FUTURUM CAPITAL ASSET MANAGEMENT LTD., a Brazilian limited liability company headquartered in the City of São Paulo, State of São Paulo, at Rua Girassol, No. 1033, Room 10, Vila Madalena, ZIP Code 05433-002, registered with the CNPJ/ME under No. 48.818.002/0001-19 (“Futurum” or “Company”), will conduct suitability procedures, as per CVM Resolution No. 30, dated May 11, 2021 (“Resolution 30”), as amended, to verify the adequacy of products, services, and operations to clients' profiles through the periodic preparation and updates of investor profiles, taking into account their financial capacity, knowledge of finance, qualifications, and experience in investment matters, their investment objective, and their risk tolerance, according to the information obtained by the Company through the Suitability Questionnaire attached to this policy as Annex I.
For clients who fit the definition of a professional investor under Resolution 30, the statement contained in Annex II must be obtained.
The purpose of the suitability procedure is to establish formal processes that enable verifying the adequacy of the investment made by the client to the risk profile assigned to them, taking into account their financial situation, experience in investment matters, degree of tolerance to volatility, and the objectives sought when requesting Futurum's services, including: a) understanding the investor's profile, expectations, restrictions, and investment objectives according to their current and future economic-financial needs, observing risk standards, the need for liquidity, and the return time frame; and b) providing selection, allocation, and reallocation services for financial assets through portfolio management.
Verifying the investor's risk profile is a process that combines personal data, such as the investor's profile, objectives, investment goals, sources of resources, etc. Each individual requires a customized portfolio due to having their own profile, needs, goals, objectives, and investment horizons.
The verification of the client’s profile must take into consideration: i) Whether the product, service, or operation is suitable for the client's investment objectives; ii) Whether the client's financial situation is compatible with the product, service, or operation; iii) Whether the client has the necessary knowledge to understand the risks related to the product, service, or operation.
To ensure compliance with the verification, Futurum's collaborators must analyze: i) The period the client wishes to maintain the investment; ii) The client's stated preferences regarding risk assumption; iii) The purposes of the investment; iv) The amount of regular income declared by the client; v) The value and assets that make up the client's wealth; vi) The future need for resources declared by the client; vii) The types of products, services, and operations with which the client is familiar; viii) The nature, volume, and frequency of operations already performed by the client in the securities market, as well as the period during which such operations were carried out; and ix) The academic background and professional experience of the client (individual).
Futurum has defined 3 risk profiles (Conservative, Moderate, and Adventurous) that evolve according to risk and return parameters and asset class allocation.
The table below provides a brief description of the risk appetite of each profile and its respective score range (obtained from the responses to the Suitability Questionnaire for the purpose of defining the profile).
ProfileBrief descriptionConservativeLow tolerance for risks, aiming to preserve capital. Moreover, even if the client is willing to take more risks in search of differentiated returns, they need to redeem their investment in the short term.ModerateWillingness to take some risk in search of differentiated return in the medium term. Additionally, there is no need for liquidity in the short term. Likely to diversify their investments in bolder alternatives, but with a low risk of loss.AdventurousHigh tolerance for risks, with no or low need for liquidity in the short or medium term. The client accepts the characteristic fluctuations of risk markets and possible losses beyond the invested capital in search of differentiated returns in the long term.Export to Spreadsheets
The Suitability Questionnaire is an integral part of the Individual Customer Registration Form. For purposes of updating the investor profile, the Suitability Questionnaire can be delivered individually.
The Suitability Questionnaire consists of multiple-choice questions, allowing for the assessment of the investor's financial situation, experience in investment matters, objectives, investment horizon, risk tolerance, and liquidity needs.
Below is the scoring table:
Weight
1
1
2
3
2
2
3
2
3
2
Question
1
2
3
4
5
6
7
8
9
10
A
1
1
1
3
2
2
3
2
3
-
B
2
2
2
6
4
4
6
4
6
-
C
3
3
3
9
6
6
9
6
9
-
D
5
4
4
8
8
8
-
E
4
-
Each of the responses has a distinct value, so that, when added to the questions, it will yield the value, in points, of the client's profile. To calculate the client's points and subsequently associate them with one of the 3 risk profiles (Conservative, Moderate, and Adventurous), one must sum the score of each answer from each of the questions, as per the table above. The final result should be associated with the risk profile, according to the table below. Questions number 10, 11, and 12 function only to validate the client's profile, assessing the responses provided to readjust the questionnaire for the investor's completion.
Profile | Score Range |
|---|---|
Conservative | Up to 60 |
Moderate | 61 to 85 |
Adventurous | Above 85 |
Furthermore, Futurum classifies the funds under its management considering the following aspects: i) Risks associated with the product and underlying assets; ii) Profile of the issuers and service providers associated with the product; iii) The existence of guarantees; and iv) The grace periods.
Based on these parameters, Futurum has defined 3 risk classifications (Conservative, Moderate, and Adventurous) for the funds under its management, following the descriptions in the table below:
ClassificationBrief descriptionConservativeThis category encompasses products whose issuers add little risk to the investment and/or have guarantees to limit asset losses. They are low volatility products and have high liquidity.ModerateThe products in this category involve slightly greater risks than the previous one, tending to present somewhat less flexible liquidity. They consist of funds that seek higher returns compared to the “Conservative” category.AdventurousHigher risks due to the greater volatility and lower liquidity of the products in this category. Products classified in this category may cause significant asset losses.Export to Spreadsheets
Futurum, through its collaborators, commits to not recommend products or services to clients in the following situations: i) The client's profile is not suitable for the product or service; ii) It is not possible to obtain information that allows identifying the client's profile; iii) The information regarding the client's profile is not up-to-date; and iv) If, nevertheless, the client orders the operation, it will be necessary to sign the “Acknowledgment of the Questionnaire”, alerting the client to the discrepancy. The signature of the term also applies when it is the first operation with the category of securities.
All required documents and declarations must be kept for a minimum period of 5 (five) years from the last recommendation made to the client, or from the last operation performed by the client. The new analysis and reclassification of the categories of securities must be made within 24 (twenty-four) months.
The documents and declarations can be kept in physical or electronic form, and it is permissible to substitute documents with the respective digitized images.
Name: Heloísa Lourenço Ishii Position: Administrator
ANNEX I - Investor Risk Profile Questionnaire (Suitability)
In compliance with CVM Resolution No. 30, dated May 11, 2021, we need to establish whether the investment you wish to make is suitable for your risk profile. Therefore, we kindly ask you to carefully fill out this form.
From what period do you consider a financial investment to be long-term?
( ) from 1 year
( ) from 2 years
( ) from 5 years
( ) from 10 years
( ) from 20 years
Assuming a 10% loss on your investment, what would you do?
( ) I would request an immediate redemption of my investment
( ) I would wait a bit. In case of an even greater loss, I would request redemption
( ) I would maintain the investment
( ) I would increase the amount in this investment
How would you classify the purpose of this investment?
( ) Preservation of the invested capital
( ) Possibility of return slightly above inflation
( ) Possibility of return moderately above inflation
( ) Possibility of return significantly above inflation
In which range is your total average monthly income? (includes salary, rents, profit, etc.)
( ) Up to R10,000.00
( ) From R10,000.01 to R50,000.00
( ) Above R50,000.00
What is the estimated value of your financial investments:
( ) Up to 200 thousand
( ) From 200 to 400 thousand
( ) From 500 to 700 thousand
( ) Above 700 thousand
What percentage does this investment represent of your total financial applications?
( ) Less than 25%
( ) Between 25% and 50%
( ) Between 50% and 75%
( ) Above 75%
What is the average duration of your financial investments?
( ) A – Up to 1 year
( ) B – From 1 to 5 years
( ) C – Above 5 years
What percentage of your financial applications do you intend to redeem in up to 1 year?
( ) I do not intend to make redemptions in the next 12 months
( ) Up to 25% of my investments
( ) Between 25% and 50% of my investments
( ) Above 50% of my investments
What is your degree of education?
( ) I do not have a higher education
( ) I have a higher education in a field unrelated to finance
( ) I have a higher education in a field related to finance
Regarding the investments listed below, would you say that you have:
(N) None,
(P) Little,
(M) Medium or
(B) Much familiarity
( ) Fixed Income Products (Savings, CDB, LCI, Public Bonds, and Debentures)
( ) Variable Income Products (Stocks, Structured Products/COEs)
( ) Investment Funds (FMM, FII, FIP, FIDC, etc..)
( ) Derivatives (Options, Futures, Terms, and Swaps)
In the last three years, what is the estimated amount in Reais that you have applied in each of the investment groups listed below?
Fixed Income Products: R$:
Variable Income Products: R$:
Investment Funds: R$:
Derivatives: R$:
How many times a year do you usually invest in one or more products from each of the groups listed below? Fixed Income Products: times a year Variable Income Products: times a year Investment Funds: times a year Derivatives: times a year
Do you have experience or have you worked directly in the financial market? ( ) Yes ( ) No
Location and Date: , Signature:
ANNEX II - Professional Investor Declaration
I, , registered with the CPF/ME under the number: , declare, under the penalties of the Law, that I am a professional investor and have financial investments amounting to more than R$10,000,000.00 (ten million reais).
As this is the expression of the truth, I (we) sign this Declaration.
Location and Date: , Signature:
Name: Heloísa Lourenço Ishii
Position: Administrator
