Bellecapital International AG

Item 5. Fees and Compensation
recommendations to clients, including                             Bellecapital generally charges fees for its services
recommendations regarding the purchase or                         as a percentage of the market value of assets
sale of securities, investment strategies, or                     under management (“AUM”) or assets under
rollovers from employer-sponsored retirement                      advisement (“AUA”). The asset management fee is
plans to IRAs.                                                    charged quarterly in arrears. AUM or AUA is
In connection with such advice, Bellecapital relies               measured with reference to the last calendar day
on Prohibited Transaction Exemption 2020-02,                      of the month of the respective calendar quarter.
which permits Bellecapital to receive certain                     The fee generally is charged in Swiss Francs. If the
forms of compensation that may otherwise be                       reference currency of the account is different
considered conflicted, provided that Bellecapital                 from Swiss francs, the fees will be converted into
complies with applicable conditions. These                        Swiss francs by applying the closing FX rate of the
conditions include adherence to the Impartial                     reference currency against Swiss franc at the end
Conduct Standards, which require the Firm to: (i)                 of each quarter. The closing FX rate is based on
act in the best interest of the client; (ii) charge no            Bloomberg or any other recognized data source
more than reasonable compensation; and (iii)                      deemed appropriate by Bellecapital. For Swiss
make no materially misleading statements                          and Liechtenstein residents the VAT will be
regarding investment transactions or other                        invoiced in addition to the fees.
relevant matters.                                                 Bellecapital is a fee-only investment adviser and
Bellecapital has adopted policies and procedures                  does not receive undisclosed remuneration from
reasonably designed to ensure compliance with                     third parties in connection with its investment
these fiduciary obligations, to mitigate conflicts                advisory services. Discounts, finder’s fees or any

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other remuneration received by Bellecapital from                  broker or National Authorities. Bellecapital’s fees
third parties will be disclosed to the client and                 do not include management or other fees
credited against Bellecapital’s investment                        charged by funds or other products that client
advisory fees. Bellecapital does not manage or                    accounts may be invested in from time to time. It
advise accounts based on commissions,                             is Bellecapital’s philosophy to generally invest in
subscriptions fees, or hourly rate charges.                       the most favorable share class with the least cost.

Investment in affiliated investment vehicles                      Fees for Discretionary Portfolio Management

The portion, which is invested in the affiliated                  The following fee schedule generally applies for
investment vehicle is excluded from the normal                    Bellecapital’s discretionary portfolio management
fee calculation. With this procedure Bellecapital                 service:
ensures that the adviser does not earn two fees
                                                                     From USD          To USD        Annual Fee
for the same investment.                                             5,000,000       10,000,000        1.00%
                                                                     10,000,001      20,000,000        0.80%
If Bellecapital invests client assets in an                          20,000,001      50,000,000        0.70%
investment vehicle affiliated with Bellecapital, we                  50,000,001      100,000,000       0.60%
                                                                    100,000,001     250,000,000 +      0.50%
may earn a higher fee than you normally pay. In
such case the fee is fully disclosed in the vehicle’s
documentation and is independent from the                         The applicable fee rates are applied on a tiered
separate managed account fee. The firm has a                      basis to each portion of the account value within
policy prohibiting double charging.                               the corresponding asset level.

                                                                  Bellecapital, however, retains the right to charge
Compensation owed to Bellecapital is not payable
                                                                  flat fees or lower fees than the fees displayed in
in advance. In all cases, Bellecapital may waive,
                                                                  the schedule. A flat fee can be a fixed percentage
discount or negotiate fees at its discretion.
                                                                  of the AUM or, exceptionally, a fixed amount
Bellecapital relies on custodian banks of its clients             agreed upon with the client.
to value the assets in the respective client
                                                                  Eligible clients have a choice either to pay
accounts, and Bellecapital computes its
                                                                  Bellecapital based on the above fee schedule, or
investment advisory fees based on these
                                                                  a fee with a performance-based component
valuations provided by the custodian bank. In
...

Item 7. Types of Clients
according to the same or a substantially similar
                                                                  Bellecapital offers investment management
investment strategy and yet have a different fee
                                                                  services to high-net-worth and ultra-high-net-
schedule applicable to such accounts as a result
                                                                  worth individuals and families and their
of the respective clients’ AUM with Bellecapital or
                                                                  foundations, trusts, estates, holding companies,
a client’s election to compensate Bellecapital on a
                                                                  individual retirement accounts (Traditional IRA
performance basis.
                                                                  and Roth IRA) and accounts for minors (UTMA)
Side-by-side management of different types of                     and other estate planning structures.
accounts may raise conflicts of interest when two
                                                                  In addition to serving US resident clients,
or more accounts invest in the same securities or
                                                                  Bellecapital provides discretionary and non-
pursue a similar although not identical strategy.
                                                                  discretionary investment advisory services to
These potential conflicts include the favorable or

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non-US resident clients. The provisions of the                   forecasts,    market,     data    and    sector-specific
Advisers Act do not apply to the management                      reports.
services provided by Bellecapital to these non-US
                                                                 Investment Strategies
clients. This brochure describes only the service
offering to US persons as defined under SEC Rule
                                                                 The investment strategies used to implement
902.
                                                                 investment advice given to clients by Bellecapital
Generally, Bellecapital prefers its client                       include long and short-term securities purchases,
relationships to have a minimum of $5,000,000 of                 trading, margin transactions and option writing,
assets under management. However, Bellecapital                   including covered options, uncovered options or
retains the right to accept accounts below the                   spreading strategies. Bellecapital’s investment
minimum requirements and will retain accounts                    strategies seek to maximize investment return
that have dropped below the minimum                              potential by profiting from upswings in macro-
requirement due to market fluctuation or                         economic        cycles:      productivity    cycles,
investment performance. Related accounts can                     demographic cycles, business cycles, profit cycles,
be aggregated.                                                   interest rate cycles, valuation cycles and currency
                                                                 cycles.