Dear Client,
Pursuant to Section 16A of the Regulation of the Practice of Investment Advice, Investment Marketing and Investment Portfolio Management Law, 5755-1995 (the "Law"), Altshuler Shaham Investment Portfolio Management Ltd. (the "Company"), a company licensed as an investment portfolio manager, is a member of the Altshuler Shaham Group (the "Investment House"). The Investment House is engaged, directly and indirectly, in a variety of activities in the capital market, including transactions in securities and financial assets, investment in assets for others and for itself, investment portfolio management, mutual funds, hedge funds, provident funds, study funds, pension funds, and additional activities in the capital markets in and outside of Israel.
The Company hereby informs that it is an affiliate of an institutional entity, within the meaning thereof in the Law, namely Altshuler-Shaham Mutual Funds Management Ltd. (the "Fund Manager") and Altshuler Shaham Provident and Pension Ltd. In addition, the Company is an affiliate of Altshuler Shaham Finance Ltd., a public company whose shares are traded on the Tel Aviv Stock Exchange; Altshuler Shaham Financial Services Ltd. (holder of an investment marketing license); Laya Global Ltd.; Altshuler Shaham Properties Ltd.; Altshuler Shaham Real Estate Ltd.; Altshuler Shaham Credit Ltd.; Altshuler Shaham Credit for Businesses Ltd.; Horizon Digital Assets Ltd.; Altshuler Shaham Alternative Ltd.; Altshuler Shaham Alternative Funds Ltd.; Altshuler Shaham Trade Ltd.; Altshuler Shaham Finance – Pension Insurance Agency Ltd.; Altshuler Shaham Pension Guidance – Pension Insurance Agency Ltd.; Altshuler Shaham Insurance Agency Ltd.; Altshuler Shaham Global Opportunities Ltd.; iFunds Capital Ltd., and corporations managing hedge funds and/or investment funds that are owned by Altshuler Shaham (jointly: the "Affiliated Entities"). Therefore, the Company has an affiliation with the above entities and with the products managed by them, including an affiliation with the mutual funds managed by Altshuler-Shaham Mutual Funds Management Ltd., with the Fund Manager and with the provident funds (including investment provident funds, “Savings for Every Child,” study funds) and the pension funds managed by Altshuler Shaham Provident and Pension Ltd.
As a portfolio manager engaged in investment portfolio management and investment marketing (and not in investment advice), as these terms are defined in the Law, the Company may, as part of its investment marketing or investment portfolio management activities, as applicable, give preference to a financial asset with which it has an affiliation over another asset that is similar in terms of its suitability for the Client and with which it has no such affiliation, provided that it has complied with any and all disclosure requirements vis-à-vis the Client. Such affiliation of an investment marketer or a portfolio manager with a financial asset shall not be deemed a conflict of interest between it and the Client.
Accordingly, the Company hereby notifies that it has an affiliation with financial assets that are managed and/or issued and/or offered and/or marketed by the Affiliated Entities, as detailed and updated from time to time on the Investment House’s website at: www.as-invest.co.il.
and that the Company may receive a benefit in connection with the performance of a transaction in such financial assets, or in connection with their continued holding, or in connection with their marketing.
It is further clarified that:
1. In respect of an investment in units of the mutual funds managed by Altshuler-Shaham Mutual Funds Management Ltd., management fees are charged by Altshuler-Shaham Mutual Funds Management Ltd., as detailed in the prospectus or in the mutual fund’s annex released to the public and in the immediate reports.
2. The Affiliated Entities and/or companies controlled by the Company’s controlling shareholder, by virtue of the Investment House’s activities and/or the activities of the individual companies in the capital markets, perform transactions in securities and/or financial assets in which the Company also performs transactions.
