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Disclosures

In accordance with the provisions of Section 16a(a)(2) of the Regulation of Investment Advice, Investment Marketing and Portfolio Management Law, 1995 (“Investment Advice Law”), IBI Investment House Ltd. and IBI-Amban Asset Management Ltd. respectfully brings the following to your attention:

IBI-Amban Asset Management Ltd. holds a portfolio management license and is engaged in the management of investment portfolios and investment marketing and not in investment advice, as the terms are defined in the Investment Advice Law.

Description of the structure of the IBI Group

IBI Investment House Ltd. holds a variety of companies that belong to the IBI Group (the “Investment House”). The Investment House, through the companies in the group, is engaged in a variety of activities on the capital market, including investment portfolio management and investment marketing, mutual fund management, provision of services related to securities and stock exchange member services, investment in securities for itself and others, underwriting and distribution services, investment fund management, trust services and other activities on the capital market in Israel and overseas.

IBI Investment House Ltd. has holdings in the following corporations[1]:

  • Full ownership of IBI-Amban Asset Management Ltd. (“IBI-Amban”), which manages investment portfolios and is engaged in investment marketing;
  • Full ownership of IBI Mutual Funds Management (1978) Ltd. (“IBI Fund Management”), which manages a variety of mutual funds;
  • Full ownership of Israel Brokerage & Investments – IBI – Ltd. (“Brokerage”), that serves as a broker and member of the stock exchange;
  • Controlling shareholder of Poalim IBI Management & Underwriting Ltd., which provides underwriting, distribution and consulting on public issues through a subsidiary (“Poalim IBI”);
  • Controlling shareholder of Four Seasons Pension Insurance Agency Ltd., which has a corporate agent license and markets various financial assets (“Four Seasons”);
  • Controlling shareholder of several investment funds.
  • Full ownership of CFX Market Ltd., engaged in brokerage and related to foreign currency exchange for eligible clients through an electronic trading system;

In view of the above, these organizations are affiliated with companies that are also affiliated with each other.

Interest in the financial assets

Each of the companies has an interest in the following financial assets, as they were issued or are managed by companies with which they are affiliated and/or as they or their affiliated companies may receive a benefit with respect to a transaction with said financial assets or further to their holding: for a list, see attached below.

  • Mutual funds – mutual funds managed by IBI Fund Management that are listed on the investment house website and revised from time to time.
  • Investment funds – that fall under the definition of “foreign fund,” as defined in the Investment Advice Law and the Joint Investment Trust Law, 1994, managed by IDB Investment House, which are listed on the investment house website and revised from time to time.
  • Structured products – from time to time, Amban purchases various types of structured products issued by financial organizations for its clients and are listed in the First Addendum to the Securities Law, 1968. They are listed on the investment house website: ibi.co.il and revised from time to time. Amban has an interest in transactions with issuers of structured products as it receives fees and/or other benefits from said issuers for transactions with the structured products or their continued holding.
  • List of the organization that manage financial assets that are marketed by Four Seasons is provided and revised from time to time on the Four Seasons website at: fsfp.co.il.

Due to said interest of the companies to certain financial assets, IBI Amban Investment Management Ltd. is engaged in investment marketing and not investment advice. The companies may prefer to purchase financial assets in which they have a financial interest for their clients and/or recommend that their clients purchase financial assets for their investment portfolios, in which the companies have an interest instead of financial assets managed by other parties, which are similar in terms of their suitability for the client.

Disclosures

  • Poalim IBI, through a subsidiary that serves as an underwriter, distributor and/or consultant on public issues and receives consideration for its services for said issues.
  • Companies in the investment house may, directly or indirectly, hold and act for themselves, at any time, with securities and financial assets that are purchased, sold or held in the accounts of their clients.
  • List of the public companies in the group and public companies affiliated with the group –
  • IBI Investment House – its shares are traded on the Tel-Aviv Stock Exchange Ltd. (“TASE”).
  • Poalim IBI – its shares are traded on the Tel-Aviv Stock Exchange Ltd. (“TASE”).

[1] The list includes only main companies that may be relevant for the service provided by the companies.