it
VERSIONE IN VIGORE DAL 9 GENNAIO 2023
Poiché Maclear opera come una piattaforma online di crowdlending p2p che mira a far incontrare investitori e mutuatari fornendo prestiti a questi ultimi, con importi finanziati mediante la cessione diretta dei crediti agli investitori che forniscono i fondi, è fondamentale che tutte le attività correlate – in particolare l'acquisizione e la verifica degli utenti, il controllo e l'accettazione dei progetti, le attività di investimento e i controlli dei conti – siano in ogni momento conformi a tutte le normative (in particolare le normative AML, bancarie e sulla privacy).
Lo scopo della presente politica è garantire la conformità e mitigare i rischi, nonché inquadrare le procedure interne a ciò relative.
È quindi della massima importanza che questa linea guida interna sia rigorosamente rispettata. In particolare, le seguenti disposizioni relative agli importi dei fondi degli investitori e alla durata della custodia dei fondi sui conti devono essere sempre scrupolosamente osservate.
La politica si applica a tutti gli amministratori, ai dipendenti e a tutti i responsabili delle decisioni di Maclear AG. Si applica anche a eventuali persone esterne chiamate da Maclear che intraprendono azioni che hanno un impatto sulle attività operative di Maclear.
La presente politica deve essere riesaminata regolarmente, almeno entro un anno dalla sua prima entrata in vigore e almeno entro due anni da ogni successiva revisione.
La presente politica integra le direttive interne di Maclear in materia di AML e compliance. Mentre il Concetto di Compliance definisce i principi generali e il quadro di riferimento, questa Politica Interna Clienti contiene obblighi concreti riguardo alle attività di Maclear, che devono essere implementati a livello operativo.
Nei confronti di terzi, i principi della presente Politica Interna Clienti si riflettono nelle Condizioni Generali e nei contratti conclusi con gli utenti della piattaforma, ossia gli investitori e i mutuatari.
Le modifiche alla presente politica devono essere esaminate per quanto riguarda la necessità di adeguamenti alle Condizioni Generali, ai contratti modello per gli accordi e a qualsiasi altra direttiva interna.
I mutuatari che cercano di ottenere fondi tramite la piattaforma dovranno concludere un Contratto di Prestito con Maclear. L'importo del prestito erogato al mutuatario dovrà essere rimborsato a Maclear dal mutuatario, maggiorato degli interessi stabiliti in anticipo, e trasferito da Maclear agli investitori in proporzione ai loro investimenti.
Se un progetto possiede i requisiti, verrà concluso tra il mutuatario e Maclear un Contratto di Accettazione e Conferma del Progetto di Investimento (Contratto di Progetto) in cui vengono regolati i dati chiave del progetto.
I crediti verso i mutuatari derivanti dal Contratto di Prestito vengono trasferiti da Maclear agli Investitori in conformità con il Contratto di Acquisto e Cessione del Credito. Il Contratto di Acquisto e Cessione del Credito è un accordo tra Maclear e gli investitori relativo all'acquisto e al trasferimento dei crediti di Maclear verso i mutuatari, nonché alla gestione di tali crediti da parte di Maclear.
Inoltre, un Contratto di Elaborazione dei Pagamenti e di Deposito concluso tra Maclear e gli investitori stabilisce le regole relative ai conti degli investitori. Il Contratto sulla Procedura di Recupero Crediti concluso tra Maclear e gli investitori regola la gestione dei crediti in caso di mancato pagamento da parte del mutuatario.
Non esiste un contratto diretto tra il mutuatario e l'investitore. Gli utenti sono anonimi sulla piattaforma. Gli utenti non ricevono alcuna informazione sull'identità di altri utenti tramite la piattaforma.
Maclear deve verificare se un nuovo utente sia maggiorenne e abbia la residenza o, in caso di persona giuridica, la sede legale in Svizzera. Se l'utente è residente o ha la sua sede legale al di fuori della Svizzera, deve essere verificato se la dichiarazione di ""reverse solicitation"" è stata resa tramite l'approvazione delle Condizioni Generali e valutato se debba essere ottenuta una dichiarazione aggiuntiva separata dal nuovo utente.
In caso di persone giuridiche, l'utente deve designare un rappresentante autorizzato che possa agire per conto dell'utente sulla piattaforma.
Se una registrazione non è completa, deve essere verificato se debba essere cancellata. Ciò non può avvenire prima di 30 giorni dall'ultimo accesso dell'utente.
Deve essere verificato se un utente si stia registrando nuovamente dopo essere stato escluso. In tal caso, la registrazione è esclusa senza il consenso scritto di Maclear. Il consenso scritto può essere dato quando non sussistono più elementi che ostacolano la registrazione, ed è garantito che gli elementi che avevano portato all'esclusione siano stati eliminati in modo duraturo e che non vi siano rischi residui.
Il programma di referral è valido solo entro i confini svizzeri. Nessun nuovo utente al di fuori della Svizzera può registrarsi tramite il programma di referral. I controlli devono garantire che nessun utente domiciliato al di fuori della Svizzera si registri sulla piattaforma utilizzando un codice di referral.
I contatti importanti degli utenti con Maclear avvengono tramite l'indirizzo e-mail support@maclear.ch. Deve essere sempre garantito che il messaggio venga letto entro un giorno lavorativo e che venga fornita una risposta con la rapidità richiesta dalle circostanze.
A un utente non deve mai essere richiesta la password per telefono o e-mail. Una password non deve mai essere comunicata a terzi.
Users can request the closure of their user account via the email support@maclear.ch at any time. In this case, it must be checked without delay whether the user is not involved in any project as an investor or borrower, if all open loans are fully repaid and if no new loan inquiry is active. If so, the user account shall be locked.
The user account must be suspended instantly if there is break of contractual obligations, or regulations such as:
In such cases, it must be determined on a case-by-case basis whether any ongoing claim assignment agreements or project agreements will be continued or also terminated. The closure becomes effective with the written confirmation issued to the user by Maclear.
In case of termination, the user’s personal data must be deleted after the retention period required by law of at least ten (10) years. Meanwhile, information will be kept confidential and provided to local AML/TF authorities only if an official information request is submitted to Maclear.
Measures, controls and checks must be implemented to guarantee that all risks, be they regulatory, reputational or legal, are effectively contained at all times. Persons under the age of 18; US persons; persons who lend on a professional basis; new users using the referral program; persons who carry other regulatory, MLA, legal or reputational risks are not accepted on the platform. User outside of Switzerland are only accepted on a reverse solicitation basis.
The appropriate measures and controls must be in place to ensure that users do not use the platform for illegal activities, such as for example:
If there are indications of any illegal activities and misuse of the platform, the appropriate measures shall be initiated immediately. The measures to be taken shall be decided on a case-by-case basis. In any case, the measures must be suitable to ensure that the platform is no longer used for illegal purposes, that the user can no longer carry out such activities and that all appropriate steps are taken against the user. During a review of indications of illegal activities, the user account concerned shall be closely monitored or blocked, depending on the severity of the alleged misconduct.
If the user is a natural person and is resident outside of Switzerland, or if the user is a legal person and has its legal seat outside of Switzerland, the user must declare the contact to Maclear was initiated by the user and that they have not be marketed by Maclear. This declaration must be available when the registration is checked. There are no exceptions. If the declaration is not available, the natural or legal person cannot become a user, neither as an investor nor as a borrower. The declaration is made by the natural or legal person by accepting the General Terms & Conditions. An additional declaration may be requested.
Given the current laws and regulations applied to US citizens in Switzerland, US citizens cannot use the platform. Controls must guarantee that no US citizens register the platform.
Similarly, the referral program runs only within the Swiss boarders. No new user outside of Switzerland can register within the referral program. Controls must guarantee that no user domiciled outside Switzerland registers the platform using a referral code.
It must be checked whether the natural and legal persons that wish to register, to invest or to submit a project provide loans, credits or similar within the scope of their business or profession (especially professional credit institutions). If so, no registry is possible respectively the account is to terminate since such persons and entities are excluded from using the platform’s services.
For the AML identification measures of investors, Maclear involves SumSub (www.sumsub.com) as a third party. This includes the identification of the customer and the representatives of legal entities, to establish the identity of the beneficial owner, to repeat the identification or the establishment of the identity of the beneficial owner and to implement the special duty of clarification. It must be ensured that the activities of SumSub are monitored with regard to the fulfilment of all delegated duties according to §38 and § 39 of the SRO PolyReg AML-Regulations. This must be stated accordingly in the Maclear’s AML Policy.
Maclear remains responsible for the fulfilment of the delegated tasks. It must be ensured that all appropriate measures are taken to ensure that the documents maintained in his files correspond to the original documents which have served to fulfil the due diligence. Therefore, SumSub must provide confirmation about the fact that the documents correspond to the one which have served to fulfil the due diligence and use encrypted transmission while transmitting the AMLA due diligence documents to Maclear.
It must be ensured that there is no further delegation.
On a risk-based-approach basis, it must be regularly checked whether the delegated onboarding of new users was correctly executed in terms of compliance with the AML regulations and if all necessary documents have been handed in and properly stored (see below 6.3.2 and 6.4.2).
If not, correspondent measures must be taken, 1) in order to restore the correct legal identification for the concerned user, and 2) to ensure that upcoming identifications do not go through the same errors again.
The ongoing monitoring of users and their activities is governed by the corresponding separate AML Policy.
In the event of relevant facts in connection with money laundering or terrorist financing, all measures must be taken immediately in accordance with the corresponding separate AML Policy.
This may include re-identification, determination of the beneficial owner or the controlling person, requesting additional information and documents, carrying out other in-depth investigations, reporting to MROS. All measures must be documented. Any additional information received must also be checked for plausibility. The plausibility check must also be documented. This is governed by the corresponding separate AML Policy.
Restrictions on registration (see above 4.) shall be integrated into the processes and monitored as far as possible.
The AML verification process for the investors is delegated to SumSub (www.sumsub.com), a global verification services provider. All identification and other due diligence measures undertaken by SumSub need not be controlled by Maclear. All due diligence measures not undertaken by SumSub shall be undertaken by Maclear. Further, Maclear shall take and implement the appropriate measures to maintain control over the actions taken by SumSub as well as to ensure that the client documents match those of the verification performed by SumSub. For this purpose, SumSub must confirm about the fact that the documents correspond to the one which have served to fulfil the KYC/due diligence. Encrypted transmission is to be used while transmitting the AMLA due diligence documents from SumSub to Maclear.
The identification and other AML due diligence requirements are governed by the AMLA, the PolyReg regulations and FINMA Circular 2016/7. The internal AML aspects to be observed in relation to AML requirements are governed by the relevant AML Policy of Maclear.
If the required identification document does not have an MRZ, the investor can contact Maclear via email support@maclear.ch. In such cases, feedback must be given to the user within one working day on a case-by-case basis. In principle, identification remains possible, but additional steps must be taken on a case-by-case basis to enable equivalent identification.
Only when the verification process has been fully completed, i.e. in particular when all the necessary identification procedures have been carried out and the relevant documents have been submitted and checked, can the investor's access to the platform be activated ('verified' status). During the verification phase, the status is 'verification pending'.
If the verification status does not change within 3 working days, the investor can contact Maclear via email at support@maclear.ch. In such cases, feedback must be given to the user within one working day on a case-by-case basis. In principle, the user can be generically informed that the AML requirements are delaying verification.
Cashflow starts from investors to separated omnibus account of Maclear and then within 60 days upon receipt to the account of borrower. Interest payments go from borrowers via Maclear separated omnibus account to investors. In this regard, the following regulatory requirements must be complied with:
These two requirements must be strictly adhered to at all times.
As the projects run for 30 days, the investor must allocate the funds deposited in the account to a project within 30 days in order to meet the 60 days limit.
Accordingly, any deposits must be invested within 30 days of receipt by Maclear on projects of the platform or withdrawn by the investor within 60 days. Any accrued borrower payments on the investor account must be withdrawn within 60 days of receipt or re-invested by the investor within 30 days of receipt on projects of the platform.
All accounts are monitored electronically in order to guarantee that. Funds held too long trigger an automatic message. The investor shall receive a reminder 5 days before the expiry of the 30-day period and 10 days before the expiry of the 60-day period. If the funds are not invested, withdrawn or reinvested within the period limits by the investor, they must be transferred back to the investor by Maclear before the expiry of the period if the CHF 1 million limit of liabilities is reached at this respective current point in time.
Therefore, Maclear can return funds at any time to the user. It must be ensured that the payment information of the user must be up-to-date in order to enable Maclear to repay the funds at any time.
Any funds that are committed to or invested in a project cannot be withdrawn until such project is closed. Apart from these funds, the investor can request the withdrawal of investor funds through the user account at any time. Funds that are not currently invested in projects will be marked in the investor’s account as ‘Available funds’. The investor will need to submit a withdrawal request for that. The withdrawal of these funds can only happen to the same bank account the investor used to deposit the money to Maclear, i.e., the verified investor’s bank account(s).
Maclear may transfer the investor funds to the investor at any time. In case Maclear is unable to transfer funds to the bank account of the investor, and the investor does not provide updated and accurate account information within 30 calendar days of Maclear's request, Maclear may be required to dispose of the funds and the investor forfeits any claims against Maclear with regards to such funds.
The following payment methods are accepted:
The terms and conditions of the respective payment services provider apply and have to be accepted by the user prior to making the transfer.
It must be verified that for each transfer method, the user transfers only from verified accounts that are in the same name as the user account. Users must ensure that Maclear can clearly identify the source of the payment in order to credit the transferred funds to the investor funds. The bank account must be on the same name as the investor’s Maclear account. Maclear’s account number must be put in the payment details.
The acceptance of deposits may be declined in accordance with Maclear’s internal AML Policy.
Once the funds are credited to the investor account, the investor is to be notified by e-mail.
Any investor funds can only be used for the purposes of investing in projects or the withdrawal to their own account. Transfers to third parties are excluded from the investor's Maclear account.
If the target amount is reached prior to the end of the offer period, the project will be blocked for further investment.
Investor funds available in one currency can only be used for a project in the same currency. Investors can use any of the third-party conversion services provided on the platform.
In case of over-subscription, the investors that invested first are eligible to invest and over-invested amounts will be returned to the investors.
Investor funds will be automatically unlocked if the project has not received the target amount within the (extended) offer period. If the 60-day limit is reached the investors must immediately withdraw the funds. Otherwise, the investor can reinvest the funds. It is also possible that Maclear agree to an extension of the project. Hereby, it must be guaranteed that the 60-day limit will not be breached, if the CHF 1 million liability limit is reached.
Detailed information about loan conditions for each project must be updated and available any time in Maclear’s projects page (https://maclear.ch/projects).
At the date of the respective maturity as defined in the Loan Agreement, the borrower has to pay monthly instalments (interest and amortisation) by means of payment transfer to Maclear. The amounts are credited on the investor’s account according to their investment.
If the borrower is more than 3 days late on monthly interest payments according to the payment schedule, the interest payments must initially continue to be paid out as per the terms of the reserve fund until the borrower resumes interest payments according to the repayment schedule. If the allowance from the provision fund is depleted before the borrower resumes interest payment, the debt enforcement proceedings will be initiated (see below 10.).
In a situation where the loan is repaid early by the borrower, the entire principal investment sum and all the interest that was accrued during that time shall be returned to the investor. The minimum period of time for which investors will receive interest is three months, even if the borrower repays the loan sooner.
By investing in a project, the investor acquires part of (or all of) the loan receivable from Maclear under the loan agreement entered into between Maclear and the borrower.
Investors may finance part or all of the loan by acquiring from Maclear the assignment of the loan claims under a loan agreement. When an investor finances a project or part thereof, it becomes bound to Maclear by an assignment agreement (Claim Purchase & Assignment Agreement).
The Claim Purchase & Assignment Agreement between Maclear and the investor regulates the purchase and transfer of the claim of Maclear against the Borrower, as well as management by Maclear of such claim. Each investment in a Borrowing Project concludes the corresponding agreement.
The following sample contracts are to be used for the agreement between Maclear and the investor:
The platform is offered solely to users above the age of 18 (or the legal age in their local jurisdiction, if higher) and legal entities with full legal capacity.
The Platform is solely directed at users with residency or legal seat in Switzerland. Users outside of Switzerland must, upon registration or request, confirm that they have discovered the platform on their own and that they have initiated the contact to Maclear.
Borrowers can only apply for a loan with clear business objective. The decision whether to consider an objective as business oriented is exclusively with Maclear. Before approving the borrower’s project and adding it to the platform, Maclear must conduct a thorough evaluation of the borrower company to ensure that it can repay the loan (see below 7.3.3).
Borrowers are not allowed to operate in the interest differential business.
Projects targeting CHF 1 million or more than CHF 1 million in revenue cannot be listed on the platform without additional regulatory measures (see below 7.3.4).
The AML verification process for the Borrowers is not delegated to SumSub. All identification and other due diligence measures shall be undertaken by Maclear. The identification is not done online or by video, but as part of the in-depth review of Borrowers and its Projects.
The identification and other AML due diligence requirements are governed by the AMLA and the PolyReg regulations. The internal AML aspects to be observed in relation to AML requirements are governed by the relevant AML directives of Maclear.
Only when the verification process has been fully completed, i.e. in particular when all the necessary identification procedures have been carried out and the relevant documents have been submitted and checked, can the investor's access to the Borrowing Project listed on the platform be activated ('verified' status). During the verification phase, the status is 'verification pending'.
If the verification status does not change within 3 working days, the Borrowing Project can contact Maclear via email at support@maclear.ch. In such cases, feedback must be given to the user within one working day on a case-by-case basis. In principle, the user can be generically informed that the AML requirements are delaying verification.
Maclear carries out a full legal due diligence and a thorough risks assessment of the borrower and the borrower's project, evaluate market trends in the segment, determine a full risk measurement of each project and evaluate the borrower's assets and capitalization, capability, and experience in carrying out such projects. The evaluation aims to ensure that the borrower can repay the loan.
Borrowers must fill a special questionnaire with a set of numerous legal and financial data about the borrower, beneficiaries, and possible guarantees.
The borrower shall provide access to, and entitles Maclear to access, any registers, third-party databases and other sources to collect further information on the borrower and the project for the entire duration of a project.
The assessment includes:
Maclear must carefully inspect all information related to the project, including the project’s risks assessment. Borrowers must fill a special questionnaire with a set of numerous legal and financial data about the borrower, beneficiaries, and possible guarantees. Further, the borrower must provide information about the legal entity's financial position, jurisdiction and previous experience.
Only after having obtained the necessary documents, and the borrower having passed the multi-level verification, which includes but is not limited to compliance, due diligence, and risk assessment processes, a borrower’s project can be considered.
Maclear may deny a project or a borrower without giving any reasons in its sole discretion.
Projects targeting CHF 1 million or more than CHF 1 million in revenue cannot be listed on the platform without additional regulatory measures. Additional measures may be taken through the issuance of bonds and other unified and mass-issued debt securities or non-certificated rights with the same function (uncertificated securities).
Such debt instruments do not qualify as a deposit if additionally, at the time of the offer, the creditors receive information in one of the forms pursuant to Article 64 paragraph 3 of the Financial Services Act (FinSA; prospectus) about the name, registered office and purpose of the issuer set out in a brief description, the interest rate, the issue price, the subscription period, the payment date, the term and the terms of repayment, the latest annual financial statements and consolidated financial statements with the audit report and, if the balance sheet date is more than six months ago, the interim financial statements, if any, of the issuer and the collateral provider, the collateral furnished, the representation of the bondholders, if contained in the investment conditions.
After obtaining the necessary documents, and passing the multi-level verification, which includes but is not limited to compliance, due diligence, and risk assessment processes, the project is considered. Maclear then conducts the final stage of negotiations with the project initiators and sign all necessary and obligatory legal agreements. After that, the project appears on the platform.
Maclear may deny a project or a borrower without giving any reasons in its sole discretion.
If the project is accepted, Maclear conducts the final stage of negotiations with the project initiators and sign the agreements (Loan Agreement and Investment Project Acceptance and Confirmation Agreement). After that, the project is to be placed on the platform.
Provided that the borrower complies with the regulatory requirements and the project is successfully verified, Maclear concludes with each borrower an Investment Project Acceptance and Confirmation Agreement as well as a Loan Agreement.
If Maclear deems a project suitable for the platform, Maclear and the borrower shall conclude a suspensive Loan Agreement. In the Investment Project Acceptance and Confirmation Agreement the key terms of the loan based on the project submission including, as a minimum, the interest rate, the duration of the loan, the offer period, the target loan amount and the collateral is defined.
The Loan Agreement is binding on the borrower from the date of signature. For Maclear, the Loan Agreement is conditional on the full receipt of funds from investors in the entire loan amount.
The borrower may use the loan amount solely for the purposes defined in the Loan Agreement and Investment Project Acceptance and Confirmation Agreement and disclosed on the platform.
The following sample contracts are to be used for the agreement between Maclear and the Borrowing Project:
Maclear advises borrowing companies to list their projects on the platform for 30 days. Borrowers have the option to extend their fundraising campaign if the funds have not been raised during the initial fundraising period. For this, the borrower must request Maclear at least five days before the end of the period. Maclear will check the possibility of extension. It can only grant the extension if the regulatory requirements are met. The extension can be granted if the following regulatory requirements are complied with:
These two requirements must be strictly adhered to at all times.
No extension can be granted if the mentioned regulatory requirements are not fully observed.
Borrowers shall immediately notify Maclear if they notice any specific errors in the information provided or published on the platform. Maclear must control that and take the necessary actions to correct the published information within the shortest possible time and decide to suspend or extent the offer period or stop the lending process on a case-by-case basis.
If a target amount of a project is reached and all investor funds are available in the target amount, Maclear declares the successful completion of the crowdfunding on the platform without delay. At the same time with the declaration, the respective Loan Agreement as well as the respective Claim Purchase and Assignment Agreements become fully binding.
Without delay, Maclear must transfer the funds from the platform’s escrow account to the borrower. From this amount is deducted the success fee and the reserve fund percental amount.
If a target amount of a project is reached within the initial project period, Maclear must check the possibility to extend the period if the borrower wishes an extension. The regulatory limits must be observed and complied with (see above 8.1).
If an extension is not possible, the user must be informed. The investors are further informed to withdraw or reinvest their funds depending on the duration and amounts in compliance with regulatory requirement (see above 7.2.3).
For the investor's financial security, Maclear shall conduct a comprehensive and in-depth review of all Borrowers and projects. In addition, Maclear itself is liable with the business assets for defaulting payments. As additional security, a separate Maclear reserve fund is formed and maintained to secure and cover recurrent interest payments to investors on their investments made in case of temporary defaults of payments from borrower’s projects.
Maclear will be transferring 2% from each project successfully funded on the Maclear platform to the fund. In the future, Maclear will also add all commissions earned for transactions on the secondary market to the reserve fund.
The fund is set up to bridge gaps in interest payments by borrowers or fully or partially make up for the default of borrowers. The Maclear reserve fund cannot guarantee full payment of interest or full repayment of the principal loan amount. The reserve fund is to be used to the extent funds are available to cover potential losses of investors on interest and/or principal payments. The reserve fund is not an insurance scheme and does not guarantee full payment.
The reserve fund is to be held in a segregated bank account. Maclear shall keep a separate bank account for the assets of the reserve fund. The assets in it are blocked for any other use than the one mentioned above.
Maclear acts as a collateral agent in favour of and on behalf of investors and is responsible for the management of the claims. On the basis of the agreement on the assignment of claims, Maclear engages in the process of collecting debts if the borrower does not fulfil his repayment obligations.
The start date of the interest accrual is calculated on the date of the successful funding of the project. At the date of the respective maturity as defined in the Loan Agreement and the Investment Project Acceptance and Confirmation Agreement, the borrower has to pay monthly instalments (interest and amortisation) by means of payment transfer to Maclear.
Maclear shall act as collection agent for the recurring interest and principal payments from the borrower to investors. Maclear credits all interest and principal payments without delay after receipt from the borrower to the investor funds as per the quota of their investment amount.
Maclear shall, on behalf of the investors, act as a collateral agent and take all reasonable measures to secure timely and full payment, including enforcement measures and securing the provided guarantees, if any. Maclear shall analyse, assess and execute any and all available pledges, securities, collateral and guarantees provided by the borrower with a view of mitigating the risks for investors. The measures shall specifically be the following:
If Maclear is unable to collect the outstanding amount and such amount is not covered by the reserve fund or another mechanism, any collected amount will be distributed among the investors on a pro-rated basis.
The user’s personal information must be stored and handled in full compliance with the applicable privacy regulations including the Swiss Data Protection Act and the EU General Data Protection Regulation (EU GDPR) according to Maclear’s Privacy Policy.
The user’s personal information must be used only to comply with Maclear's legal obligations as per its Privacy Policy.
Maclear shall make available to the users a service centre that can be contacted at any stage of the process for questions related to Maclear's services by chat, email, or phone.
This policy was approved by the management on 9th of January 2023 and will be reviewed regularly thereafter.
Aleksandr Nikitin
Member of the Board
Maclear AG
