Access
Contact us
Home | Corporate Governance and Remuneration Policy

Corporate Governance and Remuneration Policy

 

MiFID

MiFID II is Directive 2014/65/EU on markets in financial instruments, which came into force on 3 January 2018 in all countries of the European Union.

Based on improvements to the rules already adopted by MiFID, the new regulatory framework governs the authorization and operating conditions of Investment Services Firms (ISFs).

Its aim is to strengthen current European regulations on securities markets in several ways:

  • It aims to ensure that organized negotiation takes place in regulated platforms.
  • Introduce rules about algorithmic negotiation and high frequency.
  • Improves transparency and supervision of financial markets, including derivatives markets.
  • reinforces the investor protection and Standards of Conduct, as well as the conditions of competition in the negotiation and settlement of financial instruments.

Products

Investment products that fall under the MiFID II directive can be divided into the following categories based on their complexity*:

Complex products:

Non-complex products:
– Financial derivatives
– Convertible bonds and debentures
– Subordinated debt
– Structured products
– Convertible and preferred shares
– Hedge Funds		 – Private fixed income
– Public debt
– Equities admitted to trading on regulated markets
– Collective Investment Institutions in general (IICs)

* This is a general classification; however, the specific instrument should be evaluated to determine the correct classification.

Clients

CUSTOMER CLASSIFICATION:

With the aim of adopting the necessary measures to protect each investor when contracting products and services, and in accordance with current regulations, Solventis classifies clients into three categories:

  1. Retail Customer

    Anyone who cannot be considered a professional client due to a lack of extensive financial knowledge will be afforded the highest level of protection regarding the investment products and services they purchase.

  2. Professional Client

    Anyone who possesses the experience, knowledge, and qualifications necessary to make their own investment decisions and to correctly assess the risks inherent in those decisions. This type of client will require a lower level of protection than a retail client. Depending on their volume and operations, they can be classified into two types:

    1. Automatic:
      • Entities subject to supervision by a regulator and authorized to operate in the financial markets.
      • Companies that individually meet two of the following requirements:
        1. Total Balance: 20 Million Euros
        2. Net Turnover: 40 Million Euros
        3. Equity: 2 Million Euros
      • National and regional governments, public bodies that manage public debt, central banks or other similar international organizations.
      • Other institutional investors whose business activity is investing in financial instruments.
    2. Voluntary: Those not automatically included in the Professional Client description and who meet at least two of the following requirements:
      • That the client has carried out significant volume transactions in the stock market with an average frequency of 10 per quarter during the previous four quarters.
      • That the value of the client's portfolio of financial instruments is greater than 500.000 euros.
      • That the client holds or has held, for at least one year, a professional position in the financial sector that requires knowledge of the operations or services provided.

  3. Eligible Counterparty

    These are professionals with the highest levels of knowledge, experience, and financial capacity in the securities markets. This includes investment firms, collective investment schemes and management companies, pension funds and fund managers, government agencies, central banks, and international organizations. These clients enjoy complete flexibility.

CUSTOMER CLASSIFICATION CHANGES:

Retail clients may request a change of category to voluntary professional client in writing, provided they meet the requirements detailed above. However, professional client classification entails lower levels of protection in the provision of investment products and services.

Similarly, the professional client or eligible counterparty may request in writing a change of category to retail client in order to ensure a higher level of protection.

CUSTOMER SERVICE:

This classification aims to offer clients investments best suited to their profile. Therefore, the entity providing investment services is required to obtain certain information from the client to assess the suitability and appropriateness of the products they require. To obtain this information, the client must complete the corresponding questionnaire based on the service provided by the entity.

  1. Convenience Test:

    It assesses the investor's knowledge and prior experience regarding financial markets, with the aim of offering products suitable for the client and, in this way, ensuring investor protection.

    This test is required for retail customers who will be provided with a receiving and processing of orders (RTO) service.

  2. Suitability Test:

    It assesses the investor's investment objectives, financial situation, and prior knowledge and experience of financial markets to determine their risk profile based on the results obtained. The risk profile reflects a client's degree of risk aversion. Risk profiles are classified as follows (from lowest to highest risk):

    • Capital preservation
    • Conservative
    • Moderate
    • Dynamic
    • Growth

    This test is required for clients who will be provided with investment portfolio management or financial advice services.

PRODUCT MARKETING:

Receiving and processing orders Portfolio management and advice
retail Convenience test Suitability test
Professional No Test Suitability test
Eligible Counterparty No Test No Test

If the required information is not obtained from the client, the entity providing the services will inform the client that it cannot recommend investment services or financial instruments for which such information is necessary, and may only recommend those investment services or financial instruments for which the entity has sufficient information.

With regard to the actions of the entity providing investment services, and in accordance with the best execution of orders principles established by MiFID, the entity must take reasonable steps to achieve the best possible outcome for its clients.

Documents of Interest

Solventis SGIIC, SA Activities Program
Solventis SV, SA Activities Program
Articles of Association of Solventis SV, SA
Articles of Association of Solventis SGIIC, SA
Organization and Responsibilities Corporate Governance – Solventis SV, SA
Organization and Responsibilities Corporate Governance – Solventis SGIIC, SA
Policy on the Management of Conflicts of Interest and Incentives
Best Order Execution Policy
Asset Safeguarding Policy
Customer Protection Regulations
Maximum Rates Brochure
Remuneration Policy Solventis SV, SA
Remuneration Policy Solventis SGIIC, SA
Standard Portfolio Management Contract
Standard Intermediation Contract
Implementation centers – Implementation report – Fiscal year 2025
Implementation centers – Relay report – Fiscal year 2025
Annual Accounts with management report and audit – Solventis SV, SA – Financial Year 2025
Annual Accounts with Management Report and Audit – Solventis Group – Financial Year 2025
Annual Accounts with management report and audit – Solventis SGIIC, SA – Financial Year 2025
Shareholder Engagement Policy
Summary of the application of the Shareholder Engagement Policy Fiscal Year 2025
Whistleblowing channel policy