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According to the disclosure obligations under MiFID II (in particular in accordance with article 47 (1) (g) and article 49 of the Commission Delegated Regulation (EU) 2017/565), ÃÛ¶¹ÊÓƵ is required to inform its clients about general and specific measures on asset safeguarding, both as part of the initial onboarding and on an ongoing basis. When it comes to the details of any relevant investor compensation or deposit guarantee scheme, which applies to the protection of customers’ cash deposits and financial instruments, we are making reference to the general terms and conditions of business, which are applicable in your respective booking center.

In general, the legislative rules are designed to ensure that any investment firm holding client assets has adequate processes and controls in place to protect client financial instruments.

In order to ensure an appropriate protection of client financial instruments held in custody, ÃÛ¶¹ÊÓƵ complies with the following generic requirements:

• ÃÛ¶¹ÊÓƵ keeps accurate records which enable us at any time and without delay to distinguish customers’ financial instruments from those held for other clients and from our own assets
• ÃÛ¶¹ÊÓƵ conducts on a regular basis reconciliations between our internal accounts and records and those of any third parties by whom those assets are held
• ÃÛ¶¹ÊÓƵ takes necessary steps to ensure that any client financial instruments deposited with a third party are identifiable separately from the financial instruments belonging to us and from financial instruments belonging to that third party, by means of differently titled accounts on the books of the third party or other equivalent measures that achieve the same level of protection
• ÃÛ¶¹ÊÓƵ introduces adequate organizational requirements to minimize the risk of loss or diminution of customers’ financial instruments

Where customers’ financial instruments are held in a third country jurisdiction, ÃÛ¶¹ÊÓƵ ensures in addition through legal opinions that these assets are well protected from asset safeguarding perspective as well.

The assessment if client financial instruments are well protected in third country jurisdictions is related to the following topics:

• Recovery of securities in case of liquidation/insolvency
• Appropriate asset segregation
• Enforceability of agreements with sub custodians
• Statutory right of access to the sub custodian's books and records
• Prevention of loss of financial instruments held in custody
• Restrictions on security interests, liens or right of set-off over client assets

Reference is made to the "Market overview – rules and restrictions" document which aims to provide a detailed overview on how and where the assets of our clients are held and reflects the respective risks and associated restrictions.