RÉGULATION

The information contained in this document is intended to comply with the provisions – applicable to the activity described in section 2. – of the Monetary and Financial Code and the texts adopted (including the general regulations of the Autorité des Marchés Financiers).

1. DEFINITIONS
In this document, the following words mean:
Exoé: Exoé SAS.
Client: All customers or prospects of Exoé.
Service: Any financial product or investment service offered or provided by Exoé to one of its clients.
Sustainable support: A durable medium is a letter or any medium considered durable by a written agreement of the Customer.

2. AGREEMENT AND EXOE ACTIVITY
Exoé is an investment firm authorized by the ACPR (Autorité de contrôle prudentiel et de resolution), an independent administrative authority backed by the Banque de France, under the number 17873 dated 5 March 2007.

Exoé is authorized for the following investment services:

  1. Receipt -Transmission of orders for third parties for the following financial instruments: Capital securities issued by companies per share; Debt securities, Units or shares of collective investment undertakings, Financial futures, Other foreign financial instruments.
  2. Investment Advisory

This approval is available on the ACPR / Banque de France website following the link:

Http://acpr.banque-france.fr/agrements-et-autorisations/registres-et-listes/regafi-and-liste-des-agents-financiers.html, under the heading – List of investment services providers (Excluding establishments covered by Article L.531-2 of the Monetary and Financial Code).

Exoé SAS, a simplified joint-stock company with a capital of 553,500 euros
Headquarters: 6, rue de Lisbonne 75008 Paris
N ° SIREN RCS PARIS
Contact information :
Telephone: 33 (1) 80 50 59 59 – address: contact@exoe.fr
Website: http://www.exoe.fr
All these details can be used to obtain, upon request, information deemed to be available from Exoé. Exoé markets its services mainly in France and communicates exclusively in French to its customers.
Any material changes to the information contained in this document that affect the service will be communicated on a durable medium.

3. RULES OF CONDUCT
Exoé is a member of the French association AMAFI, a French association for financial markets. It acts in an honest, fair and professional manner that best serves the clients’ interests and promotes market integrity.
In accordance with the laws and regulations in force relating to professional secrecy, Exoé respects the obligations of confidentiality of the information transmitted to it.

4. COMPLIANCE AND CONTROL DEVICE, TREATMENT OF CLAIMS
Exoé has set up a system and an organization that independently controls the proper exercise of the service. This system, through appropriate procedures, aims to detect risks of non-compliance with professional obligations and minimize the consequences.
In accordance with applicable regulations, EXOE makes a commitment to acknowledge receipt of your request within ten working days and to send a response within a maximum of two month delay starting at the date of  reception. Otherwise, EXOE makes a commitment to inform you of the progress of the treatment of your complaint ans possible causes of delay.

In case of complaint, you can contact EXOE by sending a mail to the following address:

Exoé Cellule RCSI – Complaint
6, rue de Lisbonne
75008 Paris

by e-mail at the following address: rcsi@exoe.fr
(by mentioning in the object: “Complaint”)

5. POLICY FOR THE MANAGEMENT OF CONFLICTS OF INTEREST
A conflict of interest arises when a situation could affect the interests of one or more clients. In order to prevent potential conflicts of interest in the best possible way, Exoé has drafted a policy in this area. This policy, available from Exoé, aims to detect such conflicts and to neutralize them through appropriate measures. If Exoé fails to neutralize a conflict of interest, he would inform his clients on a durable basis.

6. DATA CONSERVATION
Without prejudice to any other rules that may be applicable, all data necessary for the provision of the service to the customer shall be retained for a minimum period of five years or for the duration of the relationship with the customer. They are held at the disposal of the AMF, which may consult them with the aim, inter alia, of controlling Exoé’s compliance with its professional obligations or respect for the integrity and transparency of the financial markets.
In accordance with Article 39 et seq. Of the law n ° 78-17 of 6 January 1978 relating to data processing, files and freedoms, any person may obtain communication and, where appropriate, rectification or deletion of information concerning him.

7. KNOWLEDGE AND CATEGORIZATION OF CUSTOMERS, SUITABILITY AND APPROPRIATE CHARACTER OF THE SERVICE
Exoé must have a good knowledge of his clients. To this end, the documentation comprising the framework contract, its annexes and the questionnaire “KYC Know your Client” make it possible to achieve this objective.
The purpose of this questionnaire is to provide the basis for determining the categorization of Exoé’s customers and prospects by decreasing degree of protection: non-professional client, professional client, eligible counterparty. This categorization is communicated to the customer on a durable medium. Exoé says it does not have the infrastructure to provide service to non-professional customers.
Finally, this questionnaire is the information base that allows Exoé to test the suitability of the service with the financial capacity and objectives of the client and to evaluate the suitability of the service for the general situation of the client. As part of the delivery of the RTO service, its suitability only is subject to this assessment.
The tax treatment of the service depends on the individual situation of each customer and is subject to change. It is up to each client to inquire about the applicable tax system.

8. DELEGATES, EXTERNALIZATION OF THE SERVICE AND PARTNERS
Exoé may contractually delegate or outsource some of the tasks related to the provision of the service. These contracts do not exempt Exoé from its responsibilities in this matter and are the subject of a formal control by Exoé. The list of delegated or outsourced missions and the delegated or outsourcing companies is available from Exoé.

9. INFORMATION
The provision of the service is the subject of the signature of a written agreement between Exoé and its customers.
Exoé informs its customers without delay of the execution status of the orders which are sent for transmission.

10. FEES, REMUNERATION AND BENEFITS
All costs incurred by Exoé are set out in the agreement between Exoé and its customers for the provision of the service. Exoé may pay commissions to third parties other than its clients for the service provided to its customers. The details of these remunerations are available from Exoé. Exoé does not receive or provide its customers or third parties non-monetary benefits in connection with the service.

11. POLICY FOR THE EXECUTION OF ORDERS AND SELECTION OF INTERMEDIARIES
Exoé’s order execution policy is limited to a policy of selecting intermediaries responsible for executing orders. The agreement binding Exoé to its customers may provide for constraining the selection by criteria specific to the customer. The order execution policy is available from Exoé