INFORMATION RELATING TO THE TERMINATION OF THE PROVISION OF BROKERAGE SERVICES FOR INDIVIDUAL CLIENTS

INTRODUCTION

Decision to limit the scope of WealthSeed business activities

The Management Board of Fair Place Finance S.A., which provides investment and payment services to retail clients under the trademark „WealthSeed” (hereinafter referred to as „WealthSeed” or „Investment Firm”), decided to focus its business activities on using its technology solutions to serve institutional clients. At the same time, WealthSeed decided to close its retail business and stop providing services to individual clients (hereinafter referred to as the: „Clients”).

As a result, in line with the Terms and Conditions for Brokerage Services (hereinafter referred to as “Terms and Conditions”), on the 7th of June 2023, WealthSeed sent out termination notices concerning investment and payment services to all its individual clients.

This document summarizes key information for Clients concerning the management and withdrawal of their assets from the WealthSeed platform in these circumstances in the form of frequently asked questions and answers. We apologize for any inconvenience this process may cause and greatly appreciate your cooperation in this matter.

Table of Contents

TERMINATION OF THE AGREEMENT

Fair Place Finance S.A. operating under the trademark WealthSeed decided to close its retail business and, consequently, terminates its relationships with existing Clients.

The termination notice period, in line with the Terms and Conditions, lasts 30 days counted from the day of termination (hereinafter referred to as the „Termination Notice Period”). During this period, you can execute all operations in Your account on the same terms as previously. However, please note that you are required to withdraw all your assets from the WealthSeed platform by the end of the Termination Notice Period. Please ensure you do not leave this task until the last day of the Termination Notice Period as full execution of brokerage transactions, including settlement, may last a few working days.

SECURITY OF YOUR ASSETS

The WealthSeed operating model ensures both client cash and financial instruments remain secure. During the Termination Notice Period, until you withdraw your assets from the WealthSeed platform, they remain secured in exactly the same way as previously.

WealthSeed stores client cash in separate accounts maintained by a partner bank with State Treasury’s guarantees. Clients’ securities are kept in a separate account at the Central Depository of Stocks in Poland (KDPW) for Polish stocks and ETFs or at a German bank for global stocks and ETFs. Clients’ mutual fund investments are registered in their name at third party depositaries.

Additionally, it should be noted that, in line with requirements for all Polish investment firms, all client cash and financial instruments held at WealthSeed are covered by the KDPW compensation system, which secures lost funds and financial instruments, including transactions in progress, up to the limit set in Polish regulations.[1]

For more information on the security of your assets at WealthSeed, please refer to our webpage: https://www.wealthseed.eu/bezpieczenstwo/

[1] Act of law of 29 July 2005 on turnover of securities (Unified tax in Journal of Laws of 2022, position 1500 with further amendments).

STOCKS, ETFS AND ETPS

During the Termination Notice Period you can submit orders concerning your securities exactly in the same manner as previously.

In line with the Terms and Conditions, you are obliged to sell or submit a transfer request for all of the securities stored in your account until the end of the Termination Notice Period.

You can submit a sell order for your securities at any moment during the Termination Notice Period. After placing an order to sell stocks, ETFs or other securities, you can track the status of the order in the history of brokerage transactions, which is available from the main screen of the global brokerage service. The securities you want to sell will no longer be displayed in your securities account as soon as your order is executed on the exchange. However, please note that, in accordance with market practice, the transaction will be settled only two business days after your order is executed on the stock exchange and only then you will see the funds from the sale of your securities on your cash account. Therefore, do not wait until the last minute to sell securities.

You can also request a transfer of your securities to another investment firm or bank with appropriate licenses at any time during the Termination Notice Period.

For Polish securities the transfer to another Polish investment firm/bank may take up to a few days. WealthSeed decided to waive all fees for such transfers that were originally included in the Table of Fees and Commissions (the latest Table of Fees and Commissions together with all other client documents may be found under the following link: https://www.wealthseed.eu/en/regulations/).

For international securities, the transfer to another investment firm/bank is more complicated, will take longer and will require completing additional documentation. Such a transfer may last three weeks or longer depending on the particular security and target investment firm/bank. In line with the Table of Fees and Commissions, WealthSeed charges a fee equal to 0.95% of the value of transferred securities with  a minimum fee of EUR 25 for each financial instrument (separate ISIN code). In case of a transfer of assets of high value, special terms may apply. Given the above, we recommend selling international securities before the end of the Termination Notice Period.

If you have securities in your account that have been de-listed or factional shares because of corporate actions, then WealthSeed may contact you to provide you with further details on the options available to sell your assets.

The list of investment firms and banks entitled to provide brokerage services in Poland is available on the webpage of the Polish Financial Services Authority (KNF) under the links below:

https://www.knf.gov.pl/podmioty/Podmioty_rynku_kapitalowego/Firmy_inwestycyjne_i_Agenci_firm_inwestycyjnych/domy_maklerskie

https://www.knf.gov.pl/podmioty/Podmioty_rynku_kapitalowego/Firmy_inwestycyjne_i_Agenci_firm_inwestycyjnych/Banki_prowadzace_dzialalnosc_maklerska

To request a security transfer please send us a message to kontakt@wealthseed.eu, and we will then provide you with detailed instructions on what information/documents we need to process the transfer.

Don’t worry. Settlement of brokerage transactions takes up to several business days. After placing an order to sell stocks, ETFs or other securities, you can track the status of the order in the history of brokerage transactions, which is available from the main screen of the global brokerage service. The securities you want to sell will no longer be displayed in your securities account as soon as your order is executed on the exchange. However, please note that, in accordance with market practice, the transaction will be settled only two business days after your order is executed on the stock exchange and only then you will see the funds from the sale of your securities on your cash account.

In case you owned a financial instrument on a dividend day (when the right to receive a dividend was determined) and the planned payment of the dividend is scheduled on a  date after the termination of our agreement, then you can provide us with an account number where the dividend should be transferred to after its receipt. However, please note that if you provide us with a new account number, we will also request a document confirming that you are the owner of that account, for example a bank statement.

When the Termination Notice Period ends, and there are still some securities in your investment account, then in line with the Terms and Conditions for Brokerage Services, we will sell your securities on your behalf for the best price allowing execution of the transaction. In such a situation, after the settlement of the transaction and recording cash from the sale in your account, we will aim to return the cash to you, as described in section 5 “Cash” below.

If the Termination Notice Period ends and some securities remain in your account, please you can contact us at kontakt@wealthseed.eu to receive more information about your assets and next steps.

In line with regulations, the Company will be sending information forms PIT-8C (“Information on selected capital incomes”) to clients for the year 2023. These PIT-8C forms will be sent to all individuals, who according to the regulations, should receive them, i.e. performed transactions on securities.

Information forms PIT-8C will be sent within statutory deadline, i.e. by the end of February 2024.

MUTUAL FUNDS (INVESTMENT FUNDS)

During the Termination Notice Period, you can submit instructions related to units/shares in mutual funds (“units”) on the WealthSeed platform as previously.

WealthSeed does not maintain a register of your mutual fund  units. In line with legal requirements, mutual fund registers, on request of the asset manager (TFI), are maintained by separate entity.

As a result, after the Termination Notice Period ends, you will be able to submit instructions for the redemption of your AgioFunds units or the acquisition of more units to any distributor of AgioFunds. The instruction can be also submitted directly to AgioFunds TFI, e.g. via the AgioFunds online portal at: https://online.agiofunds.pl/client/login. After creating an account in the AgioFunds online portal you will also be able to monitor the value of your AgioFunds units, if you choose not to sell them during the Termination Notice Period.

However, please note that after the Termination Notice Period ends, you will no longer receive regular cash payments from the Fund/Asset Manager that were previously paid to WealthSeed clients.

During the Termination Notice Period, you can submit instructions related to mutual funds on the WealthSeed platform as previously.

As explained in the answer to the question above, WealthSeed does not maintain a register of your mutual fund units. In line with legal requirements, mutual fund registers are maintained, on request of the asset manager (TFI), by a separate entity.

As a result, after the Termination Notice Period ends, subject to completion of a register transfer described below, you will be able to submit instructions for the redemption of your Allianz TFI units or the acquisition of more units to any distributor of Allianz TFI funds. The instructions can be also submitted directly to Allianz TFI, e.g. via the Allianz TFI investment portal at: https://sti.allianz.pl. After creating an account in the Allianz TFI online portal, you will also be able to monitor the value of your Allianz units, if you choose not to sell them during the Termination Notice Period.

However, please note that after the Termination Notice Period ends, you will no longer receive regular cash payments from the Fund/Asset Manager that were previously paid to WealthSeed clients. To implement this change, after the Termination Notice Period ends, the register of Allianz TFI units currently maintained in line with the plan “Invest with WealthSeed” (pl. “Inwestuj z WealthSeed”) will be transferred to a standard register. When the register is being transferred, then temporarily it will not be possible to submit instructions for acquisition or redemption. Hence, we recommended that you redeem currently owned Allianz TFI units before the end of the Termination Notice Period.

No, after the Termination Notice Period ends, regular cash payments from TFI/Funds to WealthSeed Clients that purchased mutual funds via WealthSeed will cease.

As the payments are made by TFI/Funds, it is their business decision on whether to continue such arrangements or not. After WealthSeed has terminated distribution agreements with AgoFunds TFI and Allianz TFI, both asset managers have decided to terminate regular payments to WealthSeed clients.

If the final cash payment from TFI/Fund to you is due after the Termination Notice Period ends, then WealthSeed will seek to transfer the cash payment to you in line with the process described in section 5 Cash below.

CASH

During the Termination Notice Period, you can manage your cash funds as previously. In particular, at any time you can send cash funds from your Wealthseed account to any account in Poland or your account abroad at a regulated financial institution. In case any cash remains on your account by the end of the Termination Notice Period, we will seek to return these funds to you. In the first step, we will seek to send the funds to your account that is known to us. If we know more than one of your accounts, then we will prioritize returning your funds to the account in the same currency that you have used most recently to send funds to WealthSeed, unless you instruct us to send the funds to another account. If we do not know your account number, then any funds remaining on your WealthSeed cash account after the Termination Notice Period end will be sent by post transfer to your residential address that is known to us. In all other cases if the return of cash funds is not successful in any of the forms mentioned above, the cash funds will be recorded in the technical account at WealthSeed, and we will wait for further instructions from you.

If you have an overdraft in your cash account at WealthSeed, then please immediately send funds to cover it. The funds should arrive no later than the last day of the Termination Notice Period.

Any cash sent to your WealthSeed cash account after the Termination Notice Period ends will be automatically returned to the account that they came from.

Cash received from the sale of financial instruments, after successful settlement of any sell transactions, should be available for transferring out in the next payment session. However, in special circumstances, when the cash transfer was immediately preceded by an f/x conversion, the cash transfer will be executed only after completion of all previous operations in Your account, e.g. clearing and settlement of your securities or f/x conversions.

OTHER

In line with the Terms and Conditions for Brokerage Services, the Agreement between the Client and WealthSeed is terminated when the Termination Notice Period ends. However, the agreement may be still binding in part required to settle your Investment Agreement, which is required to close your Investment Account.

Partial termination of the Agreement may occur if more time is needed for the final settlement of all provisions or execution of other operations in the accounts.

After we close your Investment Account, you will receive an e-mail confirmation.

Fair Place Finance S.A. will store your personal data in a secure manager for a period required by law.

In case of any questions or doubts, please kindly contact us at: kontakt@wealthseed.eu.

Most recent information on how to manage and withdraw your funds from WealthSeed is available online under the following link:

https://www.wealthseed.eu/en/faq-termination/

According to the regulations, in particular the act on trading in financial instruments of 29 July 2005 (Journal of Laws of 2023, pos. 646, unified text) and the act on anti-money laundering and financing terrorism of 1 March 2018 (Journal of Laws of 2022, pos 593, unified text), the Company is obliged to archive and store date defined by these regulations. Therefore, the Company will store your data for the minimum time after closing your investment accounts required under said regulations.

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