Obligations of the operator

Siamosoci S.r.l., through its portal mamacrowd.com:

  1. operates with diligence, fairness and transparency, avoiding that any conflicts of interest that may arise in the management of the Portal negatively affect the interests of investors and bidders, and ensuring equal treatment of the recipients of offers that are in identical conditions
  2. makes available to Investors, in a detailed, correct, clear, non-misleading and non-omitted manner, all the information regarding the Offer that is provided by the Offeror so that they may reasonably and fully understand the nature of the investment, the type of financial instruments offered and the risks associated with them and make investment decisions in an informed manner
  3. draws the attention of Investors other than professional Investors to the advisability of investments in high-risk financial assets being adequately proportionate to their financial resources. Siamosoci does not disseminate news that is inconsistent with the information published on the portal and refrains from making recommendations regarding the financial instruments that are the subject of individual offers that could influence the trend of subscriptions
  4. ensures that the information provided through the Portal is up-to-date, accessible for at least twelve months following the closure of the offers and made available to interested parties who request it for a period of five years from the date of closure of the Offer
  5. ensures that Investors other than Professional Investors have the right to withdraw from the order, free of charge, by notifying the Manager, within the time limits provided for, depending on the case, by the Consob Regulations or the Consumer Code, starting from the date of the order

The Manager directly performs the verification provided for in Article 13, paragraph 5-bis of Regulation 18592/2013, without resorting to authorized intermediaries (i.e. the Banks in charge of managing the investors' transfers), which would otherwise be required to perform the same verification activity for so-called 'supra-threshold' transactions: the Manager verifies online by means of a special questionnaire which is submitted to the investor as part of the procedure for placing orders to join the Offers that theinvestor has the level of experience and knowledge necessary to understand the essential characteristics and risks involved in the investment, on the basis of the information provided pursuant to Article 15, paragraph 2, letter b). Such information shall refer at least

  • the types of services, operations, also carried out through on-line portals, and financial instruments with which the investor is familiar;
  • the nature, volume and frequency of transactions, including through on-line portals, in financial instruments, carried out by the investor and the period during which these transactions have been carried out
  • the level of education, the profession, or if relevant, the previous profession of the investor;

If the manager considers that the instrument is not appropriate for the client, he shall warn the client of this situation, including by means of electronic communication systems.

Warnings on the appropriateness assessment that the investor must be aware of

The assessment of appropriateness of investors' orders related to the subscription of financial instruments on the Mamacrowd portal, which is carried out in the interest of the investor, is one of the mechanisms of protection of the Portal's users provided for by Consob Regulation 18592/2013 (hereinafter, the "Regulation"), and consists in verifying that the Investor has the level of experience and knowledge necessary to understand the risks involved in the financial instrument he intends to purchase.

Through the assessment of appropriateness, the Manager verifies that the investment is in line with the characteristics of knowledge and experience of the investor resulting from the answers provided to theappropriate questionnaire. The information is collected before the investment is made and is valid for 1 year.

The answers provided can be updated at any time directly online in the private area of the Mamacrowd website in the "Personal Profile Management" section. The information provided is an essential element for the correct evaluation of the financial instruments offered on the Portal and of the related risks; therefore, it is in the interest of the Investor to provide complete, timely, truthful and updated information, as well as to promptly inform the Portal of any relevant changes. In particular, the Manager assesses whether the investment of the client of the Portal is appropriate taking into account the answers provided to the questions of the questionnaire and the fact that all transactions that will be concluded on the Portal refer to investments characterized by the highest degree of risk:

  • of loss of the entire capital invested
  • of illiquidity of the financial instrument purchased

If the Manager has the necessary information he can carry out the assessment of appropriateness and warn the investor in case of any inappropriateness. In any case, taking into account the warnings received by the Manager, in case of inappropriateness of the transaction, the Investor may always decide to cancel the transaction or confirm the request for execution, even in case of incomplete information provided. If the Manager does not have the necessary information, he will inform the Investor about the impossibility of carrying out the appropriateness assessment and, therefore, he will ask the Investor for a further confirmation about his will to continue (by completing the order) or to cancel the transaction.

Contacts: email: support@mamacrowd.com - tel: +39 0240031306