SaLeS PrOSPeCTUS Veri etf-allocation Defensive

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1 Werte schaffen Mit System Ohne Prognosen SaLeS PrOSPeCTUS Veri etf-allocation Defensive UCITS investment fund under German Law Sales Prospectus including Terms and Conditions of Investment July 2015 Veritas Investment GmbH mainbuilding Taunusanlage Frankfurt am Main Commercial register: Frankfurt HrB Managing Directors: Hauke Hess Dr. Dirk rogowski Hosnia Said Prof. Dr. Dirk Söhnholz

2 NOTE ON THIS SALES PROSPECTUS Units in the Veri ETF Allocation Defensive investment fund are bought and sold based on the sales prospectus in effect at the time, key investor information documents and the applicable General Terms and Conditions of Investment in conjunction with the applicable Special Terms and Conditions of Investment. The General Terms and Conditions of Investment and the Special Terms and Conditions of Investment are printed at the end of this sales prospectus. On request, the sales prospectus must be made available free of charge to any party interested in acquiring a unit in the Veri ETF Allocation Defensive investment fund, together with the latest published annual report and any semi annual report published after the annual report. The key investor information documents must also be made available to interested parties in good time and free of charge prior to contract formation. No information or declarations may be provided that differ from the information contained in the sales prospectus. Any purchase and sale of units on the basis of information or declarations that are not contained in this sales prospectus or in the key investor information documents is done exclusively at the risk of the buyer. This sales prospectus is supplemented by the most recent annual report and any semi annual report published after the annual report. If translations of this sales prospectus are used, the German version shall apply in the case of any doubts. INVESTMENT LIMITATIONS FOR US PERSONS Veritas Investment GmbH and/or Veri ETF Allocation Defensive are not and will not be registered under the applicable United States Investment Company Act of Fund units are not and will not be registered under the United States Securities Act of 1933 or the securities legislation of any federal state in the United States of America. Veri ETF Allocation Defensive units may not be offered or sold within the United States, to a US person or on their behalf. All applicants must demonstrate, where appropriate, that they are not a US person and that they are not acquiring them on behalf of a US person or selling them on to a US person. US persons are persons who are nationals of the USA or who reside there and/or are subject to tax there. US persons may also be partnerships or corporations (Personen oder Kapitalgesellschaften) that are incorporated under the laws of the USA or a US state, territory or anywhere under US ownership. 2 Veri ETF-Allocation Defensive (July 2015)

3 IMPORTANT LEGAL CONSEQUENCES OF THE CONTRACTUAL RELATION SHIP By acquiring units, the investor becomes a co owner of the assets held by Veri ETF Allocation Defensive, having a fractional share therein. They do not have the fund assets at their disposal. No voting rights are associated with the units. The contractual relationship between Veritas Investment GmbH and the investor and pre contractual relationships are governed by German law. The registered office of Veritas Investment GmbH is the place of jurisdiction for any disputes resulting from the contractual relationship, if the investor does not have a place of jurisdiction in Germany. All publications and advertising brochures are to be drafted in German or supplemented by a German translation. In addition, Veritas Investment GmbH will conduct all communications with its investors in the German language. In the event of disputes relating to provisions of the KAGB, consumers can call upon the ombudsman for investment funds of BVI Bundesverband Investment und Asset Management ev. This has no effect on the right to bring the matter before the courts. The contact details for the ombudsman for investment funds of BVI Bundesverband Investment und Asset Management e.v. are: Büro der Ombudsstelle BVI Bundesverband Investment und Asset Management e.v. Unter den Linden Berlin, Germany Phone: Fax: investmentfonds.de investmentfonds.de In the event of disputes arising from the application of the provisions of the German Civil Code relating to distance sales of financial services, the parties concerned may also turn to the German Federal Bank Arbitration Board. This has no effect on the right to bring the matter before the courts. The contact details are: Schlichtungsstelle der Deutschen Bundesbank PO Box , Frankfurt, Tel.: or 1906, Fax: , Veri ETF-Allocation Defensive (July 2015) 3

4 Contents NOTE ON THIS SALES PROSPECTUS... 2 INVESTMENT LIMITATIONS FOR US PERSONS... 2 IMPORTANT LEGAL CONSEQUENCES OF THE CONTRACTUAL RELATIONSHIP... 3 Contents... 4 Basic information... 6 The investment fund (the Fund)... 6 Sales documents and disclosure of information... 6 Terms and Conditions of Investment and their amendments... 6 Management Company... 7 Name, legal form and registered office... 7 Board of Management/Management and Supervisory Board... 7 Equity capital and additional equity capital... 7 Custodian... 7 Sub custodian services... 7 Liability of the Custodian... 9 Name, legal form and registered office of the custodian Notice of risk Risks of investing in a Fund Risks of the Fund's negative performance (market risk) Risks of restricted or increased liquidity of the Fund (liquidity risk) Counterparty risk including loan and receivables risk Operational and other risks to the Fund Explanation of the Fund's risk profile Profile of the typical investor Investment objectives, strategy, principles and restrictions Investment objectives and strategy Investment instruments Valuation Sub funds Units Issuing and redemption of units Liquidity management Stock exchanges and markets Fair treatment of investors and unit classes Issue and redemption prices Suspension of the issue and redemption price calculation Issuing surcharge Redemption fee Publication of the issue and redemption prices Costs Management fees and other costs Particularities for the purchase of investment units Total expense ratio Performance, Calculating and applying income, financial year Performance Calculating income, income equalisation Utilisation of earnings and financial year Veri ETF-Allocation Defensive (July 2015)

5 Winding up and merging of the Fund Preconditions for winding up the Fund Procedures for the dissolution of the Fund Preconditions for the merger of the Fund Rights of investors if Fund is merged Outsourcing Conflicts of interest Summary information on the tax treatment of the fund income for investors Units held as personal assets (investors resident for tax purposes) Units held as business assets (investors resident for tax purposes) Investors non resident for tax purposes Solidarity surcharge Church tax Foreign withholding tax Earnings equalisation Separate determination of tax bases, field audit Interim profit taxation Consequences of the merger of investment funds Transparent, semitransparent and non transparent taxation as an investment fund EU savings directive, German interest information regulation Auditors Service Providers Payments to unit holders/ dissemination of reports and other information Other investment funds managed by the Company Purchaser's right of revocation General terms and conditions of investment Special terms and conditions of investment Veri ETF-Allocation Defensive (July 2015) 5

6 Basic information The investment fund (the Fund) The Veri ETF Allocation Defensive investment fund (hereinafter referred to as the "Fund") is an undertaking for the collective investment, collecting capital from a number of investors and investing according to a defined investment policy for the benefit of these investors (herinafter referred to as the investment fund ). The fund is an investment fund in accordance with Directive 2009/65/EC of the European Parliament and of the Council of 13 July 2009 on the coordination of laws, regulations and administrative provisions relating to undertakings for collective investment in transferable securities (hereinafter referred to as "UCITS") pursuant to the German Investment Code (hereinafter referred to as "KAGB"). It is managed by Veritas Investment GmbH (hereinafter referred to as the "Company"). The Veri ETF Allocation Defensive was established on September 1 st, 2005, for an indefinite period. The Company invests capital deposited with it in its own name for the joint account of the investors, according to the principle of risk spreading, in the assets permitted under the KAGB, separate from its own assets, in the form of investment funds. The assets in which the Company may invest the investors' monies and the rules it must follow in doing so are stated in the KAGB, the associated regulations and in the Terms and Conditions of Investment that govern the legal relationship between the investors and the Company. The Terms and Conditions of Investment include a general and a special part ("General Terms and Conditions of Investment" and "Special Terms and Conditions of Investment"). Terms and conditions of investment for a public investment fund must be approved by the German Federal Financial Supervisory Authority ("BaFin") before they are applied. The fund is not part of the insolvency estate of the company. Sales documents and disclosure of information The sales prospectus, the key investor information documents, the Terms and Conditions of Investment and the current annual and semi annual reports may be obtained free of charge from the company in electronic or written form. methods, and the latest developments with respect to the risks and returns of the most important categories of assets may be obtained from the Company in electronic or written form. Terms and Conditions of Investment and their amendments The Terms and Conditions of Investment are printed in this documentation after this sales prospectus. The Terms and Conditions of Investment can be amended by the Company. Amendments to the Terms and Conditions of Investment require approval by BaFin. Amendments to the investment principles of the Fund also require the approval of the Company's Supervisory Board. Amendments to the Fund's current investment principles are permissible only on the condition that the Company offers investors the opportunity to either redeem (without additional costs) their units prior to the amendments taking effect or to exchange their units free of charge for units in investment funds with comparable investment principles that are being managed by the Company or another undertaking from the Group. The proposed amendments are announced in the German Federal Gazette (Bundesanzeiger) or on the Company website at investment.de. If the amendments relate to fees and expense reimbursements that may be taken out of the fund, or to the investment principles of the Fund or material rights of investors, investors will also be informed in paper form or in electronic form ("durable medium") via their institution maintaining the securities account. This information includes the essential content of the proposed amendments, their background, the rights of investors in connection with the amendment, as well as an indication of where and how further information can be obtained. The amendments take effect no sooner than the day following their publication. Amendments to the fee and expense reimbursement provisions take effect no sooner than three months after their publication, unless an earlier date is set with the approval of BaFin. Amendments to the current investment principles of the Fund shall also take effect no sooner than three months after publication. Additional information on the investment limits of the risk management for this Fund, risk management 6 Veri ETF-Allocation Defensive (July 2015)

7 Management Company Name, legal form and registered office The company is a capital management company (Kapitalverwaltungsgesellschaft) within the meaning of KAGB, which was founded on September 13 th, 1991, in the legal form of a private limited liability company (GmbH). The name of the company is Veritas Investment GmbH. The company has its registered office in Frankfurt am Main, Germany. The Company has been authorised to manage UCITS funds since it was found in 1991 (the legal term was securities investment funds in 1991 and directive compliant investment fund from 2004 till 2013). According to the development of the investment laws, the authorisation to manage funds was extended to money market investment funds on January 10 th, 1995 and to fund of funds, mixed securities and real estate funds as well as old age provision funds on December 2 nd, Since 2011 the company manages exclusively UCITS investment funds as defined by the KAGB. Board of Management/Management and Supervisory Board You will find more detailed information about the management of the Company and the Supervisory Board at the end of this sales prospectus. Equity capital and additional equity capital The subscribed and paid up capital of the company is 2.56m Euro; the equity capital is 2.55m Euro (as of December 31 st, 2014). Custodian The KAGB provides for separation between the management and the safekeeping of investment funds. The Custodian holds the assets in blocked custody accounts or blocked bank accounts and monitors whether the Company's disposals of assets is in accordance with the provisions of the KAGB and Terms and Conditions of Investment. The investment of assets in the form of bank deposits at other credit institutions, and the disposal of such bank deposits requires the consent of the Custodian. The Custodian must give its approval if the investment/disposal is in accordance with the Terms and Conditions of Investment and the provisions of the KAGB. The Custodian also has the following tasks in particular: ensuring that the provisions of the KAGB and the Terms and Conditions of Investment of the Fund are observed when issuing and redeeming units and calculating the value of the units, ensuring that the consideration for transactions executed for the collective account of the investor comes into its safekeeping within the usual time periods, ensuring that the Fund's income is used in accordance with the provisions of KAGB and the Terms and Conditions of Investment, monitoring credit borrowing by the Company for the account of the Fund and, where appropriate, approving credit borrowing, ensuring that collateral for securities loans are ordered legally and available at any time. Sub custodian services The Custodian has according to his own statements delegated the custodian tasks listed in para. 72 KAGB to the following companies (sub custodians). Please note in this context that the fund is not investing in transferable securities or certificates of deposit in all of the listed countries. Country, intermediary custodian *), Central Custodian Argentina, Banco Santander SA, Caja Valores SA of Australia, National Australia Bank Limited, Clearing House / Austraclear Austria, Unicredit Bank Austria AG, Austrian Control Bank AG Bahrain, HSBC Bank Middle East Limited, Bahrain Bourse Forms Bangladesh, HSBC Limited, Central Depository Bangladesh Limited Belgium, Euro Clear S. A. / NV, Euro Clear SA, Brussels Botswana, Standard Chartered Bank Ltd., Botswana Stock Exchange Brazil, Banco Santander SA, CBLC / BOVESPA Bulgaria, Express Bank, Central Depository AD *) In all countries except Germany, Société Générale SA acts the first intermediary and the depositary as further specified intermediary. issuing and redeeming fund units, Veri ETF-Allocation Defensive (July 2015) 7

8 Canada, Royal Bank of Canada, RBC DEXIA, The Canadian Depository for Securities Chile, Banco Santander Chile SA, deposito Central de Valores SA China, HSBC Bank Company Limited, Colombia, Santander Investment Trust SA, Banco de la Republica Colombia Croatia, Splitska Banka dd, Central Securities Depository of Croatia Cyprus, Generale Bank of Greece (Geniki), Cyprus Central Securities Depository Czech Republic, Komercni banka, SCP Securities Centre of the Czech Republic Denmark, Nordea Bank Danmark A / S, VP Securities Danmark A / S Egypt, National Societe General Bank (NSGB), Misr Company for Central Clearing, Depository and Registry (MCDR) Estonia, Nordea Bank Finland Plc, Estonia Central Securities Depository Finland, Nordea Bank Finland Plc, Euro Clear Finland Ltd. France, Euroclear S. A. / NV Germany,, Clearstream Banking AG, Frankfurt am Main Ghana, Standard Chartered Bank Ltd., Central Depository Securitites Gh. Ltd Greece, Generale Bank of Greece (Geniki), Hellenic Exchanges Hong Kong, Deutsche Bank AG, Hong Kong Securities Clearing Company Limited Hungary, KBC Securities, Keler Ltd. Iceland, Royal Bank of Canada Ltd., Icelandic Securities Depository's (ISD) India, State Bank of India, Central Depository Services India Limited Indonesia, HSBC Corp. Limited, PT Kustodian Sentral Efek Indonesia Ireland, Euro Clear S. A. / NV, Euro Clear Israel, Bank Hapoalim BM, Tel Aviv Stock Exchange Clearing House Italy, Société Générale Securities Services SpA, Monte Titoli Japan, HSBC Corp Limited, Japan Securities Depository Center, JASDEC Jordan, HSBC Limited, The Securities Depository Center Kazakhstan, HSBC Bank Limited, Central Securities Depository Kenya, Standard Chartered Bank Ltd., Central Securities & SettlementCorporation Limited Kuwait, HSBC Bank Limited, Korea Securities Depository Latvia, Swedbank AS, Lativian Central Depository Lithuania, SEB Bank, Central Securities Depository of Lithuania Luxembourg, Brown Brothers Harriman SCA (Luxembourg), Clearstream Banking Luxembourg, CACEIS Bank Luxembourg, Société Générale Bank & Trust Luxembourg, Malaysia, HSBC Bank Limited, Bursa Malaysia Depository Sdn Bhd. Malta, HSBC Bank Plc., Malta Stock Exchange Mauritius, HSBC Limited, Central Depository & Settlement Co. Ltd Mexico, Banco Santander SA, S.D. Indeval Morocco, Societe Generale Marocaine de Banques, Maroclear Netherlands, Euro Clear S. A. / NV New Zealand, HSBC Coorp Limited, Reserve Bank of New Zealand Norway, Nordea Bank Norge ASA, VPS ASA Oman, HSBC Bank Limited, National Bank of Oman Peru, Citibank SA, Cavali S. A. Philippines, HSBC Corp Limited, Central Depository Incorporated Poland, Société Générale SA, registered branch Poland, KDPW Portugal, Banco Comercial Portugues SA, Interbolsa & SITEME Romania, Banque de Roumaine Develop ment (FRG), The Romanian Central Securities Depository Russia, Rosbank, The National Settlement Depository Saudi Arabia, The Saudi British Bank, Saudi Stock Exchange Singapore, HSBC Corp Limited, The Central Depository Pte Limited 8 Veri ETF-Allocation Defensive (July 2015)

9 Slovakia, CSOB, The Central Securities Depository of the Slovak Republic Slovenia, Unicredit Bank Austria AG, Central Securities Clearing Corporation South Africa, Société Générale SA, registered branch South Africa, STRATE South Korea, HSBC Corp Limited, KSD Spain, Société Générale SA, Spain branch, IBERCLEAR Sweden, Nordea Bank AB, Euro Clear Sweden AB Switzerland, Societe Generale SA, Switzerland branch, SIX SIS AG Taiwan, HSBC Corp Limited, Taiwan Securities Central DepositoryCo., Ltd Thailand, HSBC Corp Limited, Thailand Securities Depository Co., Ltd. Tunisia, Union International de Banque Tunis, STI CODEVAM Turkey, Citibank AS, Central Registry Agency Inc. Ukraine, ING Bank, Ukrainian Securities Depository United Arab Emirates, HSBC Bank Limited, NASDAQ Dubai United Kindom, Euroclear S. A. / NV, Euroclear USA, Brown Brothers Harriman & Co., DTC Vietnam, HSBC Bank Limited, Vietnam Securities Depository The following conflicts of interest may arise from this transfer: Possible conflicts of interest could result, if the custodian or a sub custodian delegates defined custody tasks to another service provider. If this service provider would be a company related to the company or to the custodian, these relationship set up of service provider and the company or the custodian could result in potential conflicts of interest. In order to avoid potential conflicts of interest the custodian will make sure that the listed sub custodians will always respect the duties and restrictions laid out in para. 70 sec. 1, 2, 4 and 5 KAGB and para. 72 KAGB. The custodian has implemented rules on his organisation and processes in order to make sure that conflicts of interest that might arise from sub custody will be avoided by appropriate separation of task in terms of functions and hierarchies. By implementing rules on his organisation and processes the custodian has also made sure that potential conflicts of interest will be properly identified, controlled, supervised and disclosed to the investors of the fund. The Company can not accept any responsibility for the accuracy and completeness of the information in detail. Liability of the Custodian The custodian shall be liable for the loss of a financial instrument held in custody by the custodian or by a subcustodian, to which the safekeeping of financial instruments was transferred according to para. 72 sec. 1 KAGB. The custodian is not liable if it can prove that the loss is due to external events whose consequences were unavoidable despite all reasonable countermeasures. Further claims arising from the provisions of civil law based on a contract or on provisions concerning unlawful acts, shall remain unaffected. The custodian shall be liable for any other losses suffered because of the custodian's negligent or intentionally failure to fulfill their obligations under the KAGB. For all other losses, the custodian shall only be liable if it negligently or intentionally failed to fulfill their obligations under the provisions of KAGB. The custodian may, in principle, deny its liability for a loss of financial instruments that were in custody with a sub custodian in accordance with para. 73 KAGB, if the custodian can prove that all the conditions for outsourcing its custodial functions in accordance with para. 73 KAGB are met, if there is a written contract between the custodian and the sub custodian transferring the liability of the custodian explicitly to this sub custodian and allowing the investment management company, to raise his or her claim because of loss of financial instruments against the sub custodian or allowing the custodian to raise such a claim for her and if there is a written contract between the custodian and the acting investment management company, in which a discharge of liability of the custodian is explicitly allowed and an objective reason for the contractual agreement of such a liability exemption is disclosed. If foreign regulation requires that certain financial instruments must be held by a local entity and there are no local entities that satisfy the requirements for outsourcing according to para. 73 sec. 1 point 4 letter b Veri ETF-Allocation Defensive (July 2015) 9

10 KAGB, the custodian can deny its liability if the conditions set out in para. 77 sec. 5 no. 1 6 KAGB are met. The interpretation of legal liability requirements follows Art. 100 to 102 of the Level 2 Regulation on the AIFM Directive. The custodian is basically responsible for all assets that are held in custody by himself or, with his consent, by another entity. In case of loss of such an asset the custodian is liable with respect to the fund and its investors unless the loss is triggered by events beyond the control of the custodian. For damages other than the loss of an asset, the custodian shall basically only be liable if it has at least negligently failed to fulfill his obligations under the provisions of KAGB. Name, legal form and registered office of the custodian Société Générale S. A. Paris, Frankfurt Branch, Neue Mainzer Straße 46 50, has assumed the role of the custodian for the Fund. The custodian is a credit institution under French law. His three main activities are retail banking & Specialized Financial Services (deposits and lending business specialized financial services), corporate and investment banking and global investment management and services business. Notice of risk Before the decision to buy the units in the Fund, investors should read the following notice of risk alongside the other information contained in this sales prospectus carefully and take this into account when making an investment decision. The occurrence of one or more of these risks may impair Fund performance or that of its assets and therefore also have a disadvantageous impact on unit values. If an investor sells units to the Fund at a time when the market prices for assets in the Fund have fallen below their acquisition price, the investor will not recoup all of the money invested in the Fund. The investor may lose the capital invested in the Fund in part or in individual cases even in full. Increases in value are not guaranteed. The investor's risk is limited to the amount invested. The investor has no obligation to provide additional capital above what was previously invested. In addition to the risks and uncertainties described below or at other points in the sales prospectus, the performance of the Fund may be adversely affected by various other risks and uncertainties which are currently unknown. The order in which the following risks are listed does not provide an indication about either their likelihood or the extent or significance of individual risks. Risks of investing in a Fund The risks that are typically associated with investments in a UCITS are described below. These risks may have a detrimental effect on the value of the unit, the capital invested by the investor and the period of time for which the Fund investment is planned to be held by the investor. Variation in the Fund's unit value The Fund's unit value is calculated from the value of the Fund, divided by the number of the units outstanding. The value of the Fund corresponds to the total of the market values of all of the assets in the Fund minus the 10 Veri ETF-Allocation Defensive (July 2015)

11 total of the market values of all of the Fund's liabilities. The Fund's unit value is therefore dependent on the value of the assets held in the Fund and the level of the liabilities in the Fund. If the value of these assets falls or the value of the liabilities rises, the Fund's unit value falls. Influence of the individual performance caused by tax aspects The tax treatment of capital gains depends on the individual relationships of the relevant investor and may be subject to changes in the future. The investor should contact his or her own tax advisor for individual questions in particular when it comes to their individual tax situation. Suspension of unit redemption The Company can temporarily suspend the redemption of units under extraordinary circumstances that make suspension appear necessary when the interests of investors are taken into account. Extraordinary circumstances as defined above may be economic and political crises, redemption requests to an extraordinary extent and the closure of exchanges or markets, trading restrictions or other factors that adversely affect the calculation of the unit value. The units cannot be liquidated by the investor in this period of time. Even in the event of suspending the redemption of units, the unit value may fall; e.g. if the Company is forced to sell assets under the market value when units cannot be redeemed. The unit price after restarting the redemption of units may be lower than the one before the redemption was suspended. Changing the investment policy or investment conditions The Company may modify the investment conditions with the approval of BaFin. If the investment conditions change, the provisions relating to the investors may also change. The Company may modify the Fund's investment policy, for example by changing the investment conditions, or it may increase the costs charged to the Fund. The company may modify the investment policy within the legally and contractually allowed investment spectrum without a formal change of the investment conditions and without prior BaFin approval. In this case risks connected with the investment funds may change. Dissolution of the Fund The Company has the right to terminate the management of the Fund. The Company may completely dissolve the Fund after terminating the management. The right to manage the Fund is automatically transferred to the Custodian after a six month termination period. There is therefore a risk that the investor will not be able to realise his planned holding period. When transferring the Fund to the Custodian, the Fund may be subject to other taxes in addition to German income taxes. If the Fund's units are removed from the investor's security account after ending the liquidation process, the investor may be subject to income taxes. Transfer of all Fund assets to another open public investment fund (merger) The Company may transfer all of the Fund's assets to another UCITS. The investor may in this case (i) redeem the units, (ii) retain them with the consequence that he becomes an investor in the receiving UCITS, (iii) or exchange them for units in an open public investment fund with comparable investment principles if the Company or a company associated with it manages such a Fund with comparable investment principles. This applies equally if the Company transfers all of the assets of another open public investment fund to the Fund. The investor must therefore make another investment decision ahead of time as part of the transfer. Income tax may be incurred when redeeming the unit. When exchanging the units for units in a Fund with comparable investment principles, the investors may be charged taxes, for example if the value of the units received is higher than the value of the old units at the time of purchase. Profitability and fulfilment of the investor's investment objectives There is no guarantee that the investor will achieve the desired investment success. The Fund's unit value may fall and result in losses for the investor. There are no guarantees by the Company or a third party with regard to a particular minimum payment commitment on return or a particular investment success for the Fund. An issuing surcharge or a redemption fee may reduce or even nullify the success of an investment, in particular if the investment term is short. Investors may receive an amount that is lower than the sum originally invested. Veri ETF-Allocation Defensive (July 2015) 11

12 Risks of the Fund's negative performance (market risk) The risks set out below are linked to the invested assets of the funds. The risks may affect the performance of the Fund or the assets held in the Fund and hence affect the unit value and the investors' capital invested. Value change risks The assets in which the Company invests for the Fund are subject to risks. They can therefore lose value such that the market value of the assets falls compared to the cost price or the cash or future prices may see different development. Capital market risk The development of securities prices depends in particular on the development of the capital markets, which in turn are dependent on the general situation of the global economy and on the economic and political conditions in the countries in question. The general development of securities prices, especially on a stock exchange, can also be affected by irrational factors, such as moods, opinions, and rumours. Variations in rate and market values may also be due to changes in interest rates, exchange rates or the creditworthiness of an issuer. Share price risk It has been demonstrated that shares are subject to strong rate variations and therefore also the risk of a decline in prices. These price variations are affected in particular by the development of the profits of the issuing companies and the developments of the industry and macroeconomic developments. The confidence of market participants in the relevant company may also affect the price development. This applies in particular to companies whose shares are only admitted for trading on an exchange or another organised market for a shorter period of time; these may already result in low changes to forecasts on strong rate movements. If the percentage of freely tradable shares held by many shareholders (so called free float) is low, even smaller purchase and sale orders of this share may have a strong effect on the market price and thus result in higher rate variations. Interest rate risk An investment in securities bearing fixed interest rates, bears the possibility that the market interest rate existing at the time the security is issued will change later. As a rule, the prices of fixed interest securities fall when market interest rates rise above the interest rates at the time of acquisition. Similarly, if the market interest rate falls, the prices of fixed interest securities rise. These price changes cause the current yield on fixed interest securities to correspond approximately to the current market interest rate. The size of these price fluctuations differs, however, according to the (remaining) maturity of the fixed interest securities. Fixed interest securities with shorter maturities have less price risk than fixedinterest securities with longer maturities. As a rule, fixed interest securities with shorter maturities have lower yields than fixed interest securities with longer maturities. Due to their short time to maturity of a maximum of 397 days, money market instruments tend to have a low level of price risk. In addition, the interest rates of various interest rate related financial instruments issued in the same currency may have different development with a comparable remaining term. Price risk of convertible and warrant bonds Convertible and warrant bonds securitise the right to exchange the bond for shares or purchase shares. The development of the value of convertible bonds or warrant bonds is therefore dependent on the price development of the share. The risks to the performance of the underlying shares can therefore also affect the performance of the convertible bonds and warrant bonds. Warrant bonds that give the issuer the right to provide the investor with a number of shares determined in advance (reverse convertibles) instead of the repayment of a nominal amount are dependent to an increased extent on the relevant share price. Risks associated with derivatives trading The Company may enter into derivatives transactions for the Fund. Buying and selling options or entering into futures contracts or swaps is associated with the following risks: Changes in the price of the underlying instrument may reduce the value of an option right or futures contract. If the value reduces until they are valueless, the Company may be forced to allow the purchased rights to expire. The Fund can also suffer 12 Veri ETF-Allocation Defensive (July 2015)

13 losses from changes in the value of the assets underlying a swap. The value of the Fund's assets can be more strongly influenced by the leverage effect of options than would be the case if the underlying instruments were acquired directly. It may not be possible to determine the risk of loss when concluding the transaction. There may be a lack of a liquid secondary market for a particular instrument at any specific time. It may not be possible to neutralise (close) a position in the derivatives under certain circumstances. The purchase of options entails the risk that the price of the underlying instrument might not change as expected, leading to the expiration of the option without exercise and consequent loss of the option premium paid by the Fund. When options are sold, there is a risk that the Fund will be required to purchase assets at a price higher than the current market price or to deliver assets at a price lower than the current market price. In that case, the Fund suffers a loss in the amount of the difference in prices minus the option premium collected. For futures contracts there is a risk that the Company will be required, on the Fund's account, to bear the difference between the rate set on conclusion and the market rate at the time of the closing out or maturity of the transaction. The Fund would therefore suffer losses. The risk of loss cannot be determined when concluding the futures contract. Closing out a position with an offsetting transaction, when necessary, generates costs. The forecasts made by the Company on the future development of fundamental assets, interest rates, prices and exchange markets may prove to be incorrect later. The assets on which the derivatives are based may not be purchased or sold at a favourable time or have to be purchased or sold at an unfavourable time. Potential losses may be incurred through the use of derivatives and these may be unforeseeable under certain circumstances and may even exceed the incoming payments. Over the counter (OTC) transactions may involve the following risks: There may be no organised market, so the Company may find it difficult or impossible to sell the financial instruments purchased on the OTC market on the Fund's account. The conclusion of an offsetting trade (closing out) may be difficult, not possible or associated with significant costs as a result of the individual agreement. Risks associated with securities lending transactions If the Company grants a securities loan on the Fund's account, it transfers this to a borrower who transfers the securities back at the end of the transaction in the same type, quantity and quality (securities lending). The Company has no possibility to dispose of the securities lent for the duration of the transaction. If the security loses value for the duration of the transaction and the Company wants to sell the security completely, it must terminate the loan and wait for the normal settlement cycle, which creates a loss risk for the Fund. Risks associated with sell and repurchase transactions If the Company enters into a sell and repurchase transaction, it sells securities and is obliged to buy them back at a supplement at the end of the term. The repurchase price to be paid at the end of the term by the seller in addition to the supplement is set on conclusion of the transaction. If the securities placed under sale and repurchase agreements lose value during the transaction's term and the Company intends to sell them to limit the loss of value, it can only do this by exercising the advance termination right. The advance termination of the transaction may be accompanied by financial losses for the Fund. It may become clear that the supplement to be paid at the end of the term is higher than the income that the Company has generated by reinvesting the cash received. If the Company places securities in a sale and repurchase transaction, it buys these and must sell them again at the end of a term. The repurchase price is already stipulated when the transaction is concluded. The securities taken under sale and repurchase agreements act as collateral for the provision of liquidity to the contractual partners. Any increases in the value of the securities do not benefit the Fund. Veri ETF-Allocation Defensive (July 2015) 13

14 Risks associated with receiving collateral The Company receives collateral for derivatives, securities lending and sale and repurchase transactions. Derivatives, securities on loan or securities held under sale and repurchase agreements may increase in value. The collateral provided would no longer be enough to cover the full delivery and return claims of the Company to the counterparties. The Company may create cash collateral on blocked accounts, high quality sovereign bonds or invest in money market funds with short term structures. The bank at which the credit balance is held may however fail. Sovereign bonds or money market bonds may see negative performance. When the transaction ends, the full amount of the invested collateral may no longer be available, but must be returned to the Company for the Fund at the level originally granted. The Company is obliged to restock the collateral for the Fund to the granted amount and to balance out the loss suffered by the investment. Risk associated with securitisation positions without retained interest The Fund may only purchase securities that securitise loans (loan securitisation positions) and were issued after 1 January 2011 if the lender retains at least 5% of the volume of the securitisation as a so called retained interest and complies with other requirements. The Company is therefore obliged to start remedial measures in the interest of the investors if the loan securitisations that were issued after this key date do not comply with these EU standards. As part of these remedial measures, the Company may be forced to sell such loan securitisation items. As a result of the legal regulations for banks, Fund companies, and in future possibly also for insurance companies, there is the risk that the Company will not be able to sell the loan securitisation positions held in the Fund, or only with heavy discounts or after a long delay. Inflation risk Inflation involves a risk of loss of value for all assets. This also applies to assets held in the Fund. The inflation rate may be above the increase in the Fund's value. Currency risk The Fund's assets may be invested in currencies other than the Fund's currency. The Fund receives the income, repayments and proceeds from such investments in the relevant currency. If the value of this currency declines in relation to the Fund currency, the value of such assets decreases and so does the value of the Fund. Concentration risk Concentrating investments in certain assets or markets create a particularly highly dependence on the development of these assets or markets. Risks relating to the investment in investment units The risks of the investment funds acquired for the Fund (so called "target fund") are closely connected with the risks associated with the assets held in these target funds and/or the investment strategies pursued by these target funds. However, since the managers of the individual target funds act independently of each other, several target funds may pursue the same or opposing investment strategies. This could result in a cumulative effect of existing risks and any opportunities may cancel each other out. The Company is generally not able to monitor the management of the target funds. Their investment decisions do not necessarily have to agree with the assumptions or expectations of the Company. The current composition of the target funds will often not be made known to the Company in a timely manner. If the composition does not correspond to its assumptions or expectations, the Company may not react by redeeming the target fund units until a considerable amount of time has passed. Open ended investment funds in which the Fund purchases units may temporarily suspend the redemption of units. This prevents the Company from selling the units of the other fund by redeeming them to the management company or custodian of the other fund in return for payment of the redemption price. Risks associated with the range of investments Under the investment principles and investment limits prescribed by the law and investment terms, which provide for a very wide range of investments for the Fund, the actual investment policy for the Fund may be oriented towards a focus on the acquisition of assets from, for example, only a small number of sectors, markets or regions/countries. The focus on a few special investment sectors may be associated with particular risks (e.g. narrowness of the market, high fluctuation margin within certain economic cycles). The annual 14 Veri ETF-Allocation Defensive (July 2015)

15 report provides subsequent information on the content of the investment policy for the past financial year. Risks of restricted or increased liquidity of the Fund (liquidity risk) The risks stated below may adversely affect the liquidity of the Fund. This may result in the Fund temporarily or permanently being unable to comply with its payment obligations or the Company not being able to fulfil the return requests from investors on a temporary or permanent basis. The investor may not realise the planned holding period and the invested capital or parts thereof may not be available for an undetermined period of time. The realisation of liquidity risks may also lower the net asset value of the Fund and therefore the unit value, for example if the Company is forced to sell assets for the Fund below the market value if permissible by law. Risks associated with the investment in assets Assets that are not admitted to the official market on a stock exchange or included in an authorised exchange or another organised market may also be acquired for the Fund. These assets may only be sold on discounts, delays or indeed at all. Even assets admitted for trading on an exchange may, depending on the market situation, volume, timeframe and planned costs, not be sold or only at high price discounts. Although it is only possible to purchase assets for the Fund that can in principle be liquidated at any time, it cannot be ruled out that they can only be sold temporarily or permanently whilst realising losses. Risk associated with finance liquidity The Company may, at the Fund's expense, accept loans. There is the risk that the Company will not be able to take on appropriate loans or only at much worse conditions. Loans with a variable interest rate may also see negative consequences as a result of rising interest rates. Inadequate finance liquidity may affect the liquidity of the Fund with the consequence that the Company can be forced to sell the assets ahead of time or at worse conditions than those planned. Risks associated with increased redemptions or expenditure As a result of purchase and redemption requests from investors, liquidity is added or removed from the Fund's assets. The inflows and outflows may result in net additions or deductions from the Fund's liquid funds after balancing. This net inflow or outflow may cause the fund manager to buy or sell assets resulting in transaction costs. This applies in particular if the inflows and outflows exceed or do not reach the limit set for the Fund by the Company. The resulting transaction costs are charged to the Fund's assets and may adversely affect the Fund's performance. For inflows, increased Fund liquidity may adversely affect the Fund's performance if the Company cannot invest the Funds at appropriate conditions. Risk for holidays in certain regions / countries According to the investment strategy, the fund s investments are to be made particularly in certain regions / countries. Due to local holidays in these regions / countries differences between the trading days on exchanges in these regions / countries and unit price calculation days of the Fund may occur. The fund may be able to react on a day which is not a valuation day, but a trading day in those markets; or the fund may not be able to trade on a valuation day because markets are closed due to a local holiday. As a result, the Fund may be prevented from selling assets when it would be necessary. This may affect the ability of the Fund to comply with redemption requests or other payment obligations. Counterparty risk including loan and receivables risk Below are listed the risks which may arise out of a contract between the investment fund and third party (so called counterparty). There is a risk that the counterparty may not be able to fulfil its contractual obligations. These risks may affect the growth in value of the fund and hence affect the share value and the investors' capital invested. Counterparty default risk/counterparty risks (except for central counterparties) The failure of an issuing party (hereinafter referred to as the "issuer") or a contractual partner (counterparty) against whom the Fund has claims, may result in losses for the Fund. Issuer risk is the effect of particular developments at the issuer which affect the price of a security separately from the general tendencies in the capital markets. Even when the utmost care is exercised in selecting the securities, it cannot be ruled out that there may be losses due to the financial collapse of issuers. The party of a contract entered into on behalf Veri ETF-Allocation Defensive (July 2015) 15

16 of the Fund may fail in full or in part (counterparty risk). This applies to all contracts entered into for the account of the Fund. Risk associated with central counterparties A central counterparty ("CCP") acts as an intermediate institution in certain transactions for the Fund, in particular for derivative financial instruments. In this case he acts as the buyer to the seller and as the seller to the buyer. A CCP secures his counterparty risks using a range of protective mechanisms that enable him at any time to net out losses from the transactions entered into, for example using so called additional payments (e.g. collateralisation). In spite of these protective mechanisms, the possibility that a CCP may fail cannot be excluded and this could affect claims by the Company for the Fund. This may create losses for the Fund that are not protected. Counterparty credit risks associated with repurchase transactions For sale and repurchase transactions security is provided by the consideration of the contractual partner. If the contractual partner fails during the term of the sale and repurchase agreement transaction, the Company has a right to sell the securities in the sale and repurchase transaction or cash. There may be a risk of loss for the Fund because the security provided is no longer enough due to the worsening in the meantime of the creditworthiness of the issuer or rising prices for the securities given in the sale and repurchase agreement in order to cover the full amount of the Company's right to reassignment. Counterparty risks associated with securities lending transactions If the Company grants loans for securities for the account of the Fund, it must be provided with adequate collateral in the event of default of the contractual partner. The scope of the collateral matches at least the market value of the securities transferred for lending. The borrower must provide additional collateral if the value of the securities granted as loans rises, the quality of the collateral provided declines or a deterioration of the economic conditions occurs and the collateral already provided is not adequate. If the borrower cannot comply with this obligation to provide additional collateral, there is the risk that the right to reassignment is not completely secured if the contractual partner fails. If the collateral is held under custody at an institution that is not the Fund's Custodian, there is also the risk that this cannot be sold immediately or in full if the borrower fails. Operational and other risks to the Fund The risks listed below may for example arise out of insufficient internal processes or human or system failure within the company or third parties. These risks may affect the performance of the fund and hence negatively affect the share value and the investors' capital invested. Risks associated with criminal acts, grievances or natural disasters The Fund may be the victim of fraud or other criminal acts. It may suffer losses from misunderstandings or mistakes by employees of the Company or external third parties or be damaged by external events such as natural disasters. Country or transfer risk There is the risk that a foreign debtor, despite being able to pay, cannot provide payment in good time or at all or only in a different currency as a result of the inability or unwillingness of its country of domicile to transfer the currency or for other reasons. Thus, for example, payments to which the Company is entitled to, for the account of the Fund may fail to be made or may be made in a currency that is no longer convertible or must take place in another currency due to currency exchange restrictions. If the debtor pays in another currency, this position is subject to the currency risk stated above. Legal and political risks Investments may be made for the Fund in legal systems where German law does not apply or in the event of legal disputes where the court of jurisdiction is outside Germany. The resulting rights and duties of the Company on account of the Fund may vary from those in Germany to the disadvantage of the Fund or investor. Political or legal developments including changes to the legal framework in these jurisdictions may not be recognised by the Company or recognised too late or result in restrictions relating to assets that can be or have already been purchased. These consequences may also result if the legal environment changes for the Company and/or administration of the Fund in Germany. 16 Veri ETF-Allocation Defensive (July 2015)

17 Changes to tax conditions, tax risk The tax information assumes the current legal situation. It is directed towards persons who are fully subject to income tax or corporation tax in Germany. There is no guarantee, however, that this evaluation of the tax situation will not change due to changes in the law, court rulings or bulletins issued by the tax authorities. The change of the Fund's tax bases that were incorrectly determined for previous financial years (e.g. based on field audits) can, in the case of a tax correction that is unfavourable for an investor, result in the investor being required to bear a tax burden arising from previous financial years due to the correction, even though he may not have been invested in the Fund at that time. On the other hand, the case may arise in which an investor does not receive the benefits of a tax correction favourable to him for the current and previous financial years, during which he was invested in the Fund, because he redeemed or sold the units before the correction. In addition, a correction of tax data can result in taxable earnings or tax advantages being assessed in a period that differs from the actually applicable assessment period, resulting in adverse effects for some investors. Key personnel risk When the Fund achieves very positive investment results over a certain time period, this success may also be due to the abilities of the persons involved and the correct decisions made by its management. However, the individuals making up the management of the fund can change, and the new decisionmakers could be less successful. Custody risk Custody of assets, particularly in foreign countries, is associated with the risk of loss, which may result from insolvency, violations of the duty of care, or force majeure. Risks associated with trading and clearing mechanisms (settlement risk) The settlement of security transactions via an electronic system, bears the risk that a contractual party delays payment or does not pay as agreed or that the securities are not delivered in good time. Explanation of the Fund's risk profile Profile of the typical investor An investment in the Veri ETF Allocation Defensive Fund is suitable for investors who have experience to some extent with financial markets. The investor must be able and willing to accept fluctuations of unit values and, if applicable, accept a significant loss of capital. Investment objectives, strategy, principles and restrictions Investment objectives and strategy Veri ETF Allocation Defensive is a globally investing fund of funds and acquires predominantly units of exchange traded funds that are compliant with the UCITS directive (ETFs). The focus of investment is on bond ETFs, ie mutual funds that track the development of bond markets. The strategic composition is determined by a systematic and forecast free investment approach. When investing in equity and commodity markets, that can be allocated up to a limit of 30% of the fund, the target funds are selected according to a systematic, rule based trend following approach. The bond market oriented target funds are mainly those which track an index for corporate, sovereign or high yield bonds from developed and newly industrialising countries. The investment objective is to achieve maximum capital appreciation. The risks associated with this investment policy are in the section "Risk Factors Significant risks of fund investment" explained. NO ASSURANCE CAN BE GIVEN THAT THE OBJEC TIVES OF THE INVESTMENT POLICY WILL BE ACHIEVED. Investment instruments The Company may acquire the following assets for the Fund: investment units in accordance with 196 KAGB; securities in accordance with 193 KAGB; bank deposits in accordance with 195 KAGB; money market instruments in accordance with 194 KAGB; derivatives in accordance with 197 KAGB; so called other investment instruments in accordance with 198 KAGB. Veri ETF-Allocation Defensive (July 2015) 17

18 The Company may acquire these assets within the particular limits explained in the sections "Investment restrictions for securities and money market instruments including the use of derivatives and bank balances" and "Other assets and their limits". Details on these eligible assets and the applicable investment limits are explained as follows. Investment units The Company may invest up to 100% of the value of the Fund in units of target funds, if the target funds are open ended domestic or foreign investment funds. The company acquires target fund units in Germany or in other EU member states on behalf of the fund. The target funds may invest a maximum of up to 10% in units of other investment funds in accordance with their contractual terms. The following requirements apply in addition to units in AIF: The target fund must have been admitted in accordance with legal provisions that place it under effective public supervision to protect investors, and there is an adequate guarantee that the authorities can cooperate satisfactorily. The investors' protection level must be equivalent to that of an investor in a domestic UCITS, in particular with regard to the segregation of management and custodianship of assets, borrowing, lending and the short selling of securities and money market instruments. The business of the target fund is reported in the annual and semi annual reports, to enable an assessment to be made of the assets and liabilities, income and operations over the reporting period. The target fund must be a public fund for which the number of units is not limited in terms of numbers and the investors have a right to redeem the units. The investment in units of one and the same target fund is limited to 20% of the investment fund. The investment in AIF is limited to 30% of the investment fund. The Company may not acquire more than 25% of the units issued by a target fund for the account of the Fund. The target funds may temporarily suspend the redemption of units within the statutory framework. In this case the Company may not redeem the units in the target fund with the management company or target fund custodian in return for payment of the redemption price (refer also to the section on "Notice of risks risks relating to the investment in investment units"). The Company's website at investment.de shows whether and to what extent the Fund holds units of target funds that have currently suspended the redemption of units. Securities The Company may acquire securities of domestic and foreign issuers for the account of the Fund if 1. they are admitted to trading on a stock exchange or admitted to or included in another organised market in a Member State of the European Union ("EU") or another signatory to the Agreement on the European Economic Area ("EEA"), 2. they are exclusively admitted to trading on a stock exchange or admitted to or included in another organised market outside the Member States of the EU or outside the other signatories to the Treaty on the European Economic Area or in one of these states, provided that the choice of this stock exchange or organised market has been approved by BaFin. Securities from new issues may be acquired if, in accordance with their offering terms, application for, admission to or inclusion on one of the aforementioned stock exchanges or organised markets indicated in 1. and 2. above must be applied for, and the securities are admitted or included within a year after issue. In this regard securities also refer to Units in closed ended investment funds in a contractual or corporate form that are subject to control by the unit holder (so called corporate control); in other words, the unit holder must have voting rights relating to important decisions and the right to control the investment policy using appropriate mechanisms. The investment fund must also be managed by a legal entity that is subject to the regulations on investor protection, unless the investment fund is created in the form of a company and the activity of the asset manager is not undertaken by another legal entity. Financial instruments secured by other assets or linked to the development of other assets. If derivative components are embedded in such financial 18 Veri ETF-Allocation Defensive (July 2015)

19 instruments, other requirements apply so that the Company may acquire these as securities. The securities may only be purchased under the following conditions: The potential loss that the Fund may incur may not exceed the purchase price of the security. There may be no obligation to make additional payments. The liquidity of the security purchased by the Fund may not result in the Fund no longer being able to comply with the statutory regulations on the redemption of units. This applies whilst taking into account the statutory option of suspending the redemption of units (refer to the section on "Units issuing and redemption of units and the suspension of redemption of units"). A reliable valuation of the security using exact, reliable and common prices must be available; these must either be market prices or be subject to a valuation system that is independent of the security's issuer. Adequate information must be available on the security, either in the form of regular, precise and comprehensive information on the security's market or in the form of any associated portfolio. The security is tradeable. The purchase of the security matches the investment objectives and strategy of the Fund. The risks of the security are recorded appropriately by the Fund's risk management. Securities may also be purchased in the following form: Shares to which the Fund is entitled under a capital increase from Company funds. Securities purchased in the execution of the preference rights belonging to the Fund. Subscription rights may be purchased for the Fund as securities by this definition if the securities from which the subscription rights arise could be included in the Fund. Money market instruments The Company may for the account of the Fund invest in money market instruments that are normally traded on the money market and in interest bearing securities that alternatively have a maturity or residual maturity of at most 397 days from the time of their purchase for the Fund. at the time of their purchase for the Fund have a maturity or residual maturity that is more than 397 days but whose interest rate is, according to the issuing conditions, adapted to the market regularly, at least every 397 days. whose risk profile matches the risk profile of securities that fulfil the criterion of the outstanding term or interest rate modification. Money market instruments may be purchased for the Fund if they 1. are admitted to trading on a stock exchange or admitted to or included in another organised market in a Member State of the EU or another signatory to the Treaty on the European Economic Area, 2. are exclusively admitted to trading on a stock exchange or admitted to or included in an organised market outside the Member States of the EU or outside the other signatories to the Treaty on the European Economic Area or in one of these states, provided that the choice of this stock exchange or market has been approved by BaFin, 3. are issued or guaranteed by the EU, the German Federal Government, special assets of the German federal government, a federal state, another Member State or another central state, regional or local authority or by a central bank of an EU Member State, the European Central Bank or the European Investment Bank, a non Member State or, in the case of a federal state, by one of the members making up the federation, or by a public international body to which one or more Member States belong, 4. are issued by a Company whose securities are traded in the markets indicated in numbers 1. and 2. above, 5. are issued or guaranteed by a credit institution which is subject to supervision in accordance with the criteria under European Union law, or a credit institution which is subject to and complies with supervisory provisions which are, according to BaFin, equal to those of European Union law, 6. are issued by other issuers, and each of these issuers is Veri ETF-Allocation Defensive (July 2015) 19

20 a) a company with equity capital of at least EUR 10 million that creates and publishes its annual financial statements according to the European directive on the annual financial statements of corporations, or b) a legal entity within a corporate group including one or more listed companies that is responsible for the financing of this group, or c) a legal entity that issues money market instruments that are subject to liabilities by using a credit line issued by a bank. These are products that securitise loan claims from banks (so called asset backed securities). All stated money market instruments may only be acquired if they are liquid and their value can be determined precisely at any time. 'Liquid' money market instruments are those which can be disposed of within a sufficiently short time at a limited cost. It should be remembered that the company is bound to redeem units in the Fund should investors so require and dispose of such money market instruments at short notice accordingly. There must also be a precise, reliable system for valuing money market instruments which can be used to determine their net portfolio value, or which is based on market data or valuation models, such as systems which extrapolate acquisition costs. The characteristic of liquidity is considered to have been met for money market instruments if these are authorised or included in an organised market within or outside the EEA, if BaFin has approved the choice of this market. For money market instruments that are not traded on an exchange or authorised for trade on a regulated market (refer to Numbers 3 to 6 above), the issue or issuer of these instruments must also be subject to deposits and investor protection. Therefore appropriate information must be available for these money market instruments that enables an appropriate assessment of the loan risks associated with the instruments, and the money market instruments must be freely transferable. The loan risks may be assessed by a creditworthiness check by a rating agency. The following requirements also apply to these money market instruments unless they are issued or guaranteed by the European Central Bank or the central bank of a Member State of the EU: If they are issued by the following organisations (stated above under Number 3): o the EU, o the German Federal Government, o special assets of the German Federal Government, o a federal state, o another Member State, o another central state public authority, o the European Investment Bank, o a third country, if this is a federal state, a member state of this federal state o an international public law organisation to which at least one EU Member State belongs, there must be appropriate information on the issue or the issuance programme or the legal and financial situation of the issuer before the money market instrument are issued. If they are issued or guaranteed by a bank supervised in the EEA (refer to Number 5 above), appropriate information must be available on the issue or the issuance programme or the legal and financial situation of the issuer before the money market instrument is issued that is updated at regular intervals and when significant facts occur. In addition, data related to the issue or the issuance programme must be available that enables an appropriate assessment of the credit risks associated with the investment on the issue data (e.g. statistics). If they are issued by a bank that is outside the EEA supervision provisions, which in the opinion of BaFin are equivalent to the requirements for a bank within the EEA, one of the following requirements must be met: o The bank maintains residency in one of the socalled group of ten (association of the most important leading industrial countries G10) Member States of the Organisation for Economic Cooperation and Development (referred to below as the "OECD"). o The bank has a rating that is qualified as a minimum as at the so called "investment grade". "Investment grade" refers to a rating of "BBB" or "BAA" or better, as part of the creditworthiness check by a rating agency. 20 Veri ETF-Allocation Defensive (July 2015)

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