Polus Capital Management (Us) Inc..

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MEDIOBANCA-BANCA DI
CREDITO FINANZIARIO S.P.A
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
COMMISSIONE NAZIONALE PER LA SOCIETA' E LA BORSA (CONSOB)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/17/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
19335 OF 08/26/2015
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
MEDIOBANCO- BANCA DI CREDITO FINANZIARIO S.P.A
6.
Principal Product Type:
Other
Other Product Types: 
TWO ACCELERATED BOOK BUILDING TRANSACTIONS AND ONE REVERSE ACCELERATED BOOK BUILDING TRANSACTION IN RELATION TO SHARES OF
ITALIAN LISTED ISSUER
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
CONSOB ALLEGED MISSING OR DELAYED ENTRIES IN THREE REGISTERS HELD FOR MARKET ABUSE PURPOSES IN RELATION TO THREE BOOK BUILDING
TRANSACTIONS OCCURED IN 2013 AND 2014.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
08/26/2015
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 16,900.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
A MONETARY SANCTION OF THE EQUIVALENT OF $16,900 WAS LEVIED. THIS WAS PAID IN FULL BE MEDIOBANCA AND NO APPEAL WAS FILED.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to

requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
A MONETARY SANCTION OF THE EQUIVALENT OF $16,900 WAS LEVIED. THIS WAS PAID IN FULL BY MEDIOBANCA AND NO APPEAL WAS FILED.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE ACTION STATUS IS FINAL AS THE MONETARY SANCTION LEVIED BY CONSOB AGAINST MEDIOBANCA WAS PAID BY MEDIOBANCA AND NO APPEAL
WAS FILED.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MEDIOBANCA - BANCA DI
CREDITO FINANZIARIO S.P.A
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
COMMISSIONE NAZIONALE PER LA SOCIETA' E LA BORSA (CONSOB)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
02/17/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
0022744/17
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
MEDIOBANCA - BANCA DI CREDITO FINANZIARIO S.P.A
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ALLEGED BREACH OF RULES ON DISCLOSURE OBLIGATION TO THE MARKET IN RELATION TO A TRANSACTION REGARDING AN ITALIAN LISTED COMPANY
ACTIVE IN THE TMT SECTOR
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
10/11/2017
 Exact
 Explanation
If not exact, provide explanation:
CONSOB ISSUED A SANCTION ORDER ON 11 OCTOBER 2017. MEDIOBANCA SUBSEQUENTLY APPEALED THE CONSOB ORDER BUT THE ORDER HAS BEEN
CONFIRMED.
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 86,900.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
CONSOB ISSUED A SANCTION ORDER ON 11 OCTOBER 2017. SANCTION ORDERED WAS A MONETARY PENALTY OF $86,900.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
CONSOB ISSUED A SANCTION ORDER ON 11 OCTOBER 2017. MEDIOBANCA SUBSEQUENTLY APPEALED THE CONSOB ORDER BUT THE ORDER HAS BEEN
CONFIRMED.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MEDIOBANCA - BANCA DI
CREDITO FINANZIARIO S.P.A
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
COMMISSIONE NAZIONALE PER LA SOCIETA' E LA BORSA (CONSOB)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 

3.
Date Initiated (MM/DD/YYYY): 
12/16/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
37969/2015 (95029/15)
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
MEDIOBANCA - BANCA DI CREDITO FINANZIARIO S.P.A
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ALLEGED BREACH OF DISCLOSURE OF NET SHORT POSITIONS ON THE SHARES OF AN ITALIAN LISTED COMPANY ACTIVE IN THE TMT SECTOR
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Dismissed
11. Resolution Date (MM/DD/YYYY):
09/14/2016
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
NO SANCTION WAS ISSUED
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
CONSOB DISMISSED THE ALLEGATIONS AGAINST MEDIOBANCA. NO SANCTION WAS ISSUED.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
CONSOB DISMISSED THE ALLEGATIONS AGAINST MEDIOBANCA. NO SANCTION WAS ISSUED.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANCA MONTE DEI PASCHIDI
SIENA SPA
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
BANK OF ITALY
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/03/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
BANK OF ITALY NO.698152/2021
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 

7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
SHORTCOMINGS IN TRANSPARENCY AND FAIRNESS IN CUSTOMER RELATIONS AND INCORRECT APPLICATION OF COMMISSIONS. THESHORTCOMINGS
HAVE BEEN REMEDIED.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
12/31/2022
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 3,110,540.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
IN 2021 BANCA MONTE DEI PASCHI DI SIENA S.P.A. WAS FINED BY THE BANK OF ITALY BY EUR 2,9 MILLION FOR FAILURE TO ACT TRANSPARENTLY
AND TREAT CUSTOMERSFAIRLY. THE SHORTCOMINGS HAVE BEEN REMEDIED AND CUSTOMERS REFUNDED BY EUR 40 MILLION APPROXIMATELY.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
SHORTCOMINGS HAVE BEEN REMEDIED AND CUSTOMERS HAVE BEEN REFUNDED. THE MONETARY FINE HAS BEEN PAID IN 2022 BY BANCA MONTE DEI
PASCHI DI SIENA S.P.A. WITHOUT CHALLENGING IT BEFORE THE COURT OF APPEAL. IN 2025 THERE WAS ANOTHER INSPECTION OF BANK OF ITALY ON
THE SAMETOPIC CONCLUDED WITH A POSITIVE SCORE.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANCA MONTE DEI PASCHI DI
SIENA S.P.A
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
BANK OF ITALY
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/17/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
BANK OF ITALY NO. 1526250/19
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WEAKNESS IN THE AML CUSTOMER DUE DILIGENCE AND SUSPICIOUS ACTIVITY REPORTING PROCESSES. THE SHORTCOMINGS HAVE BEEN REMEDIED.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
01/16/2020
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 1,447,940.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
SHORTCOMINGS HAVE BEEN REMEDIED AND A DEDICATED ACTION PLAN COMPLETED. THE ACTION PLAN WAS DEFINED ON THE BACKOF THE
WEAKNESSES IDENTIFIED IN 2018 BY THE BANK OF ITALY WHICH LED TO A MONETARY FINE OF 1.3 MILLION EUR THAT HAS BEEN PAID BY BANCA
MONTE DEI PASCHI DI SIENA S.P.A. WITHOUT CHALLENGING IT IN THE COURT OF APPEAL.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
SHORTCOMINGS HAVE BEEN REMEDIED AND A DEDICATED ACTION PLAN COMPLETED. THE ACTION PLAN WAS DEFINED ON THE BACK OF THE
WEAKNESSES IDENTIFIED IN 2018 BY THE BANK OF ITALY WHICH LED TO A MONETARY FINE OF 1.3 MILLION EUR THAT HAS BEEN PAID BY BANCA
MONTE DEI PASCHI DI SIENA S.P.A WITHOUT CHALLENGING IT IN THE COURT OF APPEAL.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE

CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MEDIOBANCA-BANCA DI
CREDITO FINANZIARIO S.P.A
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
SEVERAL SHAREHOLDERS OF LA FONDIARIA ASSICURAZIONI S.P.A. (NOW UNIPOLSAI ASSICURAZIONI S.P.A.).
2.
Principal Relief Sought:
Money Damages (Private/Civil Complaint)
Other Relief Sought: 
3.
Filing Date of Court Action (MM/DD/YYYY):
12/01/2003
 Exact
 Explanation
If not exact, provide explanation:
FILING DATES OF THE ACTIONS RANGED FROM DECEMBER 2003 TO MAY 2014.
4.
Principal Product Type:
Other
Other Product Types: 
EQUITY-SHARE CAPITAL
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
COURT OF MILAN AND COURT OF FLORENCE-ITALY-SEVERAL CASE NUMBERS
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
N/A
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
ON DECEMBER 18, 2002, THE ITALIAN STOCK MARKET REGULATOR ("CONSOB"), RULED THAT MEDIOBANCA ACTED IN CONCERT WITH OTHER
COMPANIES DURING THEIR COMBINED PURCHASE OF MORE THAN 30% OF THE SHARE CAPITAL OF LA FONDIARIA ASSICURAZIONI S.P.A. ("FONDIARIA",
NOW UNIPOLSAI ASSICURAZIONI S.P.A. ("UNIPOLSAI") IN VIOLATION OF ARTICLES 106, 109 AND 122 OF LAW DECREE NO. 58 OF 24 FEBRUARY 1998
(THE ITALIAN CONSOLIDATED FINANCIAL ACT - "TUF") BY OMITTING TO LAUNCH A PUBLIC TENDER OFFER, IN BREACH OF SUCH MANDATORY
PROVISIONS. SIMILAR RULINGS HAVE BEEN ISSUED BY THE ADMINISTRATIVE COURT OF LAZIO (TAR LAZIO), THE ITALIAN ANTITRUST AUTHORITY
(AGCM) AND ALSO BY THE COURT OF APPEAL OF MILANO AND TORINO. FOLLOWING SUCH RULINGS, 16 CIVIL PROCEEDINGS WERE BROUGHT BY
FONDIARIA'S MINORITY SHAREHOLDERS AGAINST UNIPOLSAI AND MEDIOBANCA. WITH RESPECT TO THE STATUS OF SUCH PROCEEDINGS, THESE HAVE
BEEN ALL TERMINATED. THE PROCEEDING BROUGHT BY MR. ROBERTO GAVAZZI, INDICATED AS PENDING AS OF THE DATE OF THE LAST CIVIL JUDICIAL
ACTION DISCLOSURE REPORTING PAGE, HAS BEEN SETTLED ON JANUARY 9, 2025 WITH THE PAYMENT BY MEDIOBANCA OF AN AMOUNT OF 58,091.26
EURO. THE PROCEEDING HAS BEEN DECLARED FINALLY TERMINATED BY COURT ORDER OF JANUARY 29, 2025. WITH RESPECT TO THE CLAIMS BROUGHT
BY THE PLAINTIFFS IN ALL THE PROCEEDINGS, PLEASE NOTE THAT AN IMPORTANT PRINCIPLE HAS BEEN STATED, IN ONE OF THE PROCEEDINGS THAT
WAS LATER SETTLED, BY THE ITALIAN HIGH COURT (COURT OF CASSATION), IN DECISION NO. 14400 DATED AUGUST 10, 2012. THE COURT STATED
THAT EACH MINORITY SHAREHOLDER THAT HAS BEEN UNLAWFULLY DEPRIVED OF THE CHANCE TO PARTICIPATE IN A PUBLIC TENDER OFFER ON THE
SHARES HAS THE RIGHT TO RECEIVE COMPENSATION FOR DAMAGES SUBJECT TO PROOF THAT THE LOSS OF THE CHANCE TO GAIN PROFITS DEPENDS
ON THE LACK OF THE LAUNCH OF A PUBLIC TENDER OFFER, IN VIOLATION OF THE PROVISIONS OF TUF. AS A RESULT, THE PROCEEDINGS RELATE TO
THE SAME UNDERLYING VIOLATION OF ITALIAN LAW AND CAN THUS BE CONSIDERED PART OF THE SAME EVENT OR PROCEEDING.

8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
N/A
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Judgment Rendered
12. Resolution Date (MM/DD/YYYY): 
01/08/2025
 Exact
 Explanation
If not exact, provide explanation:
ALL PROCEEDINGS HAVE BEEN TERMINATED.
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
PAYMENT AS COMPENSATION FOR DAMAGES IN A TOTAL AMOUNT OF APPROXIMATELY EURO 30,5 MILLION PLUS LEGAL EXPENSES.
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
ALL PAYMENTS HAVE BEEN MADE IN ACCORDANCE WITH THE RELEVANT SETTLEMENT AGREEMENTS AND/OR JUDGEMENTS.
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided). 
OF THE 16 CLAIMS BROUGHT, ALL HAVE BEEN SETTLED. CLAIMS SETTLED-PAYMENT AS COMPENSATION FOR DAMAGES IN TOTAL OF APPROXIMATELY
EURO 30.5 MILLION PLUS LEGAL EXPENSES.