Legal Notice & Regulatory


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No offer

The information published on our website constitutes neither an invitation nor an offer to use the services of POLARIS (Europe) AG or its parent company, POLARIS Investment Advisory AG. It is intended for information purposes only.


The content of the POLARIS website is protected by copyright. Should you wish to use its content for commercial purposes, please contact us.

Disclaimer for the content of the website as well as for linked websites

Publications on our website are based on sources, which we consider reliable. They have been compiled and checked with the greatest possible care. However, since the information is based on information provided by third parties, we disclaim any liability for its accuracy, completeness or timeliness. We attract your attention to the possibility of manipulation, the dangers of viruses or other harmful programs and the possibility of hacker attacks.

Access restrictions under the user's national law

Access to information on our website may be restricted or even prohibited by laws and regulations applicable to you.

Changes to the website

We reserve the right to adjust the content of the website at any time.

Information pursuant to the article 5 of the E-Commerce Act - ECG (Liechtenstein Legal Gazette 2003 No. 133) and the article 20 of the Services Act - DLG (Liechtenstein Legal Gazette 2010 No. 385)

Austrasse 52
9490 Vaduz
Phone: +423 388 10 20

Commercial Register No. FL-0002.694.684-8
Value Added Tax Number: 62648
Legal Entity Identifier: n/a
Registered office: Vaduz
Board of Directors: Martin Schweikhart, Rolf Dreiseidler, Stefan Brägger
Management: Evelyn Hilpold, Claus Hilpold
Auditors: BDO Liechtenstein AG, Wuhrstrasse 14, 9490 Vaduz, Liechtenstein

POLARIS (Europe) AG, Vaduz, is an Asset Management Company authorized in Liechtenstein.

Financial Market Authority

Financial Market Authority (FMA) Liechtenstein
Landstrasse 109
9490 Vaduz, Liechtenstein

Professional Association

VuVL Association of Independent Asset Managers in Liechtenstein
Kirchstrasse 1, P.O.Box 544, FL-9490 Vaduz

Responsible officer for client complaints

We kindly ask you to address any complaints either by mail to the above address or by email to the Company's Compliance Department at

Applicable professional regulations

Law of 25 November 2005 on Asset Management and Ordinance on the Asset Management Act (available at or as well as the Code of Professional Conduct of the Association of Independent Asset Managers in Liechtenstein (VuVL), available at

Information pursuant to the Liechtenstein Media Act (MedienG)

Publisher, media owner and editorial office of the website
Austrasse 52
9490 Vaduz

Company’s activity

Provision of services in the field of distribution or private placement of financial products and investment advice.

Shareholder of the media owner

POLARIS Investment Advisory AG, Zurich

Basic content

The purpose of this website is to present POLARIS Investment Advisory AG and POLARIS (Europe) AG as well as their services.

POLARIS Group ("POLARIS") consists of two companies

POLARIS Investment Advisory AG with its registered office in Zurich and its wholly owned subsidiary, POLARIS (Europe) AG with its registered office in Vaduz.

Information pursuant to article 3 para. 1 lit. s UCA

POLARIS Investment Advisory AG
Bahnhofplatz 12
8001 Zurich
Phone: +41 44 365 70 80

Commercial register no. CHE-114.611.274
Value Added Tax Number: CHE - 114.611.274 VAT
Legal Entity Identifier: n/a
Registered office: Zurich
Board of Directors: Claus Hilpold, Evelyn Hilpold
Management: Rolf Dreiseidler, Stefan Brägger
Auditors: BDO AG, Schiffbaustrasse 2, 8005 Zurich


Swiss Financial Ombudsman Service (FINOS)
Talstrasse 20
CH-8001 Zurich

Swiss Register of Advisors

Pursuant to article 28 FinSa, client advisors of Swiss financial services providers who are not supervised pursuant to article 3 FINMASA may only exercise their activities in Switzerland, if they are entered into a register of advisors. All client advisors of POLARIS Investment Advisory AG are registered in the advisor register of BX Swiss AG, Zurich.

Responsible officer for client complaints

Any complaints should be sent either by mail to the above address or by e-mail to the Compliance Department:

Company’s activity

Provision of services in the field of distribution or private placement/introduction of financial products as well as investment advice.

Basic content

The purpose of this website is to present POLARIS Investment Advisory AG and POLARIS (Europe) AG as well as their services.

POLARIS Group ("POLARIS") consists of two companies

POLARIS Investment Advisory AG with its registered office in Zurich and its wholly owned subsidiary, POLARIS (Europe) AG with its registered office in Vaduz.


POLARIS (Europe) AG and POLARIS Investment Advisory AG attach great importance to protecting the privacy of their (potential) customers and business partners. We are pleased to inform you about how your personal data is processed and what rights you have under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data, on the free movement of such data and repealing Directive 95/46/EC (the so-called EU General Data Protection Regulation), the Liechtenstein Data Protection Act (DPA) and the Swiss Federal Data Protection Act, respectively.

The processing of personal data of our users is limited to those data that are necessary for the provision of a functional website and our content and services. The processing of personal data of our users is only carried out for the purposes listed below and if a legal basis exists. Only those personal data are collected that are actually required for the implementation and processing of our tasks and services or that you have voluntarily provided to us.

Name and address of the data controller and the data protection officer

The data controller within the meaning of the General Data Protection Regulation (GDPR) is:

- in case of POLARIS (Europe) AG, Vaduz: POLARIS (Europe) AG, Austrasse 52, 9490 Vaduz, Liechtenstein, website:

- in case of POLARIS Investment Advisory AG, Zurich: POLARIS Investment Advisory AG, Bahnhofplatz 12, CH-8001 Zurich, Switzerland, website:

The compliance officer acts as data protection officer. She can be contacted at the addresses provided above or by e-mail to

Provision of the website

Visitor data

Each time our website is visited, our system automatically records data and information from the computer system of your PC. We store that information for data security reasons in order to ensure the stability and operational reliability of our system.

Web analyses

We do not perform our own web analyses on our website and do not use any web analysis tools. Thus, no evaluation of the aforementioned visitor data takes place.


We use cookies on our website to make our offer user-friendly. Cookies are small files that your browser automatically creates and that are stored on your device (laptop, tablet computer, smartphone, etc.) when you visit our site. The cookies remain stored until you delete them. This allows us to recognize your browser on your next visit.

If you do not agree to the above, you can set up your browser so that it informs you about the setting of cookies and you allow them in individual cases. However, we would like to point out that deactivation will mean that you will not be able to use all the functions of our website.

The legal basis for the data processed by cookies is article 6 para. 1 lit. a or b GDPR.

Contact form

If you fill out a contact form or send us an email or other electronic message, your information will be stored and used only for the purpose of processing your request.

The legal basis for processing your inquiry is article 6 para. 1 lit. a or b GDPR.

Data security

We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

Your rights

You have the right to request information about your personal data processed by us. In particular, you can request information about the processing purposes, the categories of personal data, the categories of recipients to whom your data have been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, data transfer, the origin of your data if they have not been collected by us, and the existence of automated decision-making, including profiling.

You also have the right to revoke any consent you may have given at any time to use your personal data.

You can exercise your aforementioned rights at any time by contacting us at the contact address provided.

If you are of the opinion that the processing of your personal data by us is in conflict with the applicable data protection provisions, you have the possibility to complain to the Data Protection Authority of the Principality of Liechtenstein, Städtle 38, P.O. Box 684, 9490 Vaduz or to the Federal Data Protection and Information Commissioner FDPIC, Feldeggweg 1, 3003 Bern,


A complaint is defined as an expression of dissatisfaction addressed by an individual or legal person to a company in connection with the provision of (i) an investment service under MiFID II, the UCITS Directive or the AIFMD; or (ii) a banking service listed in Annex I of the Capital Requirements Directive (CRD); or (iii) a collective portfolio management service under the UCITS Directive; or (iv) a payment service within the meaning of article 4 (3) of PSD 2; or (v) the issuance of e-money within the meaning of article 2 para. 2 of the E-Money Directive.

We kindly ask you to submit any complaints with detailed information about yourself (surname, first name, address, contact details), the subject of the complaint and your claim either:

·       by mail to POLARIS (Europe) AG, Austrasse 52, 9490 Vaduz or POLARIS Investment Advisory AG, Bahnhofpl. 12, 8001 Zurich (depending on which company your complaint concerns)


·       by e-mail to We will examine it as quickly as possible and send you a reply within 20 working days.

The Liechtenstein Ombudsman, Landstrasse 60, P.O. Box 343, 9490 Vaduz, acts as an external complaints body in the event of complaints against POLARIS (Europe) AG, Vaduz.

Principality of Liechtenstein, For the period from 1.1.2022 to 31.12.2025, the lawyer Dr. Peter Wolff, Vaduz, was appointed as ombudsman.

Complaints against POLARIS Investment Advisory AG, Zurich, can be placed with the Financial Ombudsman Service Switzerland (FINOS), Talstrasse 20, CH-8001 Zurich,, 044 552 0800.



POLARIS (Europe) AG and POLARIS Investment Advisory AG support the idea of sustainable investing and take ESG standards into account when selecting their business partners. They are signatories to the UN PRI, the United Nations Principles for Responsible Investment.

Disclosure sustainability according to regulation (EU) 2019/2088

1. General Regulations (EU) 2019/2088 and (EU) 2020/852 require certain disclosures regarding the sustainability of financial market participants. We comply with these disclosure requirements by providing information here.
Our services include Private Placement/ Third Party Introduction as well as - in case of POLARIS (Europe) AG - investment advice.

2. How are sustainability risks taken into account?
As a company, we want to make our contribution to sustainable business with the aim of reducing the impact of climate change and mitigating social injustice. We do this by working with sustainability-oriented asset managers.

3. Explanation for not considering adverse impacts on sustainability factors.
Investment decisions can have adverse impacts on the environment, on social and employee concerns, or on so-called governance factors. We are aware of our responsibility in this regard and strive to avoid adverse impacts at the corporate level.
We do not offer portfolio management services and therefore do not make any investment decisions where we could take sustainability risks into account.
When providing investment advice to our clients, we provide information about sustainability risks and ensure that clients' ESG preferences are considered in the advisory process.
As Placement Agent/ Third Party Introducer, we do not consider adverse impacts of investment decisions on sustainability factors (PAI - Principal Adverse Impact), as investment decisions are taken by external Asset Managers.

4. Consideration of sustainability criteria in compensation policy

Sustainability risks are taken into account in our internal guidelines, compliance with which is decisive for the evaluation of our employees. In this respect, our compensation policy is in line with our strategies for incorporating sustainability risks.


We are required by law to avoid conflicts of interest and have issued internal directives to this effect. Should a conflict of interest turn out to be unavoidable, we would disclose it to the client concerned without delay.


Due to its B2B business policy, POLARIS has no business relationships with private clients. POLARIS’ clients are classified either as institutional or as professional ones.

A professional client within the meaning of the Directive is a client who has sufficient experience, knowledge and expertise to make his own investment decisions and to adequately assess the risks involved. To be considered a professional client, a client must meet the following criteria:

I. CATEGORIES OF CLIENTS THAT ARE CONSIDERED PROFESSIONAL CLIENTS The following entities are considered professional clients for the purposes of the Directive with respect to all investment services and financial instruments:

(1) Entities which are required to be authorised or regulated to operate in the financial markets. The list below shall be understood as including all authorised entities carrying out the characteristic activities of the entities mentioned: entities authorised by a Member State under a Directive, entities authorised or regulated by a Member State without reference to a Directive, and entities authorised or regulated by a third country: (a) Credit institutions; (b) Investment firms; (c) Other authorised or regulated financial institutions; (d) Insurance companies; (e) Collective investment schemes and management companies of such schemes; (f) Pension funds and management companies of such funds; (g) Commodity and commodity derivatives dealers; (h) Locals; (i) Other institutional investors; (2) Large undertakings meeting two of the following size requirements on a company basis: — balance sheet total: EUR 20 000 000 — net turnover: EUR 40 000 000 — own funds: EUR 2 000 000 (3) National and regional governments, including public bodies that manage public debt at national or regional level, Central Banks, international and supranational institutions such as the World Bank, the IMF, the ECB, the EIB and other similar international organisations. (4) Other institutional investors whose main activity is to invest in financial instruments, including entities dedicated to the securitisation of assets or other financing transactions.


Clients other than those mentioned in section I, including public sector bodies, local public authorities, municipalities and private individual investors, may also be allowed to waive some of the protections afforded by the conduct of business rules. Investment firms shall therefore be allowed to treat any of those clients as professionals provided the relevant criteria and procedure mentioned below are fulfilled. Those clients shall not, however, be presumed to possess market knowledge and experience comparable to that of the categories listed in Section I. Any such waiver of the protection afforded by the standard conduct of business regime shall be considered to be valid only if an adequate assessment of the expertise, experience and knowledge of the client, undertaken by the investment firm, gives reasonable assurance, in light of the nature of the transactions or services envisaged, that the client is capable of making investment decisions and understanding the risks involved. The fitness test applied to managers and directors of entities licensed under Directives in the financial field could be regarded as an example of the assessment of expertise and knowledge. In the case of small entities, the person subject to that assessment shall be the person authorised to carry out transactions on behalf of the entity.

In the course of that assessment, as a minimum, two of the following criteria shall be satisfied:

— the client has carried out transactions, in significant size, on the relevant market at an average frequency of 10 per quarter over the previous four quarters,

— the size of the client’s financial instrument portfolio, defined as including cash deposits and financial instruments exceeds EUR 500 000,

— the client works or has worked in the financial sector for at least one year in a professional position, which requires knowledge of the transactions or services envisaged.


Due to its B2B business policy, POLARIS has no business relationships with private clients. POLARIS’ clients are classified either as institutional or as professional ones.

Pursuant to article 4 para. 1 FinSA, the persons for whom they provide financial services shall be assigned to one of the following segments:

1. private clients;

2. professional clients;

3. institutional clients.

Private clients are clients who are not professional clients (Art. 4 para. 2 FinSA).

According to Art. 4 para. 3 FinSA, professional clients are defined as:

a. financial intermediaries as defined in the Banking Act of 8 November 1934 (BankA), the Financial Institutions Act of 15 June 2018 (FinIA) and the CISA;

b. insurance companies as defined in the ISA;

c. foreign clients subject to prudential supervision as the persons listed under a and b above;

d. central banks;

e. public entities with professional treasury operations;

f. occupational pension schemes with professional treasury operations and other occupational pension institutions providing professional treasury operations;

g. companies with professional treasury operations;

h. large companies;

i. private investment structures with professional treasury operations created for high-net-worth retail clients.

Pursuant to article 4 para. 4 FinSA, institutional clients are professional clients pursuant to paragraph 3 letters a-d as well as national and supranational public-law entities with professional treasury operations.

A large company is deemed to be a professional company pursuant to article 4 para. 5 FinSA a company that exceeds two of the following sizes:

a. Balance sheet total of 20 million Swiss francs;

b. Sales revenue of 40 million Swiss francs;

c. Shareholders' equity of 2 million Swiss francs.

Companies of a group for which another company of the same group provides a financial service shall not be deemed to be customers.