“Long-range planning does not deal with the future decisions, but with the future of present decisions.”–Peter F. Drucker

  1. 1. Introduction

    Andorra has a structured financial system that operates according the solids financial European standards.

    Law 8/2013, of 9th May, on the administrative requirements and operating conditions for entities working with the financial system, investor protection, market abuse and financial collateral arrangements provides the Andorran financial system with the community Directive 2004/39/EC from the European Parliament and the Council of the 21st April 2004 known as the MiFID.

    Complying with regulations and Universal Gestió S.A.’s quality standards a performance framework is established with clients that is divided into three phases:

    • 1.1 The Pre contractual Phase

      The Pre contractual Phase consists of providing the investor with information on the business and its protection policies:

      • Information of Universal Gestió and the services that it provides
      • Financial instruments and risk related investment strategies
      • Measures for protecting and safeguarding the client’s shares
      • Procedures for financial operations to achieve the best result for its clients
      • Its policy for identification and for managing any conflict of interest
      • Price list.
    • 1.2 The Contractual Phase

      The Contractual Phase consists of obtaining information on the financial situation, the investment objectives, and to evaluate the financial knowledge of the investor, in order to classify, protect, and formalize the conditions of providing the service:

      • A client’s knowledge and financial experience will be evaluated for the purpose of classification in accordance with the regulations
      • A Suitability Test will be carried out in the discretionary management or customised portfolio and in the financial consultancy service, with the intention of matching a client’s investment to his risk profile, financial situation and investment objectives.
      • Document file and creating a contract that covers the rights of the client and Universal Gestió.
    • 1.3 Service Phase

      In the Service Phase information mechanisms are established on the carrying out of instructions and the state of executing portfolio management, as a periodic review of the Suitability Test:

      • Information relating to fulfilling orders
      • Periodic information on the situation and portfolio profitability
      • When it comes to marketing complex products not considered in the Suitability Test, a suitability Test will be carried out which will determine whether the product is suitable for the client based on their knowledge and previous experience.
      • Regular review of the suitability Test, at least in annually basis.
  2. 2. Client and Product Classification
    • 2.1 Client classification

      Andorra regulations relating to MiFID and protection of the investor (Chapter 3. Article 31 of Law 8/2013 of 9th May) require that clients to whom services are provided be classified into three categories based on their level of information, training and investor experience, according to the following list:

      • Retail investor: Maximum protection.
      • Professional client: Level of protection is limited according to their knowledge of shares, financial markets and associated risks.
      • Eligible Counterparty: Financial sector businesses.

      The retail investor client is entitled to ask for a change in classification to professional client, subject to fulfilment of at least two or three criteria required by the regulation:

      • The client has carried out transactions, in significant size, on the relevant market at an average frequency of 10 per quarter over the previous four quarters.
      • The size of the client’s financial instrument portfolio, defined as including cash deposits and financial instruments exceeds 0.5 million Euro.
      • The client works or has worked in the financial sector for at least one year in a professional position, which requires knowledge of the transactions or services envisaged.
    • 2.2 Classification of products and services

      Universal Gestió bases its activity mostly on two types of service or a combination of the two:

      A. Discretionary management and/or customised portfolio management

      B. Financial consultancy

      Prior to service provision a Suitability Test is carried out.

      If Universal Gestió wanted to invest on behalf of the client in complex financial products that are not included in the client’s suitability test, a specific suitability Test would be carried out.

      In accordance with MiFID products that are considered complex which require a prior suitability test are the following:

      • Preference shares, convertible bonds, perpetual obligations, subordinated debt etc.
      • Non-traditional investment funds (Hedge funds, Private Equity, Property Investment Funds, Commodities, etc.)
      • Derivatives (Futures, Options, Warrants, Caps, Floors, Foreign Exchange Derivatives, etc.)
      • Structured products.
      • Credit Default Swaps (CDS), Collateralised Debt Obligations (CDO)
      • Unusual financial contracts.
  3. 3. Financial instruments and associated risks
    • 3.1. General principles

      Profit/risk ratio (relationship)

      – Profitability is the yield of an investment measured by relevant financial factors

      Of course, profitability is a positive for the investor. As such, the greater the profitability, the better it is for the rational investor.

      – Risk relates to the variability of profitability. It is a negative that the investor will try to keep to a minimum.

      With basic analysis of these two variables it is possible to see the basic two outcomes, which will be relevant to the investor: profitability-risk. Therefore it is necessary to choose the option, which best combines or links both variables according to the decision maker.

      Any investment is characterised by risk and anticipated yield. The general rule for all of them is the greater the risk, the better the anticipated yield and vice versa.

      Investor profile

      As mentioned in the previous section, it is vital to know their investment profile in order to say which type of investment suits their sensitivity to risk and their yield objectives.

      So, prior to providing the services mentioned in part 2 of this document, the company carries out a Suitability Test to classify them, according to their investor profile.

      The investor profile is defined as follows:

      • Financial situation of the investor: Knowing whether yields are needed in the short or long term or liquid assets needs to meet their personal obligations.
      • Investment horizon: Knowing if the timeframe in which they would like to obtain their investment yields is more or less long, it’s also important to select the type of investment to be carried out. For example, a long term investment can be compiled of a product that is more volatile than a short term one as there is less pressure to recuperate invested capital at the beginning, they can wait for the moment when markets are more positive for our product and thus avoid losing capital in the short term.
      • Investor objectives: Determining the level of yields that the investor hopes to obtain and when they want to receive them. Be aware of what level of loss they are willing to accept, taking into account risk factors.
      • Risk profile: Identifying the degree of risk aversion that the investor has can be key when planning the investor’s portfolio.
      • Knowledge and expectations: evaluating the investor’s experience and knowledge of financial products and services.

      Investment diversification

      Although it is impossible to completely avoid risk when managing a portfolio of financial products, specific risk can be reduced through diversification.

      Possible diversification in financial instruments which can help reduce specific risks are as follows:

      • Typology of shares
      • Currency
      • Market sectors and geographic markets
      • Issuer and financial institutions where monetary resources are deposited
      • Others


      Net investment yields will no longer be gross when tax deductions or another form of imposition (taxation) are deducted. The tax burden can vary depending on the investment and the tax framework of their country of residency. We recommend taking investment decisions based on the tax system.

      In order to determine and analyse tax obligations for an investor, the company can carry out a Tax Test.

    • 3.2 Risks associated with financial instruments

      The price of a financial asset depends on profitability expectations and its associated risks.

      Variations in price of a share arise as a result in changes in the expectations for profitability or its risk, as follows:

      Credit risk or insolvency

      Credit risk or insolvency is the risk that the issuer or counterparty cannot or does not want to pay interest in the term they had originally agreed to when the issue took place.

      Market liquidity risk

      This consists of the possibility for the investor to sell off his investment as quickly as possible without having to accept a small drop in its price.

      In general, an issue will be more liquid the bigger they are as this will make it possible to spread between more investors, which always facilitates a greater volume of transactions.

      In general, shares that are listed in established markets are more liquid than those that are not.

      Exchange or currency risk

      Currency risk affects all shares equally; it doesn’t matter if these instruments are money market shares, obligations or derivatives.
      The purchase of an asset in the denomination of a currency other than that of their home economy exposes the investor to currency risk, meaning the risk that this money depreciates compared with the national currency.

      Interest rate risk and reinvestment risk

      Interest rate risk is the risk that an investor faces with a variety of interest rates that are different than expected.
      Interest rate risk is then divided in two: market risk and reinvestment risk. In the first, capital is lost due to interest rate rise. Greater or lesser price sensitivity, which interest rates can produce will depend on the characteristics of the asset. Reinvestment risk happens when reinvestment of the asset or cash flow have to be carried out at worse rates than anticipated and like the previous case, the greater or lesser outcome will depend on the specific characteristics of the asset.

      Market or price risk

      This is the risk of a fall in value of financial assets due to changes in risk factors, which adverse movements relating to the price have had.
      Market risk is the main risk of organised liquidity markets such as the variable income market of currency market or raw materials.

      Country risk

      This is where political and State problems prevent them from meeting their payment agreements. Their causes are various and of different natures for example political, social, religious and the economic situation.

      Specific risk linked to financing an investment in financial assets using credit

      The purchase of transferable securities financed with credit carry additional risk. In the case of a overflow of credit, it is possible to carry out complementary guarantees due to the unfavourable evolution of quotes for insured assets. If the investor is not in a position to replace these guarantees, the Company can be considered obliged to sell the deposited securities at an inconvenient point in time.

      Specific risk linked to the investment in derivatives

      Warrants and options react with increasing effect on the variations in listing of the underlying asset. When purchased, the instrument loses all value if on expiry of the period for option to buy, the underlying price is lower than the price forecast in the contract for the period, or if, on the expiry of the period to sell the option, it is higher.
      When selling derivatives or futures, which are not covered by underlying assets, the risk of loss is a priori unlimited.

    • 3.3 Classification of financial instruments

      There are two types of product in terms of complexity and risk:

      • Non MiFID Products

        The following products are excluded by the MiFID:

        • Current accounts
        • Savings accounts
        • Fixed term deposits
        • Pension planss
        • Endowment insurance
      • MiFID Products

        This can be divided into complex and non-complex:

        Non complex products

        • Variable income/shares listed on organised markets
        • Fixed income negotiated in organised markets
        • Money market instruments (public debt, promissory notes, etc.)
        • Investment funds and SICAVs (except Hedge Funds and other non-traditional sources like private equity, real estate, commodities)
        • Mortgage debentures.

        Complex products which require Suitability Test in advance:

        • Preference shares, convertible bonds, perpetual bonds, subordinated debt, etc.
        • Non-traditional investment funds (Hedge Funds, Private Equity, Property Investment Funds, Commodities, etc.
        • Derivatives (Futures, Options, Warrants, Cap, Floors, Foreign Exchange Derivatives, etc.)
        • Structured products.
        • Credit Default Swaps (CDS), Collateralised Debt Obligations (CDO).
        • Unusual financial contracts.

        Description of principal MiFID products, risks and characteristics:

        • Preference shares: These are issued by a company which does not offer capital participation or voting rights. They are perpetual (they don’t expire) and profitability is not guaranteed. It consists of a complex instrument with high risk, which can result in loss of capital invested.
          These instruments tend to have liquidity with many limitations in a secondary market, as the issuers normally give the liquidity.
        • Convertible bonds, perpetual bonds, subordinated debenture

          a) Convertible bonds

          They are bonds that are issued with the option for the underwriter can exchange them for shares or another type of bond from the issuer, who enable them to be listed on the market.
          It will be profitable to convert bonds into shares when the profit from the dividends is greater than those of the coupon or if greater liquidity of the asset is required if the share is *quotable on the secondary market.

          b) Perpetual bonds

          This bond does not expire. Perpetual bonds pay out coupons perpetually and the issuer cannot redeem it.

          c) Subordinated debenture

          These are fixed income shares with a stated yield that are normally issued by credit institutions that offer greater profitability than other debt assets. However, this higher profit is achieved if you forego earnings if the company closes and subsequently liquidates, since it is subordinate in payment priority compared with general creditors.

        • Principal derivatives (Options and warrants)

          a) Options

          The purchase of an option gives the right but no obligation to buy (call) or sell (put) an underlying asset, at a predetermined price, called financial year price and at a date in the future. Either way, the contract seller has to accept the decision of the buyer.
          The buyer of a CALL gains at the expiry of the contract if the price of the underlying asset is higher than the price for the financial year, and the opposite for the buyer of a PUT.
          The combination of options can result in very complex strategies and consequently high risk, especially when options are sold. An option can be used to cover a portfolio, limiting the risk of loss to the price paid for the purchase of the option.

          b) Warrants

          This is a form of option, which is listed, giving the buyer the right but not the obligation to buy/sell an underlying asset (share, future etc.) at a set price also on a predetermined date. In terms of operation, warrants are treated as options.
          Warrants are financial products that have a lifting effect, that’s to say, they are exposed to variations in price of the underlying asset which is a multiple of the initial investment. They are mostly used to speculate on the rise or drop in price of the underlying asset but the investor can confront total loss of original investment when it expires. They also serve to cover a portfolio against unfavourable movement. The PUT warrant (option to sell) is regularly used as an instrument to protect a portfolio against variations in the market.

        • Futures:
          Futures, like options are derivatives.
          They are long term contracts when two parties make a firm commitment (unlike options) to buy or sell an agreed quantity of an underlying asset at a fixed price on a predetermined date in the future (date of maturity).
          A characteristic of Future contracts is the high level of standardisation (contract amount, predetermined expiry, there is no listing (tick size), exact definition of the underlying choice, etc.)
          If on the expiry, the price of the underlying contract asset is greater than the specified price, the buyer makes a profit. Otherwise, they make a loss. The opposite is applicable to the seller.
          As with other derivatives, futures have a lifting effect, in the way that invested capital represents less than the price of the corresponding asset, which has a multiplying effect on the profitability rate of the share, increasing risk on the capital invested significantly.
          The most common form of futures are commodities (natural resources, metals, etc.), currencies, interest rates (money rates and bond yields) as with stock exchange.
          Futures contracts don’t need to be maintained until their expiry, although they can be sold any time before this, in many cases it is not necessary to buy the product at the same time, it is sufficient to just pay the difference between the price that was agreed and the price of the product upon expiry
        • Structured products:
          These are financial instruments, which combine different financial assets in one structure, where each component is used to secure a concrete objective:- Elements to totally or partially protect capital.
          – Elements of risk, which are used to optimise yield through a determined exposure to that which is underlying.Structured products are very diverse and financially extremely complex.
        • Credit default swaps (CDS)
          This is a financial operation to cover risk, included with derivatives that arises during a swap contract on a determined credit instrument (normally a bond or a loan) where the buyer of the exchange carries out a series of periodic payments (called spread) to the seller and in return receives a quantity of money from the former if the share which acts as underlying asset in the contracts is unpaid at the expiration or the issuing organisation defaults.
          The main principle of credit default swaps is to serve as security for the owner of debt security who wants to cover themselves from potential credit risk (basically failure to pay). For this they go to a credit default swaps seller, pays an annual premium, and if unpaid, the seller pays the amount of the share to the owner.
        • Hedge Funds
          These are collective investment funds organised privately and managed by professional firms and are totally speculative. They are created with the objective of high profitability and use a lot of derivatives such as Options. They have a lifting effect and offer additional diversification to the traditional portfolios, since in theory, they are not linked to share or bond market results.The different strategies are characterised by their very diverse binomial yield relations.
  4. 4. General policy for safeguarding assets

    Andorran regulations relating to MiFID and protection of the investor require measures under Article 12 of Law 8/2013 of 9th May to protect the safeguarding of assets, avoiding improper use and allowing identification at any time of the positions and operations in process for each client.

    Universal Gestió is an independent financial investment institution. Its very nature does not authorise it to carry out stocks operations using its own account or act as depositary, which guarantees its independence and stops improper use of financial assets for its own benefit.

    Universal Gestió uses policies, processes, records and security systems to safeguard the integrity, availability and confidentiality of information on its clients’ assets, including:

    • 4.1 Distinguishing clients’ assets

      Universal Gestió identifies the detail of positions and operations in process for each client.

      Therefore the positions in omnibus accounts to financial institutions are identified with a sub account for each client.

    • 4.2 Trusts

      The deposit taking institution is chosen by the client itself from the Principality’s banking institutions and institutions known for their prestige, experience and international solvency, in keeping with the following table, which may be changed in the future so that deposit taking banks who fulfil the requirements have a suitable profile:

      Andorran Institutions International Institutions
      Andbank Banque Privée Edmond de Rothschild
      Mora Banc Pictet
      Vallbanc UBS
      Banco de Sabadell d’Andorra Credit Suisse
      Crèdit Andorrà Banque de la Suisse Italienne
      Banque de Patrimoines Privés (Lux)

      These institutions also use their methods for protection and evaluation of the subcustodis of international markets.

      The chosen Trust institutions are subject to change based on their merits.

    • 4.3 Reconciling

      Reconciling of movements relative to carrying out orders takes place daily and reconciling positions with the institutions takes place on a monthly basis.

      The annual external audit also reconciles positions with responses from institutions where funds have been deposited.

    • 4.4 Contingency plans

      Universal Gestió has contingency plans to guarantee service provision if IT systems fail or when this is not possible, the recovery of positions and order records.

    • 4.5 Use of clients’ financial instruments

      Universal Gestió doesn’t act for itself and therefore guarantees not to use clients’ assets to finance its own activity.

    • 4.6 Continuous improvement

      The review and evaluation of safeguarding policy for assets is carried out periodically by the company and annually by external audit, which are submitted to AFA

    • 4.7 Communication

      Universal Gestió makes its policy for safeguarding assets available to clients and this is also available on the web www.universalgestio.com

  5. 5. General conflict of interest policy (pgci)
    • 5.1 Introduction
      • 5.1.1 Objective

        The investment service that Universal Gestió offers can make it possible for conflict of interest situations to arise between the company and its clients, and between clients themselves.

        With the aim of protecting the client, the company has established suitable policies, processes and organizational measures to prevent and eliminate potential conflicts of interest that may arise at the time of the provision of services or if these cannot be avoided or eliminated, advising the client.

      • 5.1.2 Legislation

        Article 13 of Law 8/2013, of 9th May, on the administrative requirements and operating conditions for entities working with the financial system, investor protection, market abuse and financial collateral arrangements establishes that companies operating in the Andorran financial system have to set out in writing the policy and system for the prevention and resolution of conflicts of interest according to their size, organization, volume and the complexity of their transactions.

        In addition to the CIP (Conflict of Interest Policy), the company uses a Code of Ethics based on the AFA’s binding communiqué no. 163/2005 of 23rd February 2006, regarding the rules of ethics and behaviour for financial entities operating in Andorra

      • 5.1.3 Dissemination

        This policy is revised annually, provided that there are no circumstances or regulations that require it to be revised.

        This policy and any changes are available on Universal Gestión’s web page: www.universalgestio.com

    • 5.2 Definitions
      • 5.2.1 Conflict of interest

        Conflicts of interest are those situations that can arise when providing investment or ancillary services, or a combination of these. Where these exist it can lead to impact the client interests or between the clients themselves.

        They can include, but are not limited to the following:

        • The Institution or people in question can obtain a benefit or avoid a financial loss at the expense of the client
        • The Institution or person in question might have interest in the outcome of a service provided to the client or an operation carried out in their name, which is not in the client’s interest
        • The Institution or person in question might have financial or another type of incentive, which leads them to prioritise another client/s interests over that of the client in question
        • The Institution or person in question is carrying out the same activity or business as the client.
        • The Institution or person in question might have or might in the future receive from someone other than the client an incentive related to a service provided to the client, in money, goods or service, different to the commission or normal earnings for this service.

        The following does not constitute a conflict of interest; the Institution’s perception of commission or delivered fees directly by the client as a consequence of providing investment services in keeping with the price list and/or the management or financial assessment.

      • 5.2.2 Parties involved

        People involved in CIP (Conflict of Interest Policy) are:

        • The institution itself
        • Institutions in the Group and its subsidiaries
        • The institution’s Administrators
        • Board members
        • General management
        • Staff
        • Financial agents who provide investment services on behalf of the institution and in this case, their shareholders, administrators, directors or staff
        • Clients themselves
      • 5.2.3 Incentive

        These are fees, commission or non-monetary benefits paid or received from third parties involved in the provision of an investment service to clients relating to financial instruments as applied by MiFID

        Incentives must always increase quality of service provided to the client and cannot have a negative effect on acting in the optimal interest of the client.

    • 5.3 Measures and procedures for preventing, identifying, eliminating or revealing conflicts of interest.

      The business model for Universal Gestió makes it an independent investment services company. The very independence is a differentiating factor to avoid conflict of interest situations with the company itself or with other businesses in the Group.

      Therefore, Universal Gestió has taken various organisational and administrative measures, which will be revised at least annually and increased as is seen necessary:

      • 5.3.1 Preventative measures

        The institution uses various measures to prevent conflicts of interest amongst which, the following stand out: Internal control processes

        • Physical and technological measures to preserve the confidentiality, data protection and protection of client information.
        • Division of functions between people and separate fulfilment of orders.
        • Preventative measures in the selection of managers, advisers and agents for investment services, evaluation of their reputation, confidentiality, professionalism and independence
        • Centralised procedures between the General Manager and Supervision for applying the CIP and keeping an inventory of potential conflict of interest situations. With the company’s shareholders, administrators, directors and staff

        • The company’s shareholders, administrators, employees have all received copies of this policy and have returned a copy with the section read and confirmed
        • The company does not arrange incentives in the rewards policy, which can lead to potential conflicts of interest with clients
        • Co-workers cannot accept any compensation, whether cash or paid in kind from the client directly. If a client insists the co-worker must bring it to the attention of the chief executive. With financial agents who provide investment services

        • The client will decide with which institution they wish to deposit funds.
        • The company or any involved person cannot obtain a benefit or avoid a loss at the cost of a client. There is no case where a situation can be considered a conflict of interest when the company obtains a profit if there isn’t a simple possible damage or detriment to the interests of the client concerned through the operation or service in question.
        • Universal Gestió will inform its clients of the financial products, in carrying out its business, acts directly or indirectly in the management of that product.
        • Co-workers cannot accept any form of compensation whether cash or in kind from any financial agent that provides investment services. With clients

        • Instructions for carrying out orders on discretionary or customised portfolios with criteria for independence, pro rata rules, without considering reasons for turnover with the company and in order for it to be done simultaneously.
        • In “bus” accounts that the company holds with investment agents, a sub account will be opened which will make it possible for the position of each client to be identified with the aim of assuring the individualised assignment of orders being carried out
      • 5.3.2 Identification measures

        Any person involved is required to communicate in writing the existence of a potential situation of conflict of interest, however insignificant it may be, to the email address universalgestio@univeralgestio.com

        The General Manager and Supervision will analyse the situation and will proceed to include in the register of potential situations or if applicable, take the steps to remove or reveal it.

        In its introductory programme for new co-workers Universal Gestió includes training on the identification, prevention and management of conflicts of interest. Training takes place periodically to act as a reminder, which also includes any changes that have resulted from reviews.

      • 5.3.3 Steps for removal or resolution

        When it has not been possible to avoid a conflict of interest action will be taken in accordance with the following rules:

        • As a general rule whenever there is a conflict of interest between the company or people involved and the client, the interests of the client will be safeguarded.
        • If there is a conflict of interest between clients, appropriate measures will be taken to resolve the issue. If cancellation is possible, action will be taken which minimise the impact of one client in relation to the other.

        Management of the resolution of the conflict of interest will be resolved by the General Manager and Supervision or in the absence of this, by general management directly.

      • 5.3.4 Measures for it to be revealed

        If the measures taken are not sufficient, the nature and origin of the conflict will be communicated to relevant parties, including the services or operations where the conflict came about, subject to the client’s written consent.

        Revealing the existence of a conflict of interest does not exempt the company from adopting and applying effective organisational and administrative measures to avoid it.

        The company includes General Policy for Conflicts of Interest in its pre contractual information before providing its services.

    • 5.4 Register

      The General Management and Supervision will provide an up to date record of possible conflicts of interest depending on the phase that it is in:

      5.4.1 Identification phase

      • Reason for conflict and detailed description of the situation.
      • Date of the conflict.
      • People involved.
      • Financial services that the conflict relates to.

      5.4.2 Management phase

      • Causes and circumstances that led the conflict of interest.
      • Its consequences and where possible its extent.
      • Person assigned to manage the conflict.

      5.4.3 Resolution phase

      • How it is handled in resolution.
      • The outcome of the conflict of interest.
      • Person assigned to the resolution of the conflict.

      5.4.4 Disclosure phase

      • Informing the client of the situation and support in what has been done.
      • Date
      • How and when the client expressly accepted the situation, authorising the start or the continuation of investment service that was affected by the conflict.
    • 5.5 Continuous improvement

      Through the regular review of potential situations for conflict of interests and its own experience of management and resolution, Universal Gestió will apply continuous improvements in its policies for conflict of interest, to ensure the protection of the investor and honest behaviour, impartiality and professionalism of those involved in the best interest of its clients.

      Changes to CIP are published in Universal Gestió’s website (www.universalgestió.com)

  6. 6. Policy for order fulfilment and management

    Andorran regulation relating to MiFID and investor protection requires the adoption of all reasonable measures to obtain the best possible outcome for clients in the execution of orders.

    Universal Gestió is an independent financial investment company. Its nature does not authorise it to carry out orders directly, nor have direct access to the markets, therefore the service is limited to sending orders to an intermediary for their fulfilment.

    The independent investment management company model allows the client to choose his own Trust institution which will normally be the company carrying out orders, depending on the specific instructions of the client.

    • 6.1 General criteria for the policy

      As required by Andorran regulations, investment services businesses have to take into account the following factors when fulfilling orders:

      • The characteristics of the client, including client category; retail or professional client
      • Characteristics of the financial instruments
      • Characteristics of the fulfilment centres / intermediaries to contact

      For these purposes, the financial instruments for which Universal Gestió provides services are as follows:

      • Variable income
      • Fixed income
      • Money market instrument
      • Investment funds
      • Derivatives
      • Structured products
      • Raw Materials
      • Alternative funds
      • Swaps

      Given the diversity of markets, it’s possible that there are a number of intermediaries in the chain of fulfilment if one is not a member of the relevant exchange.

    • 6.2 Selection of intermediaries and execution centres

      In the shortlisting of intermediaries and potential execution centres, the following aspects are valued:


      • Price and costs: The price of the operation and its associated costs are a fundamental factor when choosing intermediaries, given that both will be supported by the client.


      • Efficiency in the fulfilment and settlement: Speed in the fulfilment and settlement, minimising of errors and electronic systems for receipt between the company and the intermediary are appreciated.
      • Financial solvency: Solvency and professional prestige of the business.
      • Intermediary’s policies for better fulfilment: In fulfilment centres chosen by the various intermediaries.

      Once a selection of intermediaries has been chosen, a decision will be made based on the following factors:

      • Price
      • Cost
      • Speed and likelihood of the fulfilment
      • Speed and likelihood of the settlement
      • Size and nature of the order
      • Type of order – immediate or limited

      Types of asset and fulfilment centres are provided in the following table:

      Types of asset Type of market
      Variable income Organized market
      Fixed income Organized market/OTC
      Money market instruments Organized market
      Investment funds Organized market
      Derivatives Organized market/OTC
      Structured products Organized market
    • 6.3 Revision and evaluation of policy for carrying out and management of orders

      Universal Gestió reviews this policy and the suitability of chosen intermediaries annually, or when there are significant changes that require it, in order to detect and, when necessary, amend any errors.

      The Company annually undergoes an external audit complying with the procedures of internal control and sends a report to the supervisory organisation (AFA).

    • 6.4 Communication of the policy for fulfilment and order management

      This information is available on Universal Gestió’s website (www.universalgestio.com) or at its client services offices.

  7. 7. Book Rates



    a. Management Commission Payment on Global Assets:

    Universal Gestió will charge a management commission ranging from 0.00% to 2.00% per year, depending on the balance managed, the type of investment in the portfolio and the administrative complexity of the portfolio.


    b. Success Commission on Results:

    Universal Gestió may charge a success commission if the performance obtained in the managed portfolio exceeds the benchmark agreed with the client. This commission payment will be charged at the end of each calendar year.




    a. Advisory Commission on Global Assets:

    Universal Gestió will charge a commission ranging from 0.00% to 1.00% per year, depending on the balance of the advised portfolio and the type of investment in the portfolio.


    b. Success Commission on Results:

    Universal Gestió may charge a commission on success if the performance obtained in the advised portfolio exceeds the benchmark agreed with the client. This commission payment will be charged at the end of each calendar year.




    a. Commission payment for advising companies on capital structure, industrial strategy and related issues, and advice and services in relation to mergers and acquisitions of companies.

    Universal Gestió will charge a commission ranging from 0.00 euros to 12,000.00 euros per year.

    b. Commission payment for the preparation of investment reports and financial analysis or other forms of general recommendation regarding operations in financial instruments.

    Universal Gestió will charge a commission, which depending on the complexity and scope of the reports, can reach a maximum of 300 euros/hour.


    Table of rates in force from 01 January 2022.