Migliora Srl through its portal 2meet2biz:
- shall act with diligence, fairness and transparency, avoiding that any conflicts of interest which may arise in the performance of the activity of management of the Portal negatively affect the interests of investors and of the Offerors and ensuring the equal treatment of the recipients of the Offers who are in identical conditions
- makes available to investors, in a detailed, correct, clear, non-misleading and non-obscure manner, all information concerning the Offer which is provided by the Offeror so that they may reasonably and fully understand the nature of the investment, the type of financial instruments offered and the risks associated with them and make investment decisions in an informed manner;
- draws the attention of investors other than professional investors to the desirability that investments in high-risk financial assets are adequately proportionate to their financial resources. Migliora S.r.l. does not disseminate information that is inconsistent with the information published on the Portal and refrains from making recommendations regarding the financial instruments covered by the individual Offers that could influence the performance of the acceptances;
- draws the attention of investors to the limits imposed by Article 2412 of the Italian Civil Code on the issue of bonds by joint-stock companies and by Article 2483 of the Italian Civil Code on the issue of debt securities by limited liability companies, as well as to any further limits imposed by the applicable special rules;
- ensures that the information provided through the Portal is up-to-date, accessible for at least twenty-four months following the closing of the Offers and made available to interested parties who so request for a period of five years from the closing date of the Offer
- ensures that investors other than professional investors have the right to withdraw from the order, free of charge, by means of a communication addressed to the Manager, within the time limits provided for, as the case may be, by the Consob Regulations or the Consumer Code, starting from the date of the order;
- with the exception of investments made by the persons referred to in Article 24, paragraph 2-quater, letter c), the Manager shall verify, for each order to subscribe for the Offers received, that the client has the level of experience and knowledge necessary to understand the essential characteristics and the risks involved in the investment, on the basis of the information provided pursuant to Article 15, paragraph 2, letter b). If the Manager considers that the instrument is not appropriate for the Offeror, he shall warn him of this situation, also by means of electronic communication systems;
- directly performs the suitability check provided for by the Consob Regulations without resorting to authorised intermediaries by verifying online, by means of a special questionnaire, which will be submitted to the investor as part of the procedure for placing orders to accept the Offers, that the investor has the level of experience and knowledge necessary to understand the essential characteristics and the risks involved in the investment, on the basis of the information provided pursuant to Article 15, paragraph 2, letter b) of the Consob Regulations. This information refers to
- the types of services, transactions, including those carried out through online portals, and financial instruments with which the investor is familiar;
- the nature, volume and frequency of transactions, including through on-line portals, in financial instruments carried out by the investor and the period during which these transactions were carried out;
- the level of education, the profession, or if relevant, the previous profession of the investor
As mentioned above, if the Manager considers that the instrument is not appropriate for the customer, the Manager shall warn the customer of this situation, including by means of electronic communication systems.
Warnings on the assessment of appropriateness to be known by the investor
The assessment of the appropriateness of investors' orders for the subscription of financial instruments on the 2meet2biz portal, which is carried out in the interest of the investor, is one of the mechanisms for the protection of users of the Portal provided for in Consob Regulation 18592/2013 (hereinafter, the "Regulation"), and consists of verifying that the investor has the level of experience and knowledge necessary to understand the risks involved in the financial instrument he intends to purchase.
Through the assessment of appropriateness, the Manager verifies that the investment is in line with the characteristics of knowledge and experience of the investor resulting from the answers provided to the appropriate questionnaire.
The information collected before the investment is made is valid for 1 year and can be updated at any time directly online in the private area of the user's personal profile.
In the event that the investor does not fill in the questionnaire again at the end of the year, the Manager will automatically send an e-mail to the investor informing him that if he wants to make new investments he will have to fill in a new questionnaire.
More specifically, the Investor, before placing orders on the Portal, is required to:
- to view the investor education information provided for in Article 14(1)(k) and the information specified in Article 15(1) of the Consob Regulation;
- declare that they are in a position to bear the entire loss, if any, of the investment they intend to make;
- provide information on their knowledge and experience of investments through a questionnaire prepared by the Manager.
In particular, this questionnaire refers, inter alia: (a) to the main characteristics and risks associated with the instruments that may be dealt with on the Portal; (b) to the types of services, transactions and financial instruments with which the Investor is familiar; (c) to the nature, volume and frequency of transactions in financial instruments carried out by the Investor over a given period; and (d) to his level of education and profession.