Pre-contractual information

Pursuant to Article 165 of the Regulation adopted by Consob Resolution no. 20307/2018 (the “Intermediaries Regulation”), the following information is provided regarding RINASCIMENTO SCF S.r.l. (henceforth referred to as “RINASCIMENTO” or the “ADVISOR”) and the services it performs. The information contained in this document must be provided to the client or potential client before they are bound by an agreement for the provision of investment advisory services or, in any case, before such services are provided.

The recipient of this document is invited to read the following carefully before making any decision regarding the conclusion of an investment advisory agreement.

The Advisor is available to provide further information regarding the nature and characteristics of the investment advisory service.

  1. INFORMATION ABOUT THE FINANCIAL ADVISORY COMPANYTop of FormBottom of Form

Name: Rinascimento SCF S.r.l.

Registered Office: Cappuccio Street, 11 – 20123 Milano (MI)
Website: www.rinascimentoscf.com
Email: amministrazione@rinascimentoscf.com
PEC: rinascimentoscf@pec.rinascimentoscf.com
Phone: +39 02 366 85 388

Registered with resolution no. 2490 dated 23/05/2024 in the SCF section of the single register of financial advisors.

The name of the independent financial advisor who will provide investment advisory services on behalf of Rinascimento SCF S.r.l. is: Filomena Ilaria Petrella.

  1. LANGUAGE USED

The Client may communicate with the Advisor and receive documents and information from them in Italian.

  1. METHODS OF COMMUNICATION USED

The sending letters, information notes, statements, any notifications and any other declarations or written communications, including changes to the information contained in this Document, unless otherwise provided by law or contract, will be carried out for the Client with full effect at the address indicated at the time of signing the contract or subsequently communicated in writing.

The Client may choose, at the time of signing the contract for the advisory service or with subsequent written communication, to receive information on a durable medium other than paper, specifically via email. To this end, the Client will provide a valid and accessible email address exclusively for their use and commit to keeping it active (or to communicating in writing a different valid email address) for up to 14 months after the termination of the contract.

Communications and/or any notifications to the Advisor must be addressed by the Client to the headquarters of Rinascimento SCF S.r.l. or via certified email to the addresses indicated above.

The transmission of recommendations by the Advisor and the confirmation of the Client’s execution of transactions may be carried out using the following methods:

  • Mail (registered letter with acknowledgment of receipt)
  • Hand delivery
  • Internet communication platforms with user credentials specifically provided by the Advisor
  • Regular email to the address indicated in the contract
  • Certified email (PEC) to the address indicated in the contract
  1. REGISTRATION IN THE REGISTER PROVIDED FOR BY ARTICLE 18 TER OF LEGISLATIVE DECREE NO. 58 OF 24.2.1998

It is declared that Rinascimento SCF S.r.l. is registered in the section of the register referred to in Article 18 Ter of Legislative Decree of 24.2.1998 (TUF), maintained by the Supervisory Body provided for in Article 31, paragraph 4, of the aforementioned Decree, with resolution no. 2490 dated 23/05/2024.

The name and contact address of the Supervisory Body are: OCF – Via Tomacelli n. 146 – Cap 00186 – Rome.

  1. REPORTS ON THE EXECUTION OF THE ADVISORY SERVICE

RINASCIMENTO provides the Client with the following reports related to the provision of the advisory service:

  • Within 30 daysfrom the end of each quarter/semester/calendar year, a report containing the composition and performance of the Portfolio;
  • Within 60 daysfrom the end of the calendar year, a report containing:
    a) an updated statement indicating the reasons why the Portfolio aligns with the Client’s preferences, objectives, and other characteristics;
    b) the recommendations provided during the reference period;
    c) in aggregated form, the costs and charges of the service provided and of the Financial Products and services subject to recommendation.

 

  1. POLICY ON CONFLICTS OF INTEREST

Pursuant to Article 177 of the Intermediaries Regulation, RINASCIMENTO has adopted a Policy on Conflicts of Interest aimed at:

  • Identifying, in relation to the investment advisory service, the circumstances that generate or may generate a conflict of interest that could harm the interests of one or more clients, including their sustainability preferences;
  • Defining the procedures to follow and the measures to adopt to prevent or manage such conflicts.

The procedures and measures adopted are designed to identify and prevent conflicts of interest that may arise between the ADVISOR, including its managers, employees, Independent Financial Advisors, or persons directly or indirectly connected, and the Client, or between the Client and other clients of Rinascimento SCF S.r.l. at the time of providing the Service under this Contract, to ensure that such conflicts of interest do not negatively impact the Client.

If the measures adopted are not sufficient to avoid, with reasonable certainty, the risk of harming the Client’s interests, the ADVISOR will clearly inform the Client, on a durable medium, of the nature and general sources of the potential conflicts of interest arising from the recommendations provided, as well as the measures adopted to mitigate the related risks, to enable the Client to make an informed investment decision.

The Client may request RINASCIMENTO for further detailed information about the conflict of interest management policy using the contact details previously provided.

  1. SERVICES PROVIDED AND METHODS OF EXECUTION

RINASCIMENTO provides investment advisory services as per Article 1, paragraph 5, letter f) of the TUF, consisting of the “provision of personalized recommendations to a client, upon their request or on the initiative of the service provider, regarding one or more transactions related to financial instruments.”

Specifically, the services provided by the Company include:

  1. The analysis of the overall allocation of the Client’s Portfolio and the evaluation of the efficiency of the products held;
  2. The potential redefinition of the portfolio’s asset allocation and financial instruments/products held, based on the information provided by the Client;
  3. Periodic, annual evaluation of the adequacy of the Portfolio.

The personalized recommendations provided to the Client in the execution of the service may concern a wide range of financial instruments, falling under the following categories as reported in Annex 1, Section C, of the TUF:

  1. Securities.
  2. Units and shares of UCI (Undertakings for Collective Investment).

Customized recommendations may also concern financial products other than financial instruments, such as financial products issued by insurance companies or banks, as well as portfolio management services and order reception and transmission services.

RINASCIMENTO reserves the right to provide the ancillary services referred to in numbers 3 and 5 of Annex 1, Section B, of the TUF (Consolidated Law on Finance).

Non-customized recommendations are not provided.

Regarding additional professional activities carried out by Rinascimento, it is specified that they are not subject to the supervision of Consob or the Supervisory Body.

The aforementioned advisory activities are aimed at both retail and professional clients.

The advisor is not obligated to update recommendations provided to the client or to communicate losses incurred on the instruments recommended during the execution of the services.

The client is free to choose whether to proceed with the investment/disinvestment operations recommended under the terms of this contract.

The service may also be provided in locations other than the registered office of Rinascimento SCF S.r.l., using Independent Financial Advisors.

The Advisor is not authorized to execute the operations recommended to the Client, which must be carried out through authorized intermediaries (banks, SIM, SGR) within the scope of the investment services and activities provided by them.

As compensation for the provision of advisory services, the Client is required to pay the Advisor a fee commensurate with the content and value of the service.

In the absence of a standardized method for quantifying the fee, it may vary depending on the complexity and size of the assets under advisory, the objectives and risk profile of the Client, and, generally, the time the Advisor will dedicate to the analysis and study of the specific case. Therefore, the Advisor commits to providing the potential Client, after having received the necessary information summarized above, in a timely manner before the Client is bound by an agreement for the provision of advisory services, a customized fee estimate. Payment methods and terms will be indicated in the aforementioned estimate.

The fee paid by the Client constitutes, by law and contractual obligation, the sole form of compensation for the Advisor for the services provided to the Client; the Advisor is prohibited from receiving compensation (incentives) from third parties.

The Advisor is required, by professional ethics, to remain independent of the issuers of the recommended financial products, as well as of the intermediaries authorized to perform investment services in which the Client executes the recommendations.

As part of the advisory service, the Company cannot hold funds or securities belonging to clients.

The Client and the Advisor may agree that the Advisor is granted authorization to review the Client’s investments held with banks, financial intermediaries, or asset management companies used by the Client, without any authorization to operate. They may also agree that these investment companies send the Advisor information on the operations executed by the Client.

For more information about the content of the advisory service and the obligations of the Advisor and the Client, please refer to the investment advisory contract, which must be signed before the provision of the service.

  1. PERIODIC ASSESSMENT OF SUITABILITY

As part of the investment advisory service, the Advisor provides the Client with recommendations regarding investment or disinvestment operations that, if executed, ensure the suitability of the Portfolio in relation to the Client’s profile, reconstructed based on the information provided through the completion of the Questionnaire submitted before the conclusion of this contract or during any subsequent updates. Specifically, the Advisor verifies that the recommended operation:

  • Aligns with the Client’s investment objectives, including their risk tolerance;
  • Is of a nature such that the Client is financially capable of bearing the risks associated with the investment, compatible with their investment objectives;
  • Is of a nature such that the Client possesses the necessary knowledge to understand the risks associated with managing their portfolio.

The Advisor conducts a periodic suitability assessment of the Portfolio on an ANNUAL basis.

The suitability assessment is carried out to enable the Advisor to act in the best interest of the Client. It is, therefore, essential that the Client, by completing the Questionnaire provided by the Advisor, supplies accurate and up-to-date information concerning:

  • Their knowledge and experience in investments regarding the specific type of product or service;
  • Their financial situation, including their capacity to bear losses;
  • Their investment objectives, including their risk tolerance;
  • Their sustainability preferences.

The Client is required to notify the Advisor of any updates to their information.

These updates allow the Advisor to understand the Client’s essential characteristics and recommend financial products and investment services that are appropriate, particularly in reference to their risk tolerance, capacity to bear losses, and sustainability preferences. If the Client fails to provide the information requested in the Questionnaire, the advisory service cannot be provided.

Failure to update information may compromise the reliability of the suitability assessment and reduce the Client’s level of protection. The Advisor is required to refrain from making recommendations if none of the financial products or investment services are suitable for the Client.

  1. INTEGRATION OF SUSTAINABILITY FACTORS

Pursuant to Article 165, paragraph 1, letter h-bis of the Intermediaries Regulation, in the process of selecting financial instruments subject to the investment advisory service, Rinascimento SCF S.r.l. integrates an assessment regarding environmental, social, and governance (ESG) sustainability factors. This ensures that various products and instruments can only be recommended to clients who express sustainability preferences compatible with the characteristics of those instruments.

Since the advisory service provided by Rinascimento SCF S.r.l. concerns the financial portfolio as a whole, the evaluation of sustainability factors is carried out at the portfolio level. This means that the portfolio, in its entirety, must align with the client’s sustainability preferences, although it is possible that, for risk management purposes or to achieve the client’s objectives, certain individual instruments used may not individually align with the client’s preferences.

The evaluation of the environmental, social, and governance sustainability characteristics is conducted based on the type of instrument/product, using information declared by the issuer in compliance with current regulations or by employing external evaluation models (ratings) and/or analyses conducted internally.

  1. OTHER PROFESSIONAL ACTIVITIES CARRIED OUT BY RINASCIMENTO SCF S.r.l.

Rinascimento SCF S.r.l. provides the following additional activities beyond the investment advisory service:

  • Advisory services for the evaluation and coverage of pension integration needs
  • Advisory services for the identification and quantification of household risks
  • Advisory services for personal and family financial planning
  • Advisory services for family succession planning

These activities, although personalized, do not concern specific financial instruments or financial products.

The execution of the aforementioned activities is governed by a specific contract, separate from the investment advisory service, and requires the payment of a fixed or variable fee, agreed upon with the client, commensurate with the content and value of the service provided.

Only the activities listed above, which do not fall within the scope of ancillary services, are excluded from the supervision of the Supervisory Body.

  1. PROPOSED INVESTMENT STRATEGIES

In providing its advisory service, Rinascimento SCF S.r.l. is not oriented towards specific categories or a particular range of financial instruments.

Rinascimento SCF S.r.l. does not propose standardized investment strategies but evaluates the most suitable strategy for each Client, taking into account the Client’s investment objectives, risk tolerance, and financial situation, including their capacity to sustain losses.

ACF INFORMATION

The Client may file a complaint with the Financial Disputes Arbitrator (ACF), established by CONSOB, for the out-of-court resolution of disputes between investors (other than professional clients) and independent financial advisors, as well as financial consulting companies, regarding the obligations of diligence, fairness, information, and transparency in performing the activities governed by Articles 18-bis and 18-ter of the TUF (Consolidated Law on Finance). These include disputes falling under Part II of the TUF and disputes subject to Regulation (EU) no. 524/2013.

Disputes involving monetary claims exceeding 500,000 euros are excluded from the Arbitrator’s jurisdiction. Additionally, the Arbitrator does not handle damages that are not the direct result of a non-fulfilment or violation by intermediaries of the above-mentioned obligations or damages that are not of a financial nature.

The right to appeal to the ACF is irrevocable and can always be exercised, even in the presence of clauses in the contract assigning disputes to other out-of-court resolution bodies.

For more information, please refer to the website:
https://www.acf.consob.it/