Legal Disclosure
Last updated: July 21, 2026
1. General
This Legal Disclosure includes general information and disclosures in connection with the activities of Sigma Clarity Ltd. and its group companies, as applicable ("Sigma Clarity Group" or the "Group"), including disclosures required or customary under applicable law, including the Regulation of Investment Advice, Investment Marketing and Investment Portfolio Management Law, 5755-1995, as applicable.
This Disclosure is general only and does not replace a specific disclosure, engagement agreement, offering document, prospectus, report, immediate report, policy document, onboarding document or any other binding document, as applicable.
2. Group Companies and Main Areas of Activity
Sigma Clarity operates through the Group companies in various areas of the capital markets and financial services, including Portfolio Management, Investment Marketing, management of mutual funds, underwriting, distribution, brokerage, execution services, TASE Member services, structured products, financial planning and pension/insurance marketing, all subject to applicable law and to the licenses, permits and agreements applicable to each company.
3. Licenses, Investment Marketing and Portfolio Management
Clarity Capital KCPS Ltd. and Sigma Portfolio Management Ltd. hold a Portfolio Manager License and engage in Portfolio Management and Investment Marketing, and not Investment Advice, as these terms are defined in the Investment Advice Law.
Psagot Securities Ltd. is a TASE Member and holds an Investment Marketing license, and is engaged, among other things and subject to applicable law, in Investment Marketing, securities execution services and related capital market services. Psagot Securities Ltd. engages in Investment Marketing and not Investment Advice.
Sigma Premium Ltd. operates for Qualified Clients only, as this term is defined under applicable law, and does not hold a Portfolio Management license and/or an Investment Marketing license. Services are provided by the relevant company in the Group and in accordance with the license, permit, law and agreements applicable to it.
4. Information on the Website and in Mailings
The information on the Website, in mailings, publications or reviews of the Group is general information only, and does not constitute Investment Advice, pension advice, insurance advice, tax advice, legal advice or marketing/advice tailored to the personal data and needs of any particular person, unless expressly stated otherwise and subject to applicable law.
5. Affiliations with Financial Assets, Products and Related Entities
The Group companies have or may have, from time to time, an affiliation, interest or business connection with financial assets, securities, mutual funds, structured products, pension products, insurance products, issuers, institutional entities, financial institutions, transactions or financial services, including because they are managed, issued, distributed, marketed or offered by any of the Group companies or by entities related to them, or due to the receipt of commissions, distribution fees, management fees, success fees, commission rebates, revenue sharing or any other economic benefit, directly or indirectly.
As a result, the Group companies may offer, market, present or execute for clients transactions in financial assets or products with which the Group or any of its companies has an affiliation, including in preference to other financial assets or products that are similar in terms of suitability to the client and with which the Group has no affiliation, all subject to applicable law and the disclosure and suitability obligations applicable in the relevant circumstances.
6. Affiliation with Mutual Funds
Clarity Capital KCPS Ltd. and Sigma Portfolio Management Ltd. are related corporations of Sigma Mutual Funds Ltd. Accordingly, they have or may have an affiliation, interest or business connection with mutual funds managed by Sigma Mutual Funds Ltd., including because the funds are managed, offered or marketed by a company of Sigma Clarity Group, and due to the possibility of receiving an economic benefit, commission or other consideration in connection with an investment in or holding of such funds, all subject to applicable law.
Further information is available on the Tel Aviv Stock Exchange website: https://www.tase.co.il/he
Specific information regarding mutual funds, to the extent published on the Website, will be published in accordance with applicable law and subject to the relevant prospectuses, reports and disclosure documents, including the required notes, warnings and disclosures under applicable law. The purchase of units in a mutual fund, to the extent made, will be made on the basis of a valid prospectus, reports and filings and in accordance with applicable law.
7. Structured Products
The Group companies, including Sigma Premium Ltd. and/or other Group companies, may from time to time market, offer, purchase, distribute or include, as part of their services, structured products issued by various financial institutions, subject to applicable law, the relevant agreements and the characteristics of the client or service, as applicable.
The Group and/or any Group company may have an affiliation, interest or business connection with structured products and the entities issuing them, including due to the receipt of commissions, distribution fees, commission rebates, revenue sharing or any other economic benefit, directly or indirectly, in connection with the marketing, distribution, purchase, holding or execution of transactions in such products.
As of the date of publication of this Disclosure, the issuers of structured products with respect to which the Group has or may have an affiliation, interest or business connection include, among others, the entities listed below. The list may be updated from time to time:
The foregoing does not constitute a recommendation, offer or undertaking to market or purchase any structured product or any product issued by any of the entities listed above. Each product should be reviewed according to its documents, terms and characteristics.
8. Pension Marketing, Underwriting, Brokerage and Additional Services
Sigma Financial Planning may have an affiliation, interest or business connection with institutional entities, insurance companies, management companies of provident funds and pension funds and additional entities, including due to the receipt of commissions, distribution fees or other economic benefits in connection with the marketing of products managed or offered by them.
The Group companies may, from time to time, participate in public or private offerings, act as underwriter, distributor, advisor, marketer, offering manager, member of an underwriting consortium or other service provider in connection with securities, financial assets, issuers or transactions in the capital markets. Accordingly, the Group or any of its companies may have an affiliation, personal interest, economic benefit or business connection in connection with certain publications or transactions.
The Group companies may provide, themselves or through related companies, execution, trading, brokerage, receipt and transmission of orders, custody, clearing, distribution and related services, subject to applicable law, licenses and the relevant agreements. Some of the services are intended for institutional entities, Qualified Clients, corporations or other professional parties, and are not necessarily intended for the general public.
9. Publications and Additional Disclosure
Publications, reviews, articles, updates, data or other materials on the Website or in Group mailings may refer to securities, financial assets, issuers, funds, products, transactions or services with respect to which the Group or any Group company has or may have an affiliation, personal interest, business connection or economic benefit.
To the extent required by applicable law or by the nature of the publication, additional or specific disclosure will be provided in the relevant publication, offering document, prospectus, report, agreement or disclosure document.
10. Priority of Binding Documents
In any case of discrepancy or inconsistency between this Disclosure or the Website and the provisions of an engagement agreement, onboarding document, prospectus, report, offering document, specific disclosure document, provision of law or instruction of a competent authority, the binding document or provision of law shall prevail, as applicable.
11. Updates to the Disclosure and English Version
The Group may update this Legal Disclosure from time to time. The updated version will be published on the Website and will take effect upon publication, unless stated otherwise.
This Legal Disclosure may be published on the Website in both Hebrew and English. In the event of any discrepancy between the Hebrew version and the English version, the Hebrew version shall prevail, unless expressly stated otherwise.
