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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”), Clarity Capital KCSP Ltd. (the “Portfolio Manager”) respectfully brings the following to your attention:

The Portfolio Manager holds an Israeli 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.

Clarity Capital Group is a global investment management firm with offices in Israel and New York, providing wealth and investment management services to institutional and individual investors worldwide, including: high-net-worth individuals, families, endowments, foundations and institutions, since 2006.

The Client acknowledges that the following entities are related to the Portfolio Manager and engage in management of Financial Assets including Investment Funds, and that the Portfolio Manager and/or entities included in the PM’s Group, have an interest in such entities as detailed below:


  1. KCPS Capital Management Ltd. (“KCPS CM”)– a distributor of Investment Funds, the manager and general partner of Clarity Private Income Portfolio (Cayman) LP.

  2. Clarity Capital Investment Services Ltd. – the general partner and manager of Clarity Private Income Fund II (Cayman) LP..

  3. Andorra Banc Agricol Reig, S.A – a banking institution based in Andorra, being the controlling shareholder of the Portfolio Manager.

  4. Sigma Portfolio Management Ltd. (“Sigma PM”) - an Israeli company which manages investment portfolios and is engaged in investment marketing;

  5. Sigma Premium Ltd. (“Sigma Premium”)- an Israeli company which manages investment portfolios and is engaged in investment marketing for Eligible Clients as such term defined in the Investment Advice Law.

  6. Sigma Mutual Funds Ltd. (“Sigma MF”)– an Israeli company which manages a variety of mutual funds.

  7. Sigma Financial Planning Pension Insurance Agency (2011) Ltd. ("Sigma Financial") which engages in the marketing of pension products, pension funds and other insurance products.

  8. Any other entity in which one or more of the aforementioned entities have an interest (as specified in this Appendix D and as may be updated from time to time in the Portfolio Manager’s website).


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 Sigma MF that are listed on the Portfolio Manager website and revised from time to time.

  • Structured products – from time to time, Sigma PM and Sigma Premium purchase 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 Portfolio Manager website and revised from time to time. Sigma Premium 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 KCPS CM is provided and revised from time to time on the Portfolio Manager website.

  • Sigma Financial may be deemed to have an affiliation to institutional bodies due to its receipt of commissions for the marketing of products managed by them, which constitute a "financial asset". Such institutional bodies may be deemed as affiliated entities of the Portfolio Manager, and the Portfolio Manager may be deemed to have an affiliation with such products which are managed by them. Such institutional bodies may include the entire insurance companies and management companies of pension funds in the market, or any one of them. The updated list of the institutional bodies and of the pension products, pension funds and other insurance products which are marketed by the Sigma Financial, as updated from time to time, may be viewed in the Portfolio Manager’s website.


Due to said interest of the companies to certain financial assets, the Portfolio Manager 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.

Fair Disclosure

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