Financial Policy

Last Updated: March 2026

1. Introduction

Tamac Asset and Wealth Management GmbH ("Tamac", "we", "us", "our") is an independent asset management and family office services firm. This Financial Policy outlines the principles, procedures and standards that govern our asset management, investment advisory and financial services operations. This policy is designed to ensure transparency, regulatory compliance and the protection of our clients' interests at all times.

Tamac operates under the regulatory frameworks of the United Kingdom and Germany. We are committed to upholding the highest standards of financial conduct, risk management and client care in all aspects of our business.

2. Investment Philosophy and Principles

2.1 Core Investment Principles

Independence: We are not affiliated with any bank, product provider or distribution platform. All investment decisions are made solely in the best interests of our clients.
Active Management: We believe that carefully selected individual investments, combined with thorough research and active portfolio oversight, generate attractive long-term capital returns.
Long-Term Orientation: We focus on long-term mandates and sustainable value creation rather than short-term market speculation.
Risk Discipline: Rigorous risk management is integral to every investment decision. We apply strict position sizing, diversification principles and ongoing portfolio monitoring.
Transparency: We provide clear, comprehensive and timely reporting to all clients, ensuring full visibility into portfolio composition, performance and fee structures.

2.2 Asset Allocation Framework

Our asset allocation process is driven by:

Client-specific objectives, risk tolerance and investment horizon
Macro-economic analysis and market environment assessment
Diversification across asset classes, geographies and sectors
Regular portfolio rebalancing in line with strategic targets
Ongoing due diligence on all holdings and strategies

3. Service-Specific Policies

3.1 Discretionary Asset Management

Mandate Agreement: All discretionary mandates are governed by a written agreement clearly defining investment objectives, risk parameters, benchmarks and restrictions.
Single Stock Risk Management: For large or controlling stock holdings, we implement systematic risk reduction strategies to protect against concentration risk while considering tax efficiency.
Liquidity Management: We employ specialised financial management techniques to enhance asset liquidity where needed, balancing access to capital with return objectives.
Reporting: Clients receive monthly comprehensive reports showing the full structure of assets and liabilities, performance attribution and compliance with mandate guidelines.

3.2 Investment Funds

Tamac manages several thematic investment funds, each governed by its own prospectus and KIID/KID documents:

TAMAC Global Champions Fund: Cross-asset investment approach capturing the best thematic ideas across asset classes.
TAMAC China Champions Fund: Leveraging our extensive China research network to invest in "champion" companies in the world's future largest economy.
TAMAC Technology Champions Fund: Capturing growth from the global internet economy and digital transformation.
TAMAC Green Champions Fund: Investing in companies with the potential to protect the environment and repair damage already caused.

All funds are registered for distribution in the United Kingdom, Germany, Austria, Italy, Luxembourg and Switzerland. Fund documentation is available upon request and must be reviewed before investment.

3.3 Private Equity

Through our Tamac Investment Solutions platform, we provide access to global private equity strategies:

Strategy Selection: We select top-performing funds diversified by investment style, geography and industry, while also supporting niche funds with competitive advantages.
Overcommitment Management: We actively manage liquidity risk by balancing investment commitments against available capital according to our proprietary PE model.
Coverage: Our private equity access spans buyouts, venture capital, growth capital, mezzanine financing and distressed investment strategies.

3.4 Family Office Services

Wealth Structuring: Coordinated deployment of financial, tax and estate planning strategies across asset classes.
Asset Protection: Strategies for asset protection, asset transfer and intergenerational wealth growth.
Fiduciary Services: Acting as administrator and fiduciary, ensuring efficient asset transfer to the next generation, with regular detailed reporting to beneficiaries.
Collaboration: Working alongside clients' existing legal and tax advisors through our network of lawyers and accountants.

4. Risk Management

4.1 Risk Framework

Comprehensive risk identification, assessment and monitoring across all mandates and funds
Portfolio-level risk limits including concentration, liquidity and leverage constraints
Stress testing and scenario analysis conducted on a regular basis
Independent risk oversight with escalation procedures for breach events

4.2 Conflict of Interest Management

As a fully independent firm, Tamac maintains strict policies to identify, manage and mitigate conflicts of interest:

No commission-based product distribution
No proprietary trading against client positions
Full disclosure of any potential conflicts to affected clients
Chinese walls between advisory, execution and research functions

4.3 Best Execution

We are committed to achieving the best possible result for clients when executing orders, taking into account price, costs, speed, likelihood of execution and settlement, size, nature, and any other consideration relevant to the order.

5. Fee Structure and Transparency

5.1 Fee Principles

All fees are disclosed upfront in writing before mandate commencement
Fee structures are aligned with client objectives and investment horizons
No hidden charges, performance-based fees only where explicitly agreed
Annual fee reviews to ensure ongoing fairness and competitiveness

5.2 Types of Fees

Asset Management Fees: Based on assets under management, charged quarterly in arrears
Fund Management Fees: As specified in each fund's prospectus and KID
Family Office Advisory Fees: Fixed or time-based, agreed in the service agreement
Performance Fees: Where applicable, calculated in accordance with pre-agreed high-water mark provisions
Transaction Costs: Third-party costs passed through at cost with full disclosure

6. Client Onboarding and Due Diligence

6.1 Know Your Client (KYC)

Comprehensive assessment of client financial situation, investment objectives and risk tolerance
Verification of identity and source of funds in compliance with AML regulations
Documentation of investment restrictions, preferences and ESG considerations
Regular review and update of client profiles

6.2 Anti-Money Laundering (AML)

Tamac maintains robust AML procedures in compliance with the EU Anti-Money Laundering Directives and UK Money Laundering Regulations:

Client identification and verification procedures
Ongoing monitoring of client transactions and business relationships
Screening against sanctions lists and politically exposed persons (PEP) databases
Reporting of suspicious transactions to the relevant Financial Intelligence Unit
Regular staff training on AML obligations and emerging typologies

7. Reporting and Communication

Monthly Reports: Comprehensive portfolio reports including asset allocation, performance, and risk metrics
Quarterly Reviews: In-depth portfolio reviews with dedicated relationship managers
Annual Statements: Full-year performance summaries and tax documentation
Ad-Hoc Communications: Immediate notification of material market events or portfolio changes
Regulatory Reporting: Compliance with all applicable regulatory reporting obligations

8. Regulatory Compliance

Tamac operates in compliance with:

UK Financial Conduct Authority (FCA) regulations
German Federal Financial Supervisory Authority (BaFin) regulations
EU Markets in Financial Instruments Directive II (MiFID II)
EU Alternative Investment Fund Managers Directive (AIFMD)
EU General Data Protection Regulation (GDPR)
EU Anti-Money Laundering Directives
UK Money Laundering Regulations

9. Complaints Handling

We take all complaints seriously and are committed to resolving them promptly and fairly:

Complaints may be submitted in writing to our compliance team
Acknowledgement within 2 business days of receipt
Investigation by an independent team member
Substantive response within 15 business days
If the complainant is not satisfied, referral to the relevant Financial Ombudsman Service

10. Disclaimer

The value of investments and the income from them may go down as well as up and investors may not get back the amounts originally invested. Past performance is not a reliable indicator of future results. The information on this website does not constitute investment, legal, accounting or tax advice. Tamac makes no representation or warranty, express or implied, with respect to the fairness, correctness, accuracy, reasonableness or completeness of any of the information contained herein.

11. Contact Information

TAMAC
Franz-Joseph-Straße 9, 80801 Munich, Germany
Phone: +49 89 1208 5268
Email: info@tamac-fn.it.com
Business hours: Monday – Friday: 9:00 AM – 6:00 PM

Response commitment: We will respond to all financial policy inquiries within 3 business days.