Vision

At Vive, investing goes beyond financial responsibility. Vive approaches its sustainability policy from the perspective of both managing risk through sustainable business practices and making positive contributions to a more sustainable world:

1. Sustainability Risks (Outside-in): Vive analyzes sustainability risks that may affect investment performance, such as environmental issues, social risks and governance challenges. These are referred to briefly as ESG factors: Environment, Social and Governance. We integrate these risks into our investment process to make informed decisions that enhance the robustness of our portfolios.
2. Sustainability Impact (Inside-out): Vive assesses the impact of its investments to limit negative impact and contribute to positive impact on sustainability goals. This enables our fund selection to pursue a more sustainable world. We test this on the basis of the criteria in the Sustainable Finance Disclosure Regulation (SFDR). This is European legislation that thus provides an independent assessment framework.

This approach enables us not only to achieve financial returns, but also to contribute to a better world. By managing sustainability risks with ESG integration and optimizing the impact of investments, we strengthen our risk-return ratio, support our long-term goals and contribute to a more sustainable world.

Application of SRI

Our approach to SRI combines financial objectives with sustainability goals aimed at a balanced risk-return ratio. This policy is based on three core principles:

1. Exclusion Policy: Vive invests only in funds that actively exclude investments based on a structured exclusion policy.
2. Best-in-Class Selection: Vive invests only in funds that excel on sustainability within their asset class and mandate based on ESG performance and promote ESG goals or make positive impact in line with SFDR criteria.
3. Voting Rights and Engagement: Vive only invests in funds that actively exercise their voting rights and have a clear engagement strategy to drive improvements in sustainability issues.

SFDR Classification at Fund Selection.

Vive implements both ESG risk measures and SFDR criteria in its investment process so that we both manage sustainability risks and achieve positive impact. We review ESG ratings and we choose the funds with the highest scores within their category. Investment funds with an MSCI ESG rating lower than BBB are excluded. In addition, we select funds that meet at least SFDR Article 8 criteria, with a strong preference for Article 9 funds.

For government bonds, the SFDR criteria are not applied by default, as they are generally not as easily measurable as other asset classes. The SFDR ratings give us a transparent and objective framework to assess the sustainability profile of our investments.

Our selection criteria focus on:

• Positive contribution to environment and society
• Mitigation of negative impact through Principal Adverse Impact (PAI) indicators, among others
• Promotion of environmentally sustainable investments, where possible within the EU taxonomy

Through this policy, we ensure that our investments not only meet financial requirements, but also contribute to sustainable and social value, appropriate to the ongoing development of sustainability standards and regulations.

Sustainability goals and outcomes

Our investments are assessed using four main criteria:

1. Mitigation of Sustainability Risks (ESG Ratings).

Sustainability Risks and ESG Ratings.

A sustainability risk is an Environment, Social or Governance event or circumstance that could potentially negatively impact the value of an investment. Examples of such risks are:

Environmental risks: Climate change may reduce the value of investments in carbon-intensive sectors because the business model of these companies may not be sustainable over time.

Social risks: Poor working conditions or human rights violations can damage a company's reputation, negatively impacting its bottom line.

Governance risks: Lack of good governance, such as corruption or inadequate risk management, can lead to operational and financial problems.

ESG Ratings measure how well a company handles financially relevant sustainability risks and opportunities. These ratings are used to identify leaders and laggards within sectors based on:

1. Their exposure to ESG risks.
2. Their ability to effectively manage these risks compared to competitors.

ESG Ratings are categorized as:

1. ‍Leaders: AAA, AA‍.
2. Average: A, BBB, BB‍.
3. Laggards: B, CCC

These ratings are applicable to various asset classes, such as equities, fixed income, loans, mutual funds and countries.

Application of ESG criteria to Vive's Investment Policy

At Vive, we actively integrate ESG principles into our investment policies to mitigate sustainability risks and promote responsible investing. Our Best-in-Class approach focuses on selecting funds that outperform their peers on ESG criteria within their sector. This allows us to minimize risk within our portfolio while contributing to positive social impact.

We use ESG ratings as a key metric within our selection process. These ratings help us identify funds that meet our sustainability goals and fit within the standards of our policy. Below is an overview of the asset classes and their ESG ratings, where we aim for the highest scores within each segment.

2. Mitigation of negative impact (PAI).

Principal Adverse Impact (PAI) criteria

An important part of a sustainable investment strategy is the exclusion of investments with negative impacts on people and the environment. At Vive, having an exclusion policy is therefore an essential selection criterion. To limit negative impacts, the Principle Adverse Impact (PAI) indicators have been established. This set of 64 measurable indicators evaluates the potential negative effects of an investment.

For investment products under SFDR Articles 8 and 9, reporting on at least 18 of these 64 PAI indicators is mandatory. Of these 18, 14 are core indicators that are required to be reported for all relevant investment products; in addition, 4 additional indicators may be included at your discretion. The 14 mandatory indicators are:

• Greenhouse gas emissions
• Carbon footprint
• Greenhouse gas intensity of investee companies
• Exposure to companies active in the fossil fuel sector
• Non-renewable energy consumption and generation.
• Intensity of energy consumption by sector with major climate impacts
• Negative impacts on biodiversity-sensitive areas
• Emissions to water
• Hazardous and radioactive waste ratio
• Violations of UNGC and OECD guidelines.
• Lack of procedures and compliance mechanisms for monitoring compliance with UNGC and OECD guidelines
• Unadjusted gender pay gap
• Gender diversity board of directors
• Controversial weapons

Impact PAI criteria on Vive Investment Policy.

All funds in Vive's portfolio, where relevant, mitigate negative impacts through strict exclusion policies. This exclusion policy is an essential selection criterion in our investment policy. Each fund reports which negative impacts it mitigates, using PAI indicators to make its sustainability performance transparent.

Below is an overview of the asset classes and the specific PAI indicators by which negative impact is actively mitigated:

3. Positive social and environmental contribution (SFDR).

Sustainable Finance Disclosure Regulation (SFDR) classifications.

The Sustainable Finance Disclosure Regulation (SFDR) provides a European framework for classifying investments based on their sustainability performance. Only investments that meet the SFDR requirements may be labeled as sustainable. These regulations require financial institutions to report transparently on how sustainability is integrated into their investment choices and allow investors to be better informed about the sustainability of investment products. SFDR divides products into three categories based on the extent to which sustainability plays a role:

• Article 6: Investment products that do not actively integrate sustainability and typically do not provide specific information about addressing sustainability risks within the investment strategy. These products are often referred to as "gray investments."
• Article 8: Investment products that consider the impact of investments on ESG criteria, without requiring sustainability to be the primary focus. These funds can pursue sustainable investment goals, but this is not mandatory. Article 8 funds are known as "light green investments."
• Article 9: Investment products with an explicit focus on sustainable objectives, aiming for measurable positive impact on ESG. Article 9 funds focus on deep sustainability and are referred to as "dark green investments."

This rating system helps investors discern the sustainability performance of investment products and provides a standardized basis for responsible investment choices.

Impact SFDR rating on Vive Investment Policy.

What is a sustainable investment in accordance with SFDR?

Fund managers have internal policies and methodologies to measure whether an investment is sustainable in accordance with SFDR. There is no uniform set of tools to classify investment as sustainable in accordance with SFDR. SFDR legislation prescribes that an investment may be called sustainable under three conditions:

1. The investment must make a positive contribution to an environmental or social objective.
2. The investment must comply with the "Do No Significant Harm" principle, which means that the investment does not contribute to activities that could cause significant harm, such as controversial weapons.
3. The company being invested in must have good governance with clear rules to prevent social problems.

If a fund manager determines that an investment adheres to all 3 of these conditions, then it is a sustainable investment in accordance with SFDR.

4. Ecologically sustainable investments (EU Taxonomy).

EU Taxonomy

An investment is only classified as environmentally sustainable by the EU Taxonomy if the underlying activity contributes significantly and measurably to at least one of the six established environmental objectives. In addition, data must also show that the company does not significantly harm other environmental objectives (the "Do No Significant Harm" principle). The company must also meet social benchmarks, such as protecting labor rights and respecting human rights.

The six ecological objectives of the EU Taxonomy are:

1. Climate change mitigation: Reducing the company's impact on global warming by, for example, reducing greenhouse gas emissions.
2. Climate change adaptation: Measures to manage the impact of climate change on the organization by, for example, building levees to protect against flooding.
3. Sustainable use and protection of water and marine resources: promoting efficient water use and protecting water quality.
4. Transition to a circular economy: promoting recycling, reuse and reducing waste generation.
5. Pollution prevention and control: preventing and reducing air, water and soil pollution.
6. Protection and restoration of biodiversity and ecosystems: Conservation and restoration of natural habitats and prevention of biodiversity loss

Impact of EU Taxonomy on Vive Investment Policy

Vive continually examines the supply of environmentally sustainable investments within the EU taxonomy. Due to limited supply, currently the Corporate Loans Euro fund reports a limited environmentally sustainable investment of 1.06% (31/12/2023) in accordance with the taxonomy criteria. Currently, none of the funds in Vive's portfolio have set specific targets for environmentally sustainable investments.

Continuous Improvement and Adaptation

Sustainability is a topic in constant evolution. At Vive, we recognize that the standards, legislation and insights surrounding SRI continue to evolve. We therefore continue to continuously hone our sustainability policy and adapt it to the latest developments. This enables us to continually align our strategy with industry best practices to achieve lasting positive impact.

With this approach, Vive remains committed to a responsible and sustainable investment strategy, focusing on delivering value for our clients and promoting a better world.

Terms and Conditions

1. Essence of Collaboration.

Employers, employees, the self-employed (ZZP'ers), and director-majority shareholders (DGAs) can achieve pension accrual through Vive through an investment account.

1.1 Vive offers an investment option only. Participation is voluntary.

2. Participation and Responsibilities.

2.1 Employees‍

Employer offers its employees the opportunity to accrue tax-deferred pensions through Vive.

2.1.1 The employer may contribute to the cost while the employee is employed.

2.1.2 Employees are fully responsible for their own investment choices.

2.2 ZZPs/DGAs‍

Self-employed individuals and director-major shareholders can also build up a pension through an investment account with Vive.  

2.2.1 The self-employed person is fully responsible for their own investment choices.

2.2.2 The self-employed person shall bear the costs himself, unless otherwise agreed.

3. Agreement and Services.

3.1 Vive Invest provides investment services on an individual basis to employees of the employer as well as self-employed persons and DMSs.

3.2 Employer takes care of any contributions to the investment costs of employees. For self-employed persons and DGAs, they bear the costs themselves unless otherwise agreed in writing.

3.3 Vive Invest reserves the right not to enter into or terminate a client relationship if legal obligations regarding client due diligence (Wwft) cannot be met.

4. Privacy and Data Protection

The parties undertake to comply with the General Data Protection Regulation (AVG), with personal data being processed solely for the performance of the agreement and in line with applicable privacy laws. More information: Vive Privacy and Cookie Policy.

5. Duration and Termination.

5.1 The Agreement is for an indefinite period of time and may be terminated by either party by giving [number of] months' written notice.

5.2 The termination of this agreement shall not affect existing individual agreements between Vive Invest and the employees, self-employed persons, or DGAs.

Protocol Streamlining Capital Transfers (PSK).

If you have accumulated tax-deferred retirement assets with another provider and wish to transfer those assets to Vive (or vice versa) without immediate income tax liability, the Streamlining Capital Transfers (PSK) Protocol offers a solution. This document explains how to arrange such transfers. This also applies to transfers of pension assets from Vive to another provider.

Vive Pension Plan

Vive's retirement plan includes:

• A personal annuity account.
• A composite investment portfolio.
  
• An investment strategy.
  ‍

The annuity account is blocked to prevent inadvertent withdrawals, which can lead to tax consequences, such as direct withholding of income tax and possibly revision interest. Deposits to this account may be tax deductible. Transfers to or from another provider, without direct income tax withholding, are possible under certain conditions.

PSK

Vive is affiliated with the PSK to ensure a smooth transfer of accrued assets without direct tax consequences. This protocol, supported by the Association of Insurers and the Dutch Banking Association, ensures a "tax-efficient" transfer of value, which does not have to be settled directly with the tax authorities.

Income tax avoidance

A value transfer must be done accurately, because otherwise the tax authorities may levy taxes on the accrued capital. The Dutch Association of Insurers and the Dutch Banking Association have therefore made mutual agreements to make a value transfer go smoothly. This is called "tax-efficient." This means that the transfer takes place in such a way that no interim settlement with the tax authorities is required. These agreements are laid down in the PSK. The parties affiliated with the PSK (such as banks, insurers and investment institutions and companies) have agreed procedures regarding the transfer of value of tax-facilitated products to another provider. Vive is a member of the PSK and operates according to this protocol.

Read more about the PSK on the website of the Dutch Banking Association (NVB) or on the website of the Association of Insurers.

Advice on value transfer

You are responsible for choosing to transfer value to or from Vive. If necessary, seek the advice of a financial advisor to determine whether it is a wise choice to do so. Value transfers may have long-term tax consequences.

How does it work?

a. Value transfer to Vive

Download the form at the bottom of this text. Sign it and submit it to the current provider. Once the current provider receives the form and all required documents, they will initiate the value transfer.

After this, the transfer will be carried out within fourteen calendar days. Does the fourteenth day fall on a weekend or holiday? Then the next working day counts as the fourteenth day. Vive will send you a message as soon as the money has been transferred to Vive by the transferring PSK participant. The provider performing the value transfer may charge a fee.

Link to the form

b. Value transfer from Vive to other provider.

Should you decide to continue the value of your retirement investment account (on an interim basis) with another PSK provider, please notify us in the chat function of the Vive app or by emailing support@viveapp.com. In response, Vive will send an email with the transfer form and an explanation of the form. The form must be returned fully completed and signed. Upon receipt, Vive will make the transfer within fourteen days. The administrative fee charged by Vive for transferring your value to another provider is: (to be determined).

Additional required documents

Additional documents are required in some situations, such as divorce or death. Without these documents, Vive may not transfer your money to another provider.

• Divorce: divorce covenant.
• Death: Deed of death and certificate of inheritance.
• Power of Attorney: Proof of power of attorney.
  ‍

In case the financial institution to which you want to transfer the value does not participate in the PSK, the acquiring financial institution will need an indemnification statement from Vive. Vive will coordinate this indemnification statement with the acquiring financial institution.

Rate of interest

If the 14-day value transfer period is exceeded, the transferring party is obliged to pay statutory interest.

Fully customised

Everything we do is based on your situation, wishes and goals.

Your ideal portfolio

We put together the ideal investment portfolio for you that exactly fits your situation, wishes and goals.

Always adaptable

You can change or stop your plan anytime, anywhere.

A plan that fits perfectly.

We put together an investment portfolio that perfectly suits you and your goals. To get a good idea of who you are, we will ask you a number of questions beforehand. We will also map out your financial situation. We give this a score and call it your financial profile. Based on this, we estimate the risks you can take and which style of investment suits you best.

Then you indicate what you want to invest for. For example, for your house, camper van or pension. You can also put your money to work without a specific goal.

Then we will execute this plan for you by executing your investment strategy. You can always choose to adjust your plan. We will immediately incorporate your new wishes into your strategy. Do you want to take less risk? Then we will make sure that we buy in safer investments for you. Do you want to invest less per month, but get the same return? Then we will be more daring in our investments.

You can always see exactly which investments your portfolio consists of. You can find it in the app under plans > your plan > portfolio.

Good to know: every goal is different, and needs a different plan. That is why we create a unique strategy with an appropriate investment portfolio for each goal.

Automatic rebalancing

Your portfolio will always fit your risk preferences because we automatically maintain the right ratio of funds.

Tracked 24/7

Your investments are monitored by our plan manager so you don't have to.

Automatic de-risking

Your portfolio is being built more and more securely so that the chance of you achieving your goal increases as your goal date approaches.

This is how we limit your risk.

As you can read in our investment policy, we believe that investing well also means actively limiting risk. Besides our fund selection, we do two other things to manage your risk as well as possible.

Automatic rebalancing: sometimes the risk profile of your investment portfolio changes. This is because the market, and thus the value of your stocks, fluctuates constantly. So suddenly your riskier investments can outweigh your safer investments. You then run more risk than you really want. That's why we rebalance your portfolio regularly. That means that we buy and sell certain funds so that the risk profile of your portfolio matches your plan again. 


Automatic risk reduction: we reduce risk the closer you get to your goal. We do this by choosing increasingly safer investments. For example, we can gradually replace equity funds (higher risk) with bond funds (lower risk). In this way, the chance that you will achieve your goal increases over time.

If your plan changes, we immediately calculate a new strategy that suits you. The app shows you exactly how we do this. Go to your plan in the app > portfolio > strategic.

Numerous economic scenarios outlined

So that we know exactly how our funds are moving due to market changes.

Thousands of investment strategies calculated

Based on numerous economic scenarios.

Broad portfolios with different levels of risk

Our model invests in a mix of equity, bond and money market funds.

Now available to you.

Vive has built a financial model that creates thousands of investment strategies based on numerous economic scenarios. This model assembles a mix of funds that perfectly matches your goals, wishes and situation. Should your plan change, our model instantly calculates a new strategy to suit your new settings.

A strong investment portfolio consists of a broad portfolio with different types of investments. This way the risk is spread as much as possible. Our investments are divided into various asset classes. These in turn are spread across different geographical regions and sectors. Our financial model invests your money in a mix of equity, bond and money market funds. All carefully selected on cost profile, performance, risk and sustainability.

Also, the estimates of this model are updated quarterly to reflect the latest market developments.

Are you not satisfied with Vive's services? If so, we encourage you to contact customer service by emailing: support@viveapp.com, or send a chat message in the app (account/support/chat with us). The customer service staff will be happy to work with you to find an appropriate solution.

Are you unable to reach a solution with customer service and your complaint remains unresolved? In that case, make it clear that you are not satisfied with the solution offered. The customer service representative will initiate the complaint procedure for you so that your complaint can be formally addressed. 

Complaint Procedure

1. We receive your complaint.
This can be done through the communication channels used by Vive. It is unavoidable that messages are sometimes lost due to technical malfunctions, for example, or otherwise. Therefore, if you do not receive a response from us after 10 working days, please check with us whether the message has been received by us.

For the sake of completeness, please note that this complaints procedure does not prevent you from taking the normal legal action that is customary in the Netherlands.

We also note that you would be well advised to file a complaint with us as soon as possible to avoid the possibility that the complaint can no longer be dealt with because of the deadline that has already passed. As a general rule, the right to file a complaint expires in any case after five years after you are aware of what the complaint is about.

In addition to this complaints procedure, we have adopted a special procedure and measures for preventing and managing conflicts of interest. These also apply to complaints. If requested, you will receive a copy of this. ‍

2. The complaint will be registered upon receipt.
In any event, within five working days your complaint will be registered in at least the manner prescribed by the regulators and included in our complaints register. The Compliance Officer supervises this and, where necessary, will also ask for additional information in order to gain a complete picture of the complaint and to be able to record it. In this and in the entire handling of the complaint, the applicable privacy regulations will be respected at all times.

The Compliance Officer oversees business operations and therefore the entire complaint handling process.

It may be that your complaint holds us liable for damages you have suffered. In that case, we must also report your complaint to our professional liability insurer. This insurer will then take over the handling of the complaint from us. We will always inform you of this.

If the complaint relates to the actions of one of the members of the board of directors, the opinion of the director about whose actions the complaint is made, as well as at least one of the other members of the board of directors, will be requested in any case.

All complaints are registered using the complaint form. A complaint is any expression of dissatisfaction addressed to Vive by any person (whether a natural person or legal entity) relating to an investment service provided by Vive, through any channel through which Vive communicates with clients.

‍3. We aim to respond to your complaint within 10 working days.
Preferably, we will then handle your complaint immediately by resolving it. If this is not yet possible, you will in any case receive an acknowledgement of receipt of your complaint within this period, including the period within which you can expect a response and what steps we will take to deal with your complaint.

The assessment of the complaint will be sent to you only after approval by the Compliance Officer. If necessary, the Compliance Officer will also inform the Deposit Bank concerned, where your investments are held, about the complaint. In addition, Vive will provide timely information to the AFM regarding complaints and complaint handling.

4. At any time you will be given the opportunity to provide your response to the assessment of the complaint sent to you.
‍Ifthere is reason to do so we will send you a second assessment of the complaint taking into account your objections to the first assessment of the complaint. Where possible, the second assessment will involve a director who was not already involved in the assessment of the first complaint. In addition, the steps outlined in 1 through 5 will again apply.

5. If after handling the complaint you still do not agree with the first and/or any second or further assessments, you can turn to the KiFiD.
Below you will find the contact details of the KiFiD. To be sure, for current information, please visit www.kifid.nl.

Kifid
Postal address KiFiD: P.O. Box 93257, 2509 AG The Hague
Visiting address KiFiD: Kantoren Stichthage, Koningin Julianaplein 10, 2595 AA The Hague
Telephone number: +31(0)70 333 8 999
E-mail: consumenten@kifid.nlWebsite: https://www.kifid.nl

Conflict of interest policy Vive

Under laws and regulations, financial firms are required to have procedures and measures in place to prevent and manage conflicts of interest. Below you can read how Vive has incorporated the conflict of interest policy into its operations and the measures taken by Vive to protect the client's interest. At all times, the applicable laws and regulations take precedence and are also the guiding principles in cases of conflicts of interest.

Principles of policy‍.

Vive has established the policy pursuant to its license as an investment firm. The policy applies to all Vive Group affiliates.

The policy

Vive recognizes that, as with any other investment firm, there may be potential or actual conflicts of interest. Vive's policy is to protect the client's interest so that a client cannot be materially harmed as a result. Vive has defined in this policy the circumstances that may lead to a conflict and the measures taken to manage and/or prevent these conflicts.

Potential conflicts of interest

Conflicts of interest may arise in the following (non-exhaustively) listed situations, among others:

• Having an interest in the outcome of a service or transaction performed on behalf of the client that is different from the client's interest in that outcome;
• A conflict of interest among clients.
• Having a financial or other incentive to put the interests of one client or group of clients ahead of the interests of other clients;
• The provision of services by affiliates; The structure and (financing of) business activities

Because Vive's services are highly automated, the likelihood that Vive, or an employee of Vive, will have an improper influence on the manner in which asset management is conducted on behalf of a single client, or a group of clients is considered extremely low. Where clients may have a conflict of interest among themselves, or otherwise have differing interests, this is reported to the Compliance Officer.

Although the likelihood of this conflict of interest is considered low, given the service and far-reaching mode of automation, the Compliance Officer will designate individuals to represent the interests of these potentially conflicting clients.

The Compliance Officer will, in case of conflicting interests, together with the board member who is not responsible for commercial matters, weigh the interests.

‍
With respect to the provision of services by affiliated parties, decision-making is structured such that, in the event of a conflicting interest, the interest of the affiliated party is subordinate to the interest of (the customers of) Vive.

To ensure this, the Compliance Officer will decide, together with the management of Vive, that the person in whom the related party is or may be represented does not participate in the decision-making.

‍
Vive has established various measures, procedures and policy guidelines to recognize, prevent and manage a conflict of interest. Below is a non-exhaustive list of a number of measures which Vive has taken to safeguard the client's material interest.

Internal supervision

Vive has a board member who is ultimately responsible for compliance matters. In addition, the Compliance Officer oversees compliance with the conflict of interest policy. Agreements with related parties will be assessed by the Management Board in conjunction with the Compliance Officer on the "at arms length" principle, with the final decision-making authority resting with the Management Board member who is not involved with the related party. Periodically, at least annually, the effectiveness of the anti-conflict of interest policy is evaluated and if necessary updated. In the event that a conflict of interest arises for which the policy does not provide, the Compliance Officer will immediately update the policy accordingly.

Compensation Policy

A specific remuneration policy has been established whereby the service model and the manner in which the fees charged to clients are not based on service that does not serve the client's interest.

Private investment transaction

The personnel policy states that if an employee, wishes to make a private investment transaction it must be reported in advance to the Compliance Officer.

Donations

In addition to the regulation of private investment transactions, the personnel policy includes the regulation of gifts and regulation of ancillary activities to manage conflicts of interest.

Provision

Vive receives no commissions, fees or monetary or non-monetary concessions paid or provided by any third party.

Market abuse

To prevent employees of Vive from using (price) sensitive information for their own gain, Vive has established a regulation on private investment transactions. The regulation should ensure that (the appearance of) insider trading and mixing of business and private interests is prevented.

‍Functional separation

To ensure that persons cannot abuse the system, segregation of duties is ensured. A separation is made between functions in which investment services are provided and functions in which the operational processes are handled for the purpose of operations.

Communications

Any (possible) conflict of interest within Vive will be reported to the Compliance Officer, who will inform the Management Board. Compliance will investigate the reports in consultation with the Management Board. Each report will be assessed against the conflict of interest policy. A written record will be made of each relevant report in which Vive indicates how the conflict of interest was handled.

Given the specific nature of conflicts of interest, Vive will assess each report on an individual basis. If the organizational and administrative arrangements put in place by the investment firm to prevent or manage a specific conflict of interest are not sufficient, this will be disclosed at least to the, in this case, affected clients.

Asset segregation law and investor compensation. Firms providing investment services are required by law to keep their own assets separate from clients' invested assets.

If things then go wrong, their clients' investments are safe in a separate pot. Vive follows the rules of asset segregation.

The Financial Markets Authority monitors Vive's compliance with asset segregation rules. These rules ensure that should Vive go bankrupt, our customers' investments are separated from Vive's assets. As a result, customers' investments do not fall into the bankruptcy estate.

In the unlikely event that a case of fraud and/or mismanagement occurs at Vive and Vive cannot ensure the rules of asset segregation, there is the investor compensation scheme for aggrieved investors.

Investor compensation provides protection of up to EUR 20,000 per person and company.

Do you have a joint and/or investment account with your partner? If so, you are guaranteed a maximum return of EUR 40,000 together.

‍Moreinformation about the investor compensation scheme can be found on the website of De Nederlansche Bank.

General

VIVE Invest B.V. (Chamber of Commerce 62098896), in the rest of this document referred to as Vive Invest, hereby grants you access to www.viveapp.com and all of our VIVE Invest B.V. websites where it publishes texts, images and other materials which have been supplied by Vive Invest and others.

Vive Invest retains the right to alter the contents of the Website and mobile application or remove material without having to notify you at any point in time about such changes. The information and materials on the Website and mobile application are provided "as is" and cannot be considered an offer of services or a contract proposal. Contracts and services are only established by the acceptance of duly indicated quotations or offers by Vive Invest.

Liability

Although for the content of this Website and our mobile application great care has been taken, Vive Invest shall never be liable for losses or other damages that may result from inaccuracy or incompleteness of information on this Website and/or its mobile application. The materials on the Website and our mobile application are offered without any warranties, expressed or implied, and without any claims as to their accuracy. These materials can be subject to change at any given time without prior notification from Vive Invest. Especially all sums, prices and fees on the Website and mobile application are provided with reservation of type-, conversion-, and programming errors.

For the consequences of such errors no liability is acknowledged or accepted by Vive Invest. No agreement or contract with Vive Invest is established based on such errors. Studying the contents of this Website and/or our mobile application, signing up for newsletters or to send information requests can not cause any kind of relationship between Vive Invest and the receiver of the information.

This website may contain links to other websites. Vive Invest has no control over the content of those other sites and is not responsible for the content of those websites or other links to other websites. Transmission of web forms or other communications to Vive Invest without encryption or other secure means of communication and shall always be for the risk of the sender.

Intellectual Property Rights

This website contains information, data, software, photos, graphics and other materials protected by copyright, trademark or other proprietary rights. The content on this Website and our mobile application may not be reproduced, republished, distributed, transmitted, displayed, broadcasted or exploited in any manner without the express prior written consent of Vive Invest. All intellectual property rights with regards to these materials offered and available on the Website and our mobile application are the property of Vive Invest and its licensors. All intellectual property rights relating to this Website, including software, text, photographs, images and / or sounds are owned by us and / or the person from whom we have obtained a license.

At Vive Invest, we care about the protection of your data and privacy and how it applies to you, as a user of our website(s). In this Privacy Policy ('Policy'), you can find information about how, whether, and why we collect and use your personal information on our Vive Invest website www.viveapp.com and on our mobile application Vive App. This Policy applies to any personal information that is gathered when you use our services, visit our Website, or otherwise interact with us. We have divided this Policy into different sections. The processing of your personal data complies with the General Data Protection Regulation (GDPR), the Dutch GDPR Execution Act and the Dutch Telecommunications Act.

About us

The data controller for the processing of your personal data is VIVE Invest B.V., registered at the Dutch Chamber of Commerce with registration number 62098896. Our address is Keizersgracht 268, 1016 EV Amsterdam, the Netherlands.

If you have any questions about the processing of personal data resulting after reading our Privacy Statement, you can contact us at privacy@viveapp.com.

Types of personal data we collect

To assess and open Vive Website and Mobile Application accounts, we can collect and use the following personal data:

• First and last name
  
• Date, country and place of birth
  
• Nationality
  
• Gender
  
• Residential address
  
• Telephone number
  
• Email address
  
• Social security numbers and/or other tax identification numbers
  
• Counter IBAN
  
• Device data (such as type of device, operating system, IP-addresses and advertising IDs)
  
• Location data via GPS
  
• Uploaded images/content
  
• Device data of added devices and API-keys
  
• Financial and banking data, product subscriptions and transaction history
  
• Cookies and usage date on how you use our products and services
  
• Correspondence with Vive Invest and support data (telephone, chat conversations and email)
  
• Additional information related to opening an account and creating your personalized investment
  
• Plans such as your knowledge and experience of financial markets, your financial situation, investment situation and preferences and your risk preferences
  
• Marketing data (statistics related to our marketing campaigns and data to measure this)
  

Information about our communication

• When you send us an email, or chat with us online or via social media, we save your correspondence with us if you are already a customer or in the process of becoming one or contacting us to find more about our products and/or services.
  
• Information we collect when you use our Website and/or our mobile application.
  
• When you visit our Website and mobile application or use our services, we may register your IP address, browser type, operating system, referring website, web-browsing behaviour.
  
• We may receive an automatic notification when you open (or open a link from) newsletters from us.
  

Information in relation to social media

Depending on your social network settings, we may receive information from your social network provider. For example, when you sign in for our services using a social network account, we may gather publicly available information you give us access to from your social network profile, including your contact details, interests, and social network.

For more information on the personal data that we receive from your social network provider, and how to change your privacy settings, please refer to the website and the privacy policy given by your social network provider.

Information you choose to share with us

You may also choose to share information with us. For example, when you leave a comment for us on Facebook, fill out a survey, submit a contact or application form, leave a review or submit an entry for a contest or scholarship, you have opted to share personal information with us.

You may also choose to share information with us. For example, when you leave a comment for us on Facebook, fill out a survey, submit a contact or application form, leave a review or submit an entry for a contest or scholarship, you have opted to share personal information with us.

Purposes of processing your data

Vive Invest processes your personal data in accordance with the laws and regulations based on several legal grounds. Vive Invest processes personal data to provide our services. For example, personal data is processed to:

• Comply with legal obligations
  
• To preserve our agreement and to provide our services in a secure manner, we process your personal data. For example, we need your contact information to keep you informed about relevant developments, and we store correspondence data to improve our customer services.
  
• To make your user experience easier and more effective, we may assess how you use our services, and combine this data with information collected via your personal account, registration details, cookies, and similar technologies. This combination enables us to, for example, optimize our search algorithms and offer a better customer experience.
  
• To create better and personalized investment strategies
  
• To process personal information for (direct) marketing purposes. This means we may use your personal information to send you newsletters, emails, promotions, or other marketing communications. We use the results of our analysis to tailor our marketing communications to your specific interests and preferences. For example, if our analysis shows that you may be interested in certain services, we may customize our newsletters and Website with content that is relevant to you. We may use different channels for our marketing communications, such as emails, social media, and your personal online account during different time frames and in recurrent manner.
  
• To initiate and evaluate business relationships. Your personal data will be processed for the entering into agreements and the performance thereof to the point of commercial services and the managing of the business relations which emerge from them, including the performance of activities aimed at the expansion of our client database.

Vive Invest is allowed to process personal data for this purpose because you gave consent or because Vive Invest has a legitimate interest. The consent can be withdrawn at any moment, and you can object at any moment to the processing of your personal data for direct marketing purposes. The withdrawal of consent or exercise of your right to object does not affect the lawfulness of the processing prior to the moment of withdrawal or exercise of the right to object.

You may object or revoke your consent for receiving marketing communications at any time, by following the instructions in the relevant marketing communication or by sending an email to privacy@viveapp.com.

Legitimate and legal interests

In many cases, we are legally required to store certain data about you, for example to verify your identity, for research and to create personalized investment plans.

We can also process certain data when we have a legitimate interest to do so. For example, to prevent and combat misuse, to research and analyze the use of our products and services for marketing purposes, for information and system security or to share certain data with governmental institutions.

Disclosing or sharing data with third parties

General

We reserve the right to release personal information without your consent or without consulting you, when we deem it necessary to comply with our legal obligations, to enforce our terms and conditions, to protect the security of our Website and application, or to prevent fraud.

To be able to provide our services, we share certain personal data with third parties. We keep the sharing to a minimum and ensure these third parties will handle your personal data with the same care as we do. This means, among other things, we sign Data Processing Agreements. The third parties or categories of third parties with whom we share data are: Onfido Limited, VWD, Auth0 and Northern Trust.

Governmental institutions

To comply with laws and regulations we can share data with the concerned institutions. For example, the Tax Authorities can request financial data and we can share data with the Dutch Central Bank for participating in the Deposit Guarantee Scheme. Next to this, Vive Invest can have a statutory or legal obligation to share personal data with investigating authorities to prevent and combat misuse, fraud and crimes.

Security and retention

Vive Invest takes the safeguarding of your information very seriously. Vive Invest will take appropriate technical and organizational measures to protect your personal data against loss or unlawful use. These measures include but are not limited to: facilities protected by appropriate security measures, encryption of devices, version tracking and access to our databases is limited to key personnel and IP addresses and use of it is logged. Personal identifiable information and account activity are also protected through the use of user names and passwords. In order to help maintain the security of your information, you should protect the confidentiality of your user name and password.

How long we keep your personal data

We will hold all the data for so long as we have an obligation to the Customer to provide the Services, and thereafter until such time as we delete the Customer's account in accordance with our Customer Terms and Conditions.

Your personal information will be deleted on one of the following occurrences: - deletion of your personal information by you (or by another person engaged by the Customer); or - receipt of a written request by you (or another person engaged by the Customer) to us

For a large amount of data, we are legally obliged to retain this for a minimum of 5 to 7 years after ending the customer relationship. After this period, we don't store your personal data longer than legally allowed and no longer than necessary for the purposes the data was collected for.

We are able to store personal data for longer periods with a valid legal ground, or when the data is sufficiently (for example) pseudonymised or anonymised.

Your Rights

You can request access to or a copy of your personal data collected by us. You may also request the rectification and removal of personal data or the restriction of the processing of your personal data, if there is a reason for doing so. You also have the right to data portability. You also have the right to object to a processing on grounds relating to your particular situation or against the processing of your personal data for direct marketing purposes. More information on your rights is available at: https://autoriteitpersoonsgegevens.nl.

To exercise your right(s), please send us an email at privacy@viveapp.com or mail us: VIVE Invest B.V., Keizersgracht 203, 1016 DS Amsterdam, The Netherlands.

Revoking & limiting consent

When you have provided us with permission to process personal data, or when we process your personal data based on legitimate interests, you are able to revoke this permission in an easy manner or ask us to limit the use of your data. Revoking your permissions does not mean that stored data is deleted.

Direct marketing & usage data

If you do not want your data to be used for direct marketing activities and analysis of the usage of our products and services, you can let us know via the VIVE app anytime. Next to this, our communication via email contains the possibility to unsubscribe from these messages.

GPS and image and content access

While using the VIVE app, you can provide permission to process location data. If you no longer want us to use location data, you can revoke these permissions easily. This permission is also offering the possibility to protect your account, sending, for example, notifications when there is a login from an unknown location. You'll find these settings in the VIVE app. You can revoke provided permissions at any given moment.

Images and content that you use to personalise your VIVE account can be easily changed in the VIVE app.

Cookies

For more information on how to delete cookies, please see our Cookie Statement.

Modifications to this Policy

This Policy is effective as of 23 of October 2018. We reserve the right to alter or otherwise make changes to this Policy. Notices may be by email to the last email address you provided us, by posting notice of such change on our Site or the Optimizely Service, or by other communication channels. You consent to receiving notices in these ways. We reserve the right to determine the form and means of providing notifications to you, consistent with applicable law. Changes take effect as soon as the Policy is posted.

Questions or complaints

If you have any question or complaints about the processing, please send an email to us at privacy@viveapp.com. If you feel that your rights have been violated, you may also make a complaint with the Autoriteit Persoonsgegevens, the Dutch Data Protection Authority(www.autoriteitpersoonsgegevens.nl). For more information on the protection of personal data, please consult the website of the Autoriteit Persoonsgegevens.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at privacy@viveapp.com.

Investment beliefs of Vive

Vive wants you to be able to achieve your goals through your investments. The investments and investment portfolios are in the service of achieving your financial goals. Vive's asset management to private clients provides the desired investments with an efficient ratio between return and risk, at low cost, in a transparent manner and taking into account widely accepted ESG criteria (i.e. in the areas of environment, social relations and good corporate governance).

Socially responsible investing

Vive believes that investing entails a responsibility that is broader than just a financial fiduciary duty; therefore, environmental, social and corporate governance (ESG) impacts should be an integral part of the investment strategy.

Integrating ESG criteria has added value from a risk/return perspective. Responsible investment includes a combination of:

• Exclusion policy;
• Best in class selection policy;
• Exercise of voting rights and active engagement strategy.

In principle, Vive seeks to select only funds with ESG policies that include the above policy components.

To evaluate the ESG integration in the funds, we look at the fund classification under the EU Sustainable Finance Disclosure Regulation (SFDR). The EU Sustainable Finance Disclosure Regulation (SFDR) is a set of EU rules aimed at making the sustainability profile of funds more comparable and easier to understand for end investors.

Spreading risk and keeping costs low are important

Vive believes that investing is best done through broadly diversified portfolios. Vive strives to diversify as much as possible across asset classes, and within them across geographic regions and sectors. Avoidable risk that is not rewarded by a positive expected risk premium (excess return above the risk-free rate) should in principle be avoided.

Vive does not believe that market timing and tactical asset allocation add value to the client after fees. Vive does not believe that trying to beat the market structurally adds value to the client net of fees. With active management, it is very difficult to outperform the market average. Therefore, the policy is to select funds on a "passive where possible" basis. Vive believes that active management makes sense for less efficient or inefficient markets if it leads to better risk management. Vive's focus within portfolio management is on constructing portfolios by risk level as best as possible based on realistic and plausible (long-term) economic scenarios. Customers' investment horizons range from short-term to long-term. Outsourcing to external asset managers, or providers of unlisted mutual funds in which Vive invests for its clients, allows Vive to focus on adding value for you as a client. Vive can select the mutual funds itself. Vive invests only through unlisted UCITS in the selected asset classes.

Focus on risk management

Risk management is crucial to sustainable asset management. This means measuring risk frequently and adjusting the portfolio as needed. Vive adopts the principle that the value of downside risk of optimal portfolios is updated quarterly and that the composition of optimal portfolios can be adjusted accordingly to achieve the best ratio of expected return to downside risk. To ensure that clients' investment plans remain close to the intended risk profile, Vive monitors your investment portfolios daily and applies rebalancing of the portfolios if they deviate too much from that risk profile. The actual composition is then aligned with the strategic portfolio belonging to the investment plan at the time of rebalancing.

In which investment categories will the money be invested?

The asset classes that qualify for the optimal portfolio should have a positive expected risk premium that is scientifically substantiated.

Based on the investment beliefs, Vive can fill the portfolios with the following asset classes:

• Money market investments in euro;
• Government bonds denominated in euro or hedged to the euro;
• Investment grade corporate bonds denominated in euro or hedged to the euro;
• Global equities, in mature markets and emerging markets;
• High Yield corporate bonds, i.e. corporate bonds of lower credit quality than Investment Grade.

Vive determines a representative index series for each category, which is used to determine the statistical characteristics in Vive Technology's Economic Scenario Generator model. These characteristics determine the degree of risk dispersion across categories.

How does Vive select the funds for each asset class?

Vive offers asset management through investments in unlisted mutual funds ("funds"). Vive does not invest in its own funds but uses third-party funds; this prevents unwanted conflicts of interest.

Vive selects third-party funds based on the following criteria:

Liquid:
The portfolio is composed of unlisted open-ended mutual funds that are traded daily.

High degree of risk diversification:
There is a wide spread within the fund: there are sufficient names in each investment fund and it is ensured that no individual investment has an excessive allocation within the fund, both in terms of Euro weighting and risk weighting. This is tested by applying a 5% worst case scenario to the two largest positions in the portfolio and checking that they do not exceed the Value at Risk of the relevant asset class. If this is exceeded, the fund does not meet the risk diversification criterion and does not qualify for selection.

Low costs:
The ongoing cost factor (OCF) must be low. This is tested by comparing the OCF of a fund to be selected with the median OCF of comparable funds. The level of any entry or exit charge must be in line with the market.

The level of ESG:
Vive believes that investing involves a responsibility that is broader than just a financial fiduciary duty; the effects on environment, social relations and good corporate governance (ESG) should therefore be an integral part of the investment strategy. Integrating ESG criteria has added value from a risk/return perspective. In principle, Vive only selects funds with an ESG policy. If no fund with such an ESG policy is available for a specific asset class, Vive may consider adding a fund that does not meet Vive's ESG selection criteria if the improvement in the return-risk ratio for the client is significant. In this case, it will be specifically recorded and communicated to clients how Vive's ESG policy starting point is deviated from and why Vive believes it is in the best interest of clients that the fund in question can be part of client portfolios.

Appropriate Mandate of the Instrument:
The benchmark of the fund is in reasonable agreement with the representative index series on which the statistical characteristics are based; the tracking error between the two indices is not expected to exceed 1%. This concerns two index series. The index series on which the statistical characteristics are based refers to the index series used to determine the parameters in the Economic Scenario Generator model. The other index series, from the benchmark, refers to the fund's benchmark. The investment universe and risk limits contribute to sufficient risk diversification. In the case of an index tracker, the replication method ensures a good connection to the benchmark (e.g. full replication). The management style of the fund is passive and responsible where possible.

Good quality asset manager:
The asset manager has a proven track record (i.e. has demonstrated reliable asset management in the relevant asset class), has its own risk management in order and has a stable organization. Vive specifically sets an ISAE 3402 certificate as a criterion. The stability of the organization is checked by, among other things, looking at staff turnover both of the organization as a whole and within the group of decision makers.

Suitable and permitted for retail investors within the European Union:
The fund has UCITS (UCITS) status and for the fund the Key Investor Information Document (EBI, in English: KIID) is available in the English language and in the language of the country where Vive offers the app. This means that the EBI is available in the Dutch language for the funds used for clients in the Netherlands.

Funds with securities lending and unnecessary use of derivatives should be avoided:
Vive has a strong preference for funds with no securities lending and no use of derivatives (such as total return swaps). Vive considers the addition of counterparty risk through securities lending undesirable because it is not a transparent source of risk for the client. The use of derivatives in a fund introduces additional risks that cannot be clearly understood by non-professional investors. If a fund without securities lending or derivatives use is not available for a specific asset class, but the improvement in risk-return ratio for Vive's clients is significant, Vive may still consider adding this fund. In this case, it will be specifically recorded and communicated to clients in what manner it deviates from Vive's principle for securities and derivatives lending, and why Vive considers it in the interest of clients that the fund in question may be part of client portfolios. Excluded are funds that use so-called exotics (custom derivatives).

How are investment plans made?

Vive helps clients set investment goals based on preferences that clients specify and within the client's risk tolerance profile based on the client's stated risk appetite. Using a software-defined procedure, an optimal investment strategy is then derived for each goal plan. This strategy is a so-called lifecycle strategy: the "investment risk decreases as the end date approaches.

Vive determines an optimal investment portfolio within the client's risk profile. Vive provides portfolio optimization and rebalancing after adjusting the risk-return characteristics of the underlying asset classes. The optimal portfolios and forecasts for the median and worst-case scenario are based on an economic scenario set generated quarterly by the Economic Scenario Generator model.

Investment plans are implemented by investing for each investment plan in an optimal portfolio belonging to the level of risk the client accepted when the plan was created (or last revised). Vive uses the same consistent portfolio optimization to fill out the investment mix in the different types of investment plans.

Portfolio optimization with eligible asset classes is done by selecting, at each desired Value-at-Risk (VaR) level, the portfolio with the highest expected return (median scenario) based on a realistic 1-year scenario. Vive uses a robust optimization technique to minimize the impact of outliers. The VaR level is determined as the 5% percentile of the probability distribution of portfolio returns.

Part of Vive's services includes rebalancing the portfolios in the investment plans created by the client. Differences between the actual portfolio and the strategic portfolio for the client's investment plan can occur due to price movements and change in the strategic portfolio. The purpose of rebalancing is to align the actual portfolio with the strategic portfolio associated with the specific investment plan at that time.