, exchange rate fluctuations may positively or negatively affect any gains relating to an investment. Certain changes in taxes and tax reliefs may occur. The aforementioned taxes and tax reliefs always refer to those in force and their value will depend on each investor’s circumstances. Investments in emerging markets involve a high level of risk. Investments in the Funds must always be made taking into account the current Prospectuses, the Statements of Investment Policy Principles and the other documentation available for the Funds. The information contained on these pages does not form part of any type of contract, nor is it intended for the formalisation of a contract.
Before making any investment decision, you should obtain appropriate and specific professional financial, tax and legal advice. Likewise, before subscribing to any of our products, you must receive free of charge the documentation required by the legal provisions in force at any given time, which is available on this Website and also from NAO ASSET MANAGEMENT or at the offices of authorised distributors. This Website is not directed at any person in any country where, due to nationality, residence or any other circumstance, its availability or publication is prohibited or not permitted.

COPYRIGHT
The Website is owned by NAO ASSET MANAGEMENT SA SGIIC. The intellectual property rights and the rights of exploitation and reproduction of this Website, its pages, screens, the information contained therein, its look and feel and design, as well as its products and services, are the property of NAO ASSET MANAGEMENT, unless otherwise specified.
You may, at your own risk, download contents, copy or print any page of this Website (generally referred to as “Information”), but exclusively for your personal use and provided that you do not infringe the copyright or any other property right of NAO ASSET MANAGEMENT, nor change, modify or delete any Information, content or notices. Copying Information shall not be understood as an authorisation to transfer to you or to any person the property rights of NAO ASSET MANAGEMENT. You may not reproduce, transmit, modify, link to or make public use of the content of this Website, for any purpose, directly or indirectly, under any circumstances, without the prior written authorisation of NAO ASSET MANAGEMENT.

REGISTERED TRADEMARKS
The name and logo of NAO ASSET MANAGEMENT are registered trademarks and service identifiers. NAO ASSET MANAGEMENT may assert its rights over any trademark contained on this Website.
DISCLAIMER OF WARRANTY AND LIMITATION OF LIABILITY
All information and contents of the pages of this Website are subject to change by NAO ASSET MANAGEMENT without prior notice. This Website, the information contained herein, the links and the information obtained through them, or access to them, may be suspended, cancelled or restricted in any way, at any time, by NAO ASSET MANAGEMENT.
NAO ASSET MANAGEMENT considers that the information contained on this Website, as well as in the documents that may be viewed on it, is correct as of its date of publication; however, no warranty is given as to the accuracy, completeness, updating, exhaustiveness or suitability of such information. NAO ASSET MANAGEMENT hereby disclaims all liability for any damage arising from the use, error or omission of any part of this Website, to the extent permitted by law.

APPLICABLE LAW AND JURISDICTION
Access to and visit of the website, its use and these terms are governed by Spanish law and shall be interpreted in accordance therewith. The courts of Spain shall have exclusive jurisdiction over any dispute relating to the foregoing, without prejudice to NAO ASSET MANAGEMENT choosing any other jurisdiction for the dispute in question, in accordance with applicable law.

Privacy Policy

Information on Data Protection

PROCESSING OF PERSONAL DATA

NAO ASSET MANAGEMENT ESG SGIIC, S.A., with registered address at Valencia, Plaza Ayuntamiento 27, 7, 46002 (hereinafter, “NAO”), will be the Data Controller for your data.

NAO obtains clients’ personal data either directly from them or through the specific forms provided for that purpose, as well as browsing data when you visit our Website. During the course of our contractual relationship, the client may provide NAO with third-party data, such as legal representatives, shareholders, ultimate beneficial owners, beneficiaries or family members. In this regard, the client confirms that they have informed, and where applicable obtained the consent of, any other individuals whose personal data they supply to us.

NAO, as Data Controller, processes the personal data of its clients, their legal representatives, shareholders, employees, agents, or other collaborators for the following purposes:

1. Performance of the contractual relationship itself:

• To formalize the investment made through the client’s order.
• Management of the relationship, holding meetings, and communication by telephone and email.
• Payment management and monitoring of the contracted services.
• Furthermore, depending on the fund chosen, personal data will be communicated to third-party depositary entities.
• Handling queries, suggestions and complaints.

2. Compliance with a legal obligation:

• Processing arising from compliance with legal and tax obligations, which may entail disclosing data to different public administrations where required by applicable law.
• Likewise, as a consequence of anti–money laundering and counter–terrorist financing obligations, NAO will be obliged to carry out formal and real identification, and professional or business checks of the Client, for which it will collect the documentation necessary for that purpose.
• • Disclosure of clients’ personal data to entities directly or indirectly owned by Grupo Zriser, the details of which can be consulted at the following links: https://www.zriser.es/sector-industrial/ and https://www.zriser.es/sector-tecnologico/, for anti–money laundering and counter–terrorist financing measures.

3. Consent

• Only if the Client has authorized it, NAO may send you updates on funds and pension plans.

4. Legitimate interest

• NAO belongs to the Zriser Group (http://www.zriser.es) and, on the basis of legitimate interests, receives various internal administrative services from it.
• In order to prevent fraudulent conduct, NAO may disclose clients’ personal data to entities directly or indirectly owned by Grupo Zriser, the details of which can be consulted at the following links: https://www.zriser.es/sector-industrial/ and https://www.zriser.es/sector-tecnologico/

 

DISCLOSURE OF PERSONAL DATA

NAO may disclose personal data to: (i) regulatory authorities; and (ii) in order to prevent fraudulent conduct, personal data may be sent to the different companies of the NAO Group or to centralized information systems. Likewise, NAO has third-party service providers that may access personal data in the course of providing their services, such as auditors, consulting services, advisors, IT maintenance, potential purchasers or investors, administrative services, and document destruction, among others. NAO preselects such providers based on data protection compliance criteria, has entered into data protection agreements with all of them, and monitors their compliance with their obligations in this area.

NAO has a virtual infrastructure under a “cloud computing” model through two leading global market providers: Microsoft Corporation and Digital Ocean, complying with security measures to carry out these processing activities within and outside the EU under the applicable regulations, using Standard Contractual Clauses and/or adhering to the EU–US Data Privacy Framework. Likewise, NAO uses the email delivery program MailChimp by The Rocket Science Group LLC (Intuit) with the same safeguards.

 

RETENTION PERIOD FOR PERSONAL DATA

Personal data accessed will be processed for as long as the contractual relationship is maintained. In this regard, NAO will retain personal data, duly blocked, after the contractual relationship has ended, for the limitation period of actions that may arise from the relationship maintained with clients. In any case, NAO will retain the information required by the Anti–Money Laundering and Counter–Terrorist Financing regulations for a period of 10 years from the termination of the business relationship or the execution of the transaction.

Personal data of those who subscribe to the newsletter will be processed until they request to unsubscribe, at which time the data will be blocked for the three years set as the limitation period by data protection regulations.

Personal data collected through the contact form will be kept while your query is being handled. Once completed, the data will be blocked for the three years set as the limitation period by data protection regulations.

 

SECURITY MEASURES

NAO has security measures appropriate to personal data, so as to prevent its alteration, loss, or unauthorized processing or access, taking into account the state of the art, the nature of the data stored and the risks to which it is exposed, whether arising from human action or the physical or natural environment. Specifically, NAO undertakes to adopt, update and maintain all organizational and technical measures necessary to guarantee the security and confidentiality of personal data, preventing any alteration, loss, processing, or unauthorized access.

NAO will not apply or use personal data for any purpose other than that stated in this contract, nor disclose it, not even for storage, to other persons.

 

CONFIDENTIALITY AND DUTY OF SECRECY

The parties agree that any proprietary information, regardless of the medium on which it is contained, shall be considered confidential information, maintained under secret, confidential and restricted treatment, and shall be handled in accordance with the provisions of this contract.

NAO will ensure at all times that the aforementioned personal data are accurate, complete and up to date, are not used for purposes other than those related to this contract, and are kept in the strictest confidence.

 

EXERCISING DATA PROTECTION RIGHTS

The client may exercise the rights of access, rectification, erasure, objection, request the restriction of processing of their personal data, data portability, as well as not to be subject to automated individual decisions, with respect to the data provided at any time, by writing to NAO, Plaza Ayuntamiento 27, 7, 46002, Valencia or via the email address [dpd@informaconsulting.com](mailto:dpd@informaconsulting.com).

 

Before whom can you lodge your data protection complaints?

If the Client believes their data protection rights have been infringed or has any complaint regarding their personal information, they may contact NAO’s Data Protection Officer at the address indicated above. In any case, data subjects may contact the Spanish Data Protection Agency, the supervisory authority for data protection matters, https:www.aepd.es C/ Jorge Juan número 6, 28001, Madrid.

Cookie Policy

The social dimension encompasses the impact of the company’s activities on employees, customers, suppliers and, in a broader sense, society. In companies where human capital is crucial, such as consulting firms, advertising agencies or engineering firms, a favourable social policy mitigates operational risk.