In accordance with the Estonian Securities Market Act subsection 46 (11), we (Grünfin AS) are required to establish written procedures for treating our clients in the meaning of the Securities Market Act.

A client is any person to whom we provide our investment services, and a potential client is a person to whom we want to provide or offer our services, but with whom no contractual relation has been entered into.

Our client classification procedures are very simple. We shall not treat any client or potential client as a professional client or as an eligible counterparty even if he/she wants to be treated as a professional or eligible counterparty. We treat all our clients and potential clients only as retail clients which gives the client the highest legal protection (i.e. the clients who are not professional clients or eligible counterparties). This is also agreed in our client agreements.