Portfolio Management - Full Disclosure
Dear Customer
Pursuant to section 16A (a) of the regulation of the practice of investment consulting, investment marketing and investment portfolio management, 1995 (the Consulting Regulation), Ayalon Financial Solutions (2004) Ltd. (“Ayalon”) is honored to inform you that:
1. Ayalon has a portfolio manager license, and deals with investment portfolio management and investment marketing, and does not engage in investment advice, following the terms as defined by the Consulting Regulation.
2. Ayalon is part of a group of companies controlled by Ayalon Investment House Ltd. (“Ayalon Group”). The Ayalon Group, for all or part of the group, is engaged in capital market activity, including investment activities in securities and financial assets, both for itself and for others as well as in the management of mutual funds.
The Ayalon Group may, directly or indirectly, hold and operate securities and financial assets for itself, acquired/sold from/to the client’s account before and/or during and/or after the execution of such transactions for the client, all subject to the provisions of any law.
3. The following is a list of the entities to which Ayalon is affiliated with as corporation (“the affiliated entities”) and/or to which Ayalon has an affiliation with their financial assets:
| The essence of the relationship | The essence of the entity | Entity name |
| A corporation affiliated with Ayalon, a sister company | Mutual Fund Management | Ayalon Mutual Funds Ltd. and the mutual funds managed by it |
| A corporation affiliated with Ayalon | A company engaged in underwriting and distribution, as defined in the Securities (Underwriting) Regulations, 2007 | Sable Capital Markets Ltd. |
| תאגיד קשור לאיילון | סוכנות לביטוח פנסיוני |
סייפ צ’וייס צעדים פיננסים סוכנות לביטוח פנסיוני (2020) בע”מ |
4. As provided in the Consulting Regulation, and in accordance with the conditions set forth therein, Ayalon may, as part of its practice in managing investment portfolios and marketing investments, as the case may be, prefer financial assets which Ayalon and/or its controlling shareholder and/or a corporation controlled by them – have an affiliation with, including the financial assets that are issued and/or offered and/or managed by the related entities, over another financial asset that is similar in terms of its suitability to the client, and to which they have no affiliation.
5. Ayalon has an affiliation with the financial assets, due to the fact that these financial assets are managed, issued, or offered by Ayalon or by any of the related entities, which are controlled by Ayalon and/or by the controlling shareholder in Ayalon, and also because Ayalon and/or the controlling shareholder may receive benefits from the related entities in connection with the execution of a transaction in the said financial assets or in connection with their continued holding. In addition, as part of its role as a portfolio manager and/or as an investment marketer, Ayalon may derive benefits associated with a transaction it will make for the execution of a transaction in the financial asset or related to its continued holding, from other sources than the purchaser or holder of the financial asset. This includes the fact that Ayalon is entitled (and/or may in the future be entitled) to receive payment of fees or commissions from mutual fund management companies (including such companies listed as related entities, which will be updated from time to time), by which it is employed (and/or may later be employed) in the marketing of the participation units of those mutual funds, and Ayalon Mutual Funds Ltd., will be entitled to a management fee and an additional rate and/or additional payments, as far as permitted by law, for the participation units of the mutual funds held in the clients’ accounts.