ZASI Bitspiration Booster

INFORMATION POLICY FOR ZASI/ASI

Information on business activities

Bitspiration Booster spółka z ograniczoną odpowiedzialnością (Limited Liability Company) is an Externally Managed Alternative Investment Companies Manager (“Zewnętrznie Zarządzający Alternatywnymi Spółkami Inwestycyjnymi”, hereinafter as ZASI) as defined in Article 8b(2)(2) of the Act of 27 May 2004 on Investment Funds and the Management of Alternative Investment Funds (“UFIZAFI Act”). The company was registered in the Register of ZASI, maintained by the Polish Financial Supervision Authority (KNF), on 28 July 2017.

Depending on the total value of assets included in the investment portfolios of the Alternative Investment Companies (hereinafter also referred to as “ASI”) managed by a particular ZASI, ZASI operates either based on a KNF license or by registration in the ZASI register. Registration in the ZASI register is sufficient for ZASI managing investment portfolios of lower value.

All ZASI under the UFIZAFI Act are subject to KNF supervision as entities operating in the capital market, to the extent they are required by applicable laws related to participation in this market. However, the scope of KNF supervision varies depending on whether given ZASI operates based on registration or a license. For ZASI operating under a license, the scope and oversight capabilities of the KNF are significantly broader, as the licensing process and subsequent ongoing supervision, along with the operational requirements for such ZASI, are shaped similarly to those of investment funds.

Since ZASI operating under registration manage portfolios of lower value, the requirements and legal regulations imposed on them are significantly simplified and limited.

Therefore, when deciding to invest in ASI managed by us, it is important to keep in mind that KNF supervision over a ZASI registered in the ZASI register is generally limited to an annual audit of the assets managed by that ZASI. In particular:

• The legal requirements for documents submitted with the application for registration as ZASI are much more limited compared to the requirements for a license application;
• Ongoing KNF supervision of ZASI operating under registration mainly focuses on monitoring the size of the assets managed by these companies and the types of investments and markets they operate in, with the goal of identifying potential systemic risks posed by the collective activities of ZASI, based on special reports submitted annually to the KNF. Consequently, we are not required to submit annual financial statements to the KNF (neither as a ZASI nor on behalf of the ASI we manage);
• The KNF does not supervise or verify the composition of the ASI investment portfolio, or any changes in the internal documents of the ASI, such as its investment policy or investment strategy;
• We are not required to enter into an agreement with a depository (a bank or investment firm) that would store and maintain a register of all ASI assets and also act as an additional supervisory entity overseeing the actions taken by ASI and ZASI to ensure that regulated activities are carried out in compliance with the law and the ASI’s internal regulations;
• We are not legally required to adopt and maintain a number of internal documents regulating our activities, such as remuneration policies, engagement policies, internal control system procedures (including compliance), audit procedures, or risk management procedures.

Given the limited regulations governing ZASI operating under registration, and consequently, the limited supervision by the KNF, capital market participants must be aware of the general, elevated investment risk associated with investing in participation rights of such ASI.