Valeur Fiduciaria Sa

Item 5. Fees and Compensation                           interest between Valeur and its clients. Valeur has
                                                        an incentive to recommend investment products
Valeur’s fees generally are charged as a percentage     based on the compensation Valeur will receive
of the market value of assets under management          rather than based on each client’s needs. Thus,
(“AUM”) or assets under advisement (“AUA”). The         Valeur is not always impartial with respect to its
fee is charged quarterly in arrears. AUM or AUA is      investment recommendations. Further, Valeur
measured with reference to the average of the           generally does not inform its clients of the receipt
closing balances for the last business day of each      of indirect compensation. Valeur seeks to minimize
month within the respective calendar quarter.           this conflict of interest by limiting the amount of
                                                        indirect compensation it will receive on an annual
The maximum annual fee for discretionary and            basis to no more than 1% of the AUM or AUA of
nondiscretionary mandates is 1.5% of AUM or             each client’s portfolio. To the extent that Valeur
AUA. It depends on the size and complexity of the       receives indirect compensation in excess of this
mandate.                                                cap, Valeur will credit the respective client’s
                                                        account with such additional amount. Further, if
There is no minimum annual fee.                         asked by the client, Valeur agrees to disclose
                                                        indirect compensation it receives in relation to the
Compensation is not payable in advance. Accounts        client’s account as is reasonably practical (in
initiated or terminated during a calendar quarter

March 21, 2019                                                             Valeur Fiduciaria SA, CRD: 284243

certain cases, it is difficult to apportion indirect   conflict, Valeur generally will enter into a
compensation paid without reference to a specific      performance fee arrangement upon the request of
account to a particular client). Clients generally     a client or in the case of specific investment
have the option to purchase investment products        performance objectives.
that Valeur recommends through agents or
brokers whereby Valeur would not receive indirect      A combination between asset-based fee and
compensation.                                          performance-based fee is possible.

Other fees and expenses you may incur                  Side-by-Side Management

Fees charged by Valeur do not include custodian        Valeur manages many client Accounts and as a
fees, fees for trade settlement, brokerage             result of differences in the fees charged on various
commissions, or any other fee imposed by the           account, Valeur has conflicts related to such side-
custodian bank or the broker. The fees also do not     by-side management of different accounts. For
include management or other fees charged by            example, Valeur may manage more than one
funds or other products that client Accounts may       account according to the same or a substantially
be invested in from time to time.                      similar investment strategy and yet have a
                                                       different fee schedule applicable to such account

Item 7. Types of Clients                                depending on his or her investment profile, which
                                                        as described in Section 4 above, is determined in a
Valeur offers investment management services to         discussion with the Client at the beginning of the
individuals, high net worth individuals and their       Client relationship and is based among others on
foundations, trusts or other estate planning            his or her personal loss capacity, investment
structures. In addition Valeur offers its services to   objectives, knowledge and experience. Valeur
businesses and institutional clients.                   offers five different investment strategies (“Fixed
                                                        income”,      “Income”,     “Dynamic      income”,
In addition to serving US resident clients, Valeur      “Balanced”, “Growth”) differentiated depending
provides its services to non-US resident clients.       on risk tolerance and investment targets.
The provisions of the Advisers Act do not apply to
the investment services provided by Valeur to           Clients also have the possibility to define their own
these non-US clients. This brochure describes only      strategy with their individual parameters for the
the service offering to US persons as defined under     asset class allocation.
SEC Rule 902.
                                                        Types of Securities
Generally, Valeur prefers its client relationships to
                                                        Valeur offers investment management and
have a minimum of $ 1 million of AUM or AUA.
                                                        advisory services on the following types of
Valeur may accept Accounts below the minimum
                                                        securities and transactions: exchange-listed
requirements, or may retain Accounts that have
                                                        securities, securities traded over-the-counter,
dropped below the minimum requirement due to
                                                        securities issued by non-US issuers, corporate debt
market fluctuation or investment performance.
                                                        securities (and other commercial paper),
Accounts that have family, corporate, or other
                                                        certificates of deposit, investment company
relationships may be aggregated for purposes of
                                                        securities such as mutual funds, U.S. or foreign
the minimum account size.
                                                        government securities, exchange traded funds,
                                                        foreign exchange transactions, certain derivatives