Swiss Regulatory Requirements:

As of March 2015, marketing of foreign alternative funds (Hedge, Private Equity, Venture Capital and Real Estate) can no longer be conducted through the private placement exemption.

Reliance on "Reverse inquiry" is practically impossible. The definition of "distribution" is very broad and includes any direct or indirect discussion, introduction or promotion of the fund – effectively negating any reverse solicitation safe harbour. Marketing to the following Swiss investors requires the fund to appoint a Swiss Representative and a Swiss Paying Agent:

• Pension Funds

• Family Offices

• Independent Wealth Managers

• High Net Worth Individuals

• Banks investing in a fund for a client outside discretionary or, in certain instances, advisory mandates

• Function of the Swiss Representative:

• Ensures the fund is distributed in compliance with Swiss regulation (i.e. ensures the fund Promoter and Distributor are fully informed of Swiss regulatory requirements on a continual basis)

• Acts as local contact point for Swiss investors and the financial regulator FINMA

• Makes the fund offering documents available, free of charge, to Swiss investors at their request

• Ensures the fund's Distributor is adequately authorised and supervised in compliance with Swiss regulations and formally appoints the Distributor for marketing in Switzerland via a Distribution Agreement

• Ensures the fund's offering/marketing documentation contains mandatory Swiss disclosure language

• Ensures the Distributor undertakes classification of qualified investors before promoting the fund

• Obtains annual confirmation of compliance with Swiss law from Distributor

Swiss Regulatory Requirements:

Marketing of UCITS to Swiss Non-Qualified Investors (i.e. retail investors) requires:

• FINMA authorisation of the fund

• The fund to appoint a Swiss Representative and a Swiss Paying Agent

• Publication of the fund's NAV and fund data on a Swiss publishing platform

• Prospectus, constitutional documents, KIIDs and annual (and semi-annual) reports to be made available.

• Amendment of the prospectus and KIIDs to comply with Swiss requirements (including Swiss disclaimer in all fund documentation)

Once appointed, the Swiss Representative is responsible for preparing and submitting the fund authorisation request to FINMA.

The overall timeframe for obtaining FINMA authorisation is approximately 6 weeks (approval by FINMA takes at least 4 weeks following the authorisation request).

• Advantages of working with ASR:

• Internal legal and compliance expertise enabling quick execution

• Digitalised on-boarding, monitoring and audit process

• Long standing and continuous relationship with FINMA

• Competitive pricing: no set-up fee and annual fixed fee including all representation services both for single funds and umbrella structures

• Introduction and distribution capability

• Privileged relationship with network of law firms.

ASR offers distribution services in Switzerland and the UK, on a case by case basis. The services offered as set out below:

Integrated:

Partnering with fund managers to build and maintain an investor base in the agreed geographic zone. Hands-on approach and support provided in all aspects of capital raising.

Consulting:

Market research and road show arrangements. Roundtable events.