This disclaimer is made in accordance with Luxembourg laws and regulations and is without prejudice of specific additional mentions as may be required by local applicable rules.

WEBSITE’S PURPOSE: INFORMATION

This website is exclusively an information tool and therefore does not constitute an offer or a solicitation of shares or investment services. Its purpose is to present the main features of BANOR SICAV (the “Fund”), a Luxembourg Investment Company (Société d’investissement à capital variable) incorporated for an unlimited duration in Luxembourg on 13 February 2007. The Fund is organised in accordance with the provisions of the law of 10 August 1915 on commercial companies, as amended, and the law of 17 December 2010 on Undertakings for Collective Investment, as amended (the “2010 Law” or “UCI Law”). In particular, it is subject to the provisions of Part I of the 2010 Law specific to undertakings for collective investment in transferable securities (UCITS) as defined in the Directive of the Council of the European Community of 13 July 2009, as amended (directive 2009/65/EC). The Fund’s registered office is located 19-21, route d’Arlon, L-8009 Strassen, Grand Duchy of Luxembourg. The Fund is registered with the Registre de Commerce et des Sociétés de Luxembourg under number B 125 182.

LIABILITY

Information contained herein is provided by Altum Management Company (Luxembourg) SA. The Fund has appointed Altum Management Company (Luxembourg) SA (the “Management Company”) as its Management Company to be responsible on a day-to-day basis, under supervision of the Fund’s Board of Directors, for providing administration, marketing and investment management services in respect of all sub-funds.

The Management Company was incorporated on 6 August 2018 as a société anonyme under Luxembourg law for an indeterminate period and is registered with the Luxembourg Trade Register under number B 226 846. The last version of the articles of incorporation of the Management Company have been published in the RESA on 30 May 2024. The Management Company has a fully paid-up share capital of EUR 11,425,000.

The Management Company is approved as management company regulated by chapter 15 of the 2010  Law (the “UCI Law”) and CSSF Circular 18/698 . The Management Company is also authorized and licensed as alternative investment fund manager with the CSSF.

The Management Company endeavours to keep the information contained herein up to date and correct. However, it makes no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, products, services, or related graphics contained on the website for any purpose. Any reliance you place on such information is therefore strictly at your own risk.

Furthermore, every effort is made to keep the website up and running smoothly. However, the Management Company takes no responsibility, and will not be liable for, the website being temporarily unavailable due to technical issues beyond its control.

ACCESS

Any investment carried out in the Fund shall be made pursuant to the legal documentation in force authorised by the Luxembourg Supervisory Authority, the Commission de Surveillance du Secteur Financier (Prospectus, and the Key Information Document (KID) as the case may be) as well as pursuant to the articles of incorporation and the semi-annual and annual reports of the Fund. All these documents can be obtained free of charge at the Fund’s registered office; they may also be freely downloaded from the present website.

The information contained herein is not intended for persons residing in countries where the fund is not authorized for marketing.

Any person under restraint, such as American nationals, shall not be granted access to the information contained herein.

Investors are sole responsible of their compliance with the law and regulations of their countries of citizenship or residence and they are recommended to take advice from their legal, financial and tax counsels prior to any decision.

RISK WARNING

The Net Asset Value per share may fall as well as rise and hence, on redemption of shares, investors may receive back an amount less than the original amount of their investment. Past performance is not a reliable indicator of future results. The performance reported is net of management fees and administration expenses, but gross of initial sales charges and taxes. Any performance figures given on this website rely on figures denominated in the currency indicated. Where this currency is different from the currency in the country in which you are resident, the return illustrated may increase or decrease as a result of currency fluctuations. The benchmarks have been chosen with the sole purpose of monitoring the performance of the various portfolios.

Euro denominated shares, issued for Portfolios whose reference currency is different from the Euro, are systematically hedged against the exchange risk compared to the reference currency of the relevant Portfolio; such hedging may, for technical reasons, not be complete and not cover the entire exchange risk. Moreover, in case of hedging, the investors will not take advantage of any possible positive evolution of the exchange rate.

MONEY LAUNDERING

The Management Company and the Fund strictly comply with rules purporting to the fight against money laundering and terrorist financing. ”), including in particular with the Luxembourg law of 12 November 2004 on the fight against money laundering and terrorist financing, as amended (the “2004 Law”), the CSSF Regulation 12/02 and further implementing regulations and CSSF circulars or other guidance by the competent authorities in the field of AML/CFT, adopted from time to time (collectively referred to as the “AML/CFT Regulations“).To comply with such requirements, you shall be requested to supply with proper identification documents and information by carrying out your investment.

PROHIBITION OF «LATE TRADING» AND «MARKET TIMING» PRACTICES”

Late Trading” is to be understood as the acceptance of a subscription or redemption orders after the cut-off time on the relevant Valuation Day and the execution of such orders at the price based on the net asset value per share applicable to such Valuation Day. To deter such practice, the Board of Directors of the Fund takes the necessary measures to prevent that subscriptions or redemptions be accepted after the cut-off time in Luxembourg and that the net asset value per share is calculated after the cut-off time (“forward pricing”).

The repeated purchase and sale of shares designed to take advantage of pricing inefficiencies in the Fund –also known as “Market Timing”-may disrupt portfolio investment strategies and increase the Fund’s expenses and adversely affect the interests of the Fund’s long term Shareholders. To deter such practice, the Board of Directors of the Fund reserves the right, in case of reasonable doubt and whenever an investment is suspected to be related to Market Timing, which the Board of Directors of the Fund shall be free to appreciate, to suspend, revoke or cancel any subscription, redemption or conversion order placed by investors who have been identified as doing frequent subscriptions and redemptions in and out of the Fund.

The Board of Directors of the Fund, as safeguard of the fair treatment of all investors, may take necessary measures to ensure that (i) the exposure of the Fund to Market Timing activities is adequately assessed on an ongoing basis, and (ii) sufficient procedures and controls are implemented to minimise the risks of Market Timing in the Fund.

PERSONAL DATA

Personal data or information supplied by the shareholders will be stored and processed in compliance with the provisions of  the EU Regulation n°2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (the “GDPR”) and (ii) any applicable national data protection laws (including but not limited to the Luxembourg law of 1st August 2018 on the organization of the National Data Protection Commission and the general data protection framework, as amended from time to time) (collectively hereinafter the “Data Protection Laws”).

Nevertheless, users of the present website are informed that the Internet network does not constitute a safe mean of communication and that they are using this network at their own risk.

In no event will the Management Company or the Fund be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of, or in connection with, the use of this website.

Furthermore, through this website you may be able to link to other websites which are not under the control of the Management Company. The Management Company has no control over the nature, content and availability of those sites. The inclusion of any links does not necessarily imply a recommendation or endorse the views expressed within them.

COPYRIGHTS

The Management Company and/or the Fund hold copyrights on all work appearing on this website, in particular pictures, texts, iconographic representations and documents which may be obtained from this website.

The copy and use of all or part of the present website, by any mean whatsoever, is strictly forbidden without the Management Company’s prior written approval.

Pages and/or parts of this website may nevertheless be downloaded or printed for personal use only subject to the disclosure of copyrights and intellectual property references.

The present website shall not be reproduced (in part or in whole), transmitted (by any means, including electronic), modified nor used for public or commercial purposes. No links to the present website shall be created without the prior written approval of the Management Company and/or the Fund.