NEUTRAX Independence Charter
The document that governs, in written and verifiable form, the structural conditions that ensure the independence of NEUTRAX's activity with respect to its clients' decisions about their holdings.
Preamble
NEUTRAX's independence is not a statement of intent but a structural condition of the relationship with the client.
NEUTRAX acts exclusively in the interest of the instructing client, without receiving fees, commissions, rebates, referral fees, success fees or other economic benefits from third parties involved, directly or indirectly, in the decisions about the holdings that are the subject of the engagement.
NEUTRAX does not broker real estate, does not place products, does not manage assets, does not represent the client before third parties and has no economic interest in the outcome of the transactions it assesses.
NEUTRAX's function is to provide an independent, structured and documented assessment, so that the client can make decisions about their holdings that are clearer, better reasoned and more defensible. The decision always rests, entirely, with the client.
This Charter is published on the neutrax.it website and is an integral part of every professional relationship established by NEUTRAX. Every client receives it attached to the engagement letter.
The principles
- 01
Fees exclusively from the instructing client
NEUTRAX receives fees only from the client who confers the engagement. No other party, at any stage of the relationship, pays NEUTRAX any consideration, commissions, fees or economic benefits connected to the engagement or to the decisions that are its subject.
- 02
Exclusion of commissions, rebates and success fees
NEUTRAX receives, in no form, any commission, rebate, referral fee, fee, success fee or variable component tied to the outcome of transactions in which the client takes part. The consideration for NEUTRAX's work is always fixed, predetermined and stated in writing before the engagement.
- 03
No fees for the introduction of clients
NEUTRAX pays no fees, commissions, referral fees, rebates, percentages, benefits or other economic advantages to those who present, refer or introduce potential clients, including, by way of example, bankers, accountants, lawyers, family officers, advisers, consultants or other trusted professionals. Every request is assessed independently by NEUTRAX, which remains free to accept or decline the engagement according to how well the case fits its scope of work, its standards and the principles of this Charter.
- 04
Exclusion of intermediation and of any operational role
NEUTRAX does not carry out real estate brokerage or intermediation. It does not seek buyers, does not seek sellers, does not approach counterparties, does not place financial products, funds, club deals or transactions. It does not manage real estate, does not administer assets, does not sign on the client's behalf and does not represent the client before third parties.
- 05
No interest in the outcome of the transaction
NEUTRAX has, and declares that it has, no economic interest, direct or indirect, in the outcome of the transactions in which the client takes part, and takes no position, direct or indirect, in the assets under assessment. NEUTRAX's position is external to the outcome: its sole mandate is to make the client's decision clearer, better reasoned and more defensible.
- 06
Transparency on prior relationships
Before accepting an engagement, NEUTRAX checks for any prior relationships, professional or personal, with the parties involved in the decision the client is weighing. Any material relationships are disclosed in writing to the client, who freely decides whether to confer the engagement nonetheless.
- 07
Register of conflicts of interest
NEUTRAX keeps an internal register of conflicts of interest, recording for each engagement: the subject of the work, the parties involved, any prior relationships and the exclusions applied. The register is subject to annual review under principle 14 below.
- 08
Right to decline or suspend the engagement
NEUTRAX reserves the right to decline an engagement, or to suspend its performance, should a condition arise at any time that compromises its independence. Exercising this right entails no penalty for the client and gives the right to the return of any fees not yet accrued.
- 09
Referrals to third-party professionals and operators
Where, in the client's interest, NEUTRAX indicates the names of professionals, technical experts, advisers, operators or other third parties, that indication is purely informational and entails no obligation for the client. Any such indication does not constitute a professional recommendation, a guarantee of results or the assumption of liability for the third party's work. NEUTRAX receives no fees, commissions, rebates, referral fees, benefits or economic advantages, direct or indirect, from the parties it may indicate. The client remains free to choose their own trusted advisers and operators, and to assess independently their competence, terms and suitability for their needs.
- 10
Written scope for every engagement
Every engagement arises from a written engagement letter, which explicitly sets out: the subject of the service, the activities included, the activities expressly excluded, the parties involved, the fee, the payment terms, the duration, the termination conditions and any potential conflicts disclosed.
- 11
Consistency with the client's advisers
NEUTRAX works alongside the client's trusted advisers (tax adviser, lawyer, private banker, family officer) and not in their place. On matters reserved by law to licensed professionals or authorised parties (tax, legal and investment advice, technical assessments), NEUTRAX refrains and directs the client to their own advisers.
- 12
Strict confidentiality, including after the relationship ends
The information NEUTRAX acquires in the course of every professional relationship is treated with the utmost confidentiality and is not disclosed to third parties, save with the client's written consent, legal obligations, requests from the competent authority or the need to protect a right before the courts. NEUTRAX does not disclose its clients' cases, not even in anonymous or aggregate form: it does not use the content of the work carried out for purposes other than the engagement, does not present it in communication materials and does not share it with uninvolved third parties. Access to the documentation by the independent third party charged with the annual review under principle 14, who operates under confidentiality pursuant to that same principle, does not constitute disclosure. The confidentiality obligation persists after the relationship ends, to the extent permitted by law.
- 13
The final decision rests with the client
Under no circumstances does NEUTRAX substitute itself for the client in the decision. NEUTRAX's function is to make the decision better informed, better structured and more defensible. The decision always rests, entirely, with the client.
- 14
Annual review by an independent third party
Compliance with the principles of this Charter is reviewed each year by an independent third party (accountant, auditor, lawyer or compliance adviser), appointed in writing by the company. The review certifies, for the year in question: the absence of fees received from parties other than the instructing client, the absence of variable components in the consideration, the absence of fees paid to third parties for the introduction of clients, and the consistency of the contractual relationships with what this Charter states. The party charged with the review accesses the necessary documentation in protected form, is bound in writing by a confidentiality obligation no less strict than the one NEUTRAX owes its clients, and discloses in no form the cases, names or content of the work examined. The outcome of the review is certified in summary form, with no reference to individual clients or engagements.
- 15
Verifiability by the client
The client may ask NEUTRAX for information on compliance with the principles of this Charter applicable to their engagement, within the limits of the confidentiality owed to third parties and of the company's internal organisation. NEUTRAX undertakes to respond within a reasonable time.
Subscription
This Charter of Independence is approved by the governing body of NEUTRAX S.r.l. and is published on the neutrax.it website. It is an integral part of the conditions under which NEUTRAX provides its services.
Every client receives a copy of this Charter attached to the engagement letter. Signing the engagement letter entails having read and accepted this Charter.
Date of adoption: 9 July 2026.