Regulatory Disclosure & Important Legal Information

Licensing and Regulatory Status

Libraly Finance Ltd. (“Libraly” or the “Company”) is engaged in investment marketing, and not in investment advisory or investment portfolio management, as such terms are defined under the Israeli Regulation of Investment Advice, Investment Marketing and Investment Portfolio Management Law, 5755–1995.

General Informational Purposes Only

The information presented on this website is general in nature and is provided for informational purposes only. It does not constitute investment advice, investment marketing, portfolio management, legal advice, tax advice, accounting advice, an offer to purchase, or a solicitation of an offer to sell or purchase any financial asset, security, fund, structured product, or other investment product.

Any investment decision should be made only after receiving personalized investment marketing or other professional advice from a licensed professional, taking into account the client’s personal circumstances, investment objectives, financial position, risk tolerance, investment horizon, liquidity needs, tax considerations, and any other relevant data.

No Services to U.S. Persons

Libraly is not registered with, licensed by, or authorized by the U.S. Securities and Exchange Commission (SEC), FINRA, or any other U.S. regulatory authority to provide investment advisory, investment marketing, brokerage, or similar services to U.S. citizens, U.S. residents, U.S. tax residents, or other U.S. persons.

The Company’s services and the information on this website are not intended for, directed at, offered to, or made available to U.S. persons. Nothing on this website should be considered an offer, solicitation, recommendation, investment advice, investment marketing, or other regulated service to any U.S. person.

Affinity, Conflicts of Interest, and Third-Party Remuneration

Libraly has, or may have, an affinity (Zika), commercial relationship, distribution arrangement, referral arrangement, cooperation agreement, or other business relationship with certain financial institutions, banks, investment banks, brokers, issuers, fund managers, product providers, and other third parties.

As a result, Libraly may have an interest in marketing, presenting, or preferring certain financial assets, investment products, funds, structured products, or services over other financial assets or services that may be similarly suitable for a client, but with respect to which Libraly has no affinity or commercial relationship.

Libraly may receive commissions, distribution fees, placement fees, retrocessions, referral fees, management-related remuneration, or other forms of remuneration from financial institutions, issuers, product providers, banks, brokers, fund managers, or other third parties, in accordance with applicable law and the relevant client documentation.

Where required by law, and subject to the relevant client agreement and applicable disclosure obligations, Libraly will disclose the existence of such affinity, relationship, remuneration, or potential conflict of interest.

Financial Institutions and Product Providers with Respect to Which Libraly May Have an Affinity

Libraly may have, or may from time to time have, a commercial relationship, affinity, cooperation, distribution arrangement, referral arrangement, or other relationship with, among others, the following entities and product providers.

This list is provided for disclosure purposes only, may not be exhaustive, may include past, current or prospective relationships, and may be updated from time to time.

International Banks and Investment Banks

• EFG Bank
• Julius Baer
• Leonteq Securities
• BNP Paribas
• Morgan Stanley
• Goldman Sachs
• Nomura
• Citi
• Société Générale
• Credit Suisse / UBS

Investment Houses, Asset Managers, Funds and Product Providers

• Pagaya: P2P funds and related financial products
• IBI Investment House: funds and investment products, including Quality, CCF, Comrit, SBL, Volcano, Reem/Raam fund series, CLO, DataCom, Atlantis etc.
• Altshuler Shaham: hedge funds, including Yanshuf, Netz, Orca etc.
• Sphera: hedge funds and investment vehicles
• The Phoenix: investment products and funds, including Ogen, KYC, Co-Invest, LEAP fund series, Apollo funds, BPC, real-estate debt funds, BlackRock-related products etc.
• Noked Capital: hedge funds
• More Investment House: funds and investment products, including CLO Fund, Multi Strategy etc.
• Movchan’s Group: investment funds
• Eitan Funds: including Flexible and Opportunities funds
• Encounter Capital: including Acumulus, Context etc.
• Kai Capital
• ION Tech Fund
• Arbitrage Capital
• Kai Yam Wealth Management
• K.Y. Hospitality
• Privatam
• Futora
• Marex
• Reading Capital
• TLP
• Vertical funds
• Arion

Related Parties, Proprietary Products and Structured Products

Libraly may also have an affinity, economic interest, commercial relationship, management involvement, distribution arrangement, or other relationship with related parties, proprietary products, structured products, notes, certificates or other investment vehicles, including E.T.R. Finance, Tera Note and structured notes.

Such products may involve additional conflicts of interest, including economic interests of Libraly, its shareholders, officers, employees, related parties or business partners. Any such product will be presented, if at all, subject to applicable law, relevant offering documents, client eligibility, suitability considerations, and the required disclosures.

Investment Risks Disclosure

Investments in financial assets, securities, funds, structured products, alternative investments, private equity, hedge funds, credit products, notes, certificates, or other investment products involve risks. These risks may include, among others, market risk, credit risk, liquidity risk, issuer risk, counterparty risk, currency risk, concentration risk, leverage risk, regulatory risk, tax risk, operational risk, and the risk of partial or total loss of the invested capital.

Past performance is not a guarantee of future results. Any projected, estimated, target, back-tested, simulated, or hypothetical return is for illustrative purposes only, is not guaranteed, and may not materialize.

Certain products may be complex, illiquid, subject to strict restrictions on transfer, redemption, or resale, and/or intended solely for qualified, accredited, professional, classified or sophisticated investors, including qualified investors under the First Schedule to the Israeli Securities Law, 5728–1968, where applicable.

Clients should carefully review all official offering documents, prospectuses, private placement memoranda, term sheets, risk factors, subscription documents, and legal agreements before making any investment decision.

No Public Offering

Nothing on this website constitutes a public offering of securities, funds, structured products, notes, certificates, or other financial instruments in Israel, the United States, or in any other jurisdiction.

Any offering or transaction, if made, will be made only in accordance with applicable law, client eligibility requirements, and the relevant offering documents.

Updates

Libraly may update this disclosure and the list of entities, financial institutions, issuers, product providers, funds and other parties from time to time.