DISCLAIMER

This internet website is provided for information only and is not in any circumstances intended to constitute advice as to any person who views this website or any other person buying, selling or subscribing for any investment or engaging in any other transaction. Nothing on this website constitutes an invitation or inducement to any person to engage in investment actively (as defined in section 21(8) of the UK Financial Services and Markets Act 2000) with ApexRed IR or any other person.

This website is offered to professionals for informational purposes only and does not constitute an offer to sell or to buy any securities nor advice on the buying or selling of securities. Before making any investment, potential investors should carefully read the relevant offering memorandum or prospectus which contains the appropriate information needed to evaluate the investment and provides important disclosures regarding risks, fees and expenses. Any offer or solicitation will be made only through relevant offering memorandum or prospectus and subscription agreement and is qualified in its entirety to the terms and conditions contained in such documents.

PRIVACY AND SECURITY

In order to maintain the security of its systems, to protect its staff and to detect fraud and other crimes, ApexRed IR reserves the right to monitor all internet communications, including web and e-mail traffic, into and out of its domains. Monitoring includes checks for but not limited to viruses and other malignant code, criminal activity and use or content which is unauthorised.

EU GDPR

The contact for service for EU GDPR in the EU is Stephen McHugh, Edificio Al Jarafe, Benlamadena, Spain and mchugh@apexred.com

CONFLICTS OF INTEREST AND MATERIAL INTEREST

ApexRed IR is required to manage conflicts of interest fairly. When the firm has or may have a conflict of interest between itself and a client or between one client and another client the firm pays due regard to the interests of each client and manages conflicts of interest fairly.

ApexRed IR takes reasonable steps to ensure fair treatment of its clients and discloses the interest to its clients either orally or in writing before it provides advice and is able to demonstrate that the client does not object. When it is not practical for the firm to act as above, it may take steps to ensure fair treatment for its clients by relying on a policy of independence as below.

INDEPENDENCE POLICY

ApexRed IR holds itself out to clients as providing an independent and impartial service. All employees maintain this independence and disregard any other interest they, ApexRed IR or other clients may have when providing advice or in any way communicating with or acting for a client.

Employees disregard any arrangement or interest which is likely to influence in a manner material to the client the advice which the employee gives or the decisions taken. This is observed at all times and all advice and decisions are given without regard to other interests. If any employee believes his independence is compromised, he does not continue in his duties until the situation has been discussed with the Compliance Officer.

In a particular case, ApexRed IR may be required to consider taking other steps, such as specific disclosure. An employee should consult with the Compliance Officer if that employee considers a conflict of interest or a material interest is involved.