Legal & Disclaimer.

LEGAL E DISCLAIMER GREN Italia S.r.l. — Corporate Informational Website Version 1.0 — March 2026

This page sets out the legal notices, limitations of liability and regulatory disclaimers applicable to the use of this website. The content has been drafted in accordance with Luxembourg law, European Union regulations and applicable Italian legislation.

1. General Information and Identification of Entities

This website ("www.grenfinance.com", hereinafter the "Website") is operated and maintained by the group of companies headed by GREN (hereinafter, collectively, "GREN" or the "Group"). The entities within the Group operate in compliance with their respective national and European regulatory frameworks.

1.1 Luxembourg Entities

GREN Holding S.à.r.l. Société à responsabilité limitée incorporated under the Loi du 10 août 1915 sur les sociétés commerciales, as amended. RCS Luxembourg: B304429 | VAT: LU 20262404391 Registered office: Parc d'Activités Capellen, L-8308 Capellen, Luxembourg Branch office: JL Towers Mazaya Business Avenue BB2, Dubai, UAE

  • GREN World Management S.à.r.l. Société à responsabilité limitée, Luxembourg law. RCS Luxembourg: B304466 | VAT: LU 20262404634 Registered office: Parc d'Activités Capellen, L-8308 Capellen, Luxembourg

  • GREN Fund 1 SCSp Société en commandite spéciale, structured as a Reserved Alternative Investment Fund (RAIF) under the Loi du 23 juillet 2016 relative aux fonds d'investissement alternatifs réservés. RCS Luxembourg: B304625 | VAT: LU 20265802436 Registered office: Parc d'Activités Capellen, L-8308 Capellen, Luxembourg

1.2 Italian Entity

  • GREN Italia S.r.l. Società a responsabilità limitata, Italian law. VAT: 18286421005 | REA: RM 1774515 Registered office: Viale Luigi Schiavonetti, 270 – Pal. E, 00173 Rome (RM), Italy GREN Italia S.r.l. is not an investment firm and does not provide investment services or activities within the meaning of Legislative Decree 58/1998 (TUF) and Directive 2014/65/EU (MiFID II).

2. Informational Nature of the Website – No Offer or Solicitation

2.1 All information published on this Website is intended solely for informational and corporate communication purposes. No content on the Website may be construed as:

(a) a public offer or an invitation to offer within the meaning of Article 2(1)(d) of Regulation (EU) 2017/1129 (Prospectus Regulation), or within the meaning of Articles 94 et seq. of Legislative Decree 58/1998 (TUF);

(b) an investment solicitation, a personalised recommendation or investment advice within the meaning of Directive 2014/65/EU (MiFID II) and the related Commission Delegated Regulation (EU) 2017/565;

(c) marketing of alternative investment funds within the meaning of Article 4(1)(x) of Directive 2011/61/EU (AIFMD) and Article 2 of Regulation (EU) 2019/1156 (CBDF);

(d) legal, tax, accounting or any other form of professional advice.

2.2 Any references to investment strategies, digital infrastructure, asset classes, historical or expected returns, or technological solutions are purely descriptive and illustrative in nature and do not in any way constitute a contractual proposal, a suitability indication or a merit assessment regarding the appropriateness of an investment.

2.3 This Website does not replace official offering documentation. Any investment decision relating to products that may be managed or promoted by the Group's entities must be based exclusively on the official documentation (prospectus, regulations, KID/KIID, subscription agreement) made available in the manner and form required by law.

3. Applicable Regulatory Framework

3.1 GREN Fund 1 SCSp – RAIF

GREN Fund 1 SCSp is structured as a reserved alternative investment fund (RAIF) under the Loi du 23 juillet 2016 relative aux fonds d'investissement alternatifs réservés. As a RAIF, the fund:

  • is not subject to direct supervision by the Commission de Surveillance du Secteur Financier (CSSF), but is subject to indirect oversight through the external alternative investment fund manager (AIFM) authorised under Directive 2011/61/EU (AIFMD);

  • is reserved exclusively for well-informed investors as defined in Article 2 of the Loi du 23 juillet 2016, namely institutional investors, professional investors and other investors who have confirmed their status in writing and who invest a minimum of EUR 125,000 (or equivalent amount);

  • may benefit from the European marketing passport for cross-border distribution under the AIFMD (Directive 2011/61/EU) through its AIFM, in accordance with the notification procedures set out in Articles 31 and 32 of that Directive and Regulation (EU) 2019/1156 (CBDF).

3.2 GREN Italia S.r.l. – Operational Scope

GREN Italia S.r.l. operates as a strategic advisory and operational support company. The company:

  • is not an authorised investment firm and is not registered in the Register of SIMs maintained by CONSOB;

  • does not provide investment services or activities within the meaning of Article 1(5) of Legislative Decree 58/1998 (TUF);

  • does not carry out investment advisory activities within the meaning of Article 1(5-septies) of the TUF;

  • does not engage in the promotion or placement of financial products or units of collective investment undertakings (UCITS/AIFs) to the public within the meaning of Articles 30 et seq. of the TUF;

  • is not subject to the supervision of the Bank of Italy or CONSOB in relation to investment services.

3.3 Non-Marketing Clause

This Website does not constitute marketing of alternative investment funds within the meaning of Article 4(1)(x) of Directive 2011/61/EU (AIFMD), as it does not contain a direct or indirect offer or placement of units or shares of an alternative investment fund to investors domiciled or having their registered office in the European Union, nor does it qualify as a pre-marketing communication within the meaning of Article 30a of that Directive, as introduced by Directive (EU) 2019/1160.

4. Geographic and Subjective Access Restrictions

4.1 This Website is intended exclusively for professional investors and qualified institutional counterparties, as defined by Directive 2014/65/EU (MiFID II, Annex II) and the respective national implementing legislation.

4.2 The Website is not intended for, and must not be accessed by, retail investors or persons resident or domiciled in jurisdictions where access to or use of the Website would violate local laws or regulations, including, without limitation, the United States of America (under the Securities Act of 1933 and the Investment Company Act of 1940).

4.3 GREN reserves the right to restrict or prevent access to the Website from certain jurisdictions, where required by applicable law or deemed appropriate to safeguard the Group's compliance.

5. Limitation of Liability and Absence of Warranties

5.1 The Website and its contents are provided on an "as is" and "as available" basis, without any warranty, express or implied, including, without limitation, warranties of completeness, accuracy, timeliness, fitness for a particular purpose, merchantability or non-infringement of third-party rights.

5.2 To the fullest extent permitted by applicable law, GREN, its subsidiaries, directors, officers, employees, agents, advisors and service providers disclaim all liability for:

(a) errors, inaccuracies, omissions or delays in updating the content of the Website;

(b) interruptions, malfunctions, cyber-attacks or temporary or permanent unavailability of the Website;

(c) any damage, whether direct or indirect, incidental or consequential, including loss of profits, data, goodwill or opportunity, arising from the use of or inability to use the Website;

(d) investment decisions or any other decisions taken on the basis of information published on the Website.

5.3 Use of the Website is at the user's sole risk. The user acknowledges that the information contained on the Website does not constitute a substitute for independent professional advice and that the user is required to carry out their own independent assessments and to consult their own legal, tax and financial advisors before making any decision.

6. Forward-Looking Statements

The Website may contain forward-looking statements relating to future events, objectives, strategies or results. Such statements, identifiable by the use of terms such as "expects", "estimates", "intends", "targets", "potential" and similar expressions, are by their nature subject to risks, uncertainties and factors beyond the control of GREN. Actual results may differ materially from those expressed or implied in the forward-looking statements. GREN assumes no obligation to update or revise such statements in light of new information, future events or any other circumstances.

7. Investment Risk Warnings

7.1 Investment in alternative investment funds, including Luxembourg-law RAIFs, involves significant risks, including:

  • Risk of capital loss: the value of investments may decrease and the investor may not recover the amount originally invested.

  • Illiquidity risk: units of alternative funds may be subject to lock-up periods, redemption restrictions and the absence of a liquid secondary market.

  • Market and credit risk: fluctuations in financial markets, interest rates, exchange rates and the creditworthiness of issuers may adversely affect the value of investments.

  • Risk related to digital assets: investments in cryptocurrencies and blockchain-based assets are subject to extreme volatility, technological risk, regulatory risk and the potential total loss of capital, in accordance with Regulation (EU) 2023/1114 (MiCA) where applicable.

  • Regulatory risk: changes in applicable legislation may affect the structure, taxation and profitability of investments.

7.2 Past performance is not a reliable indicator of future results. Any illustrative returns or projections do not constitute a guarantee of performance and are presented for illustrative purposes only, in accordance with Regulation (EU) 1286/2014 (PRIIPs) and applicable ESMA guidelines.

8. Intellectual Property

All trademarks, logos, trade names, texts, graphics, images, layouts and multimedia content on the Website are the exclusive property of GREN or of third parties who have granted a licence for their use. They are protected under Luxembourg and European Union intellectual property legislation, including the Règlement grand-ducal du 24 mars 1989 and Directive (EU) 2019/790. The reproduction, distribution, modification, transmission or use in any form of the Website's content without the prior written consent of GREN is prohibited.

9. Links to Third-Party Websites

The Website may contain hyperlinks to websites operated by third parties. GREN exercises no control over the content, security policies or regulatory compliance of such websites and cannot be held liable for any damage or loss arising from their consultation. The inclusion of a link does not imply endorsement, recommendation or affiliation with the destination website. Users are encouraged to review the terms of use and privacy policies of third-party websites before proceeding.

10. Confidentiality and Personal Data Protection

10.1 Any personal data collected through the Website is processed in accordance with Regulation (EU) 2016/679 (GDPR), the Loi du 1er août 2018 portant organisation de la Commission nationale pour la protection des données (Luxembourg legislation implementing the GDPR) and Legislative Decree 196/2003 (Italian Privacy Code, as amended by Legislative Decree 101/2018). For full details, please refer to the Privacy Policy accessible from the Website.

10.2 The information contained on this Website may be of a confidential nature. Any reproduction, distribution or disclosure to third parties of the Website's content without prior written authorisation from GREN is prohibited.

11. Compliance with Local Laws

The user is solely responsible for verifying that access to and use of this Website complies with all applicable laws, regulations and provisions in their jurisdiction of residence or domicile, including restrictions relating to access to financial information, technological products or content subject to export controls.

12. Governing Law and Jurisdiction

12.1 This disclaimer and the use of the Website are governed by the laws of the Grand Duchy of Luxembourg, excluding conflict of laws rules.

12.2 Any dispute arising from the use of the Website or in connection with this disclaimer shall be subject to the exclusive jurisdiction of the Tribunal d'arrondissement de Luxembourg.

12.3 In relation to the activities carried out by GREN Italia S.r.l., the courts of Rome shall have jurisdiction, without prejudice to any mandatory provisions of law to the contrary.

13. Amendments to This Disclaimer

GREN reserves the right to amend, update or supplement this disclaimer at any time and without prior notice. Continued use of the Website following the publication of any amendments shall constitute acceptance of the updated terms. Users are encouraged to review this page periodically.

14. Contact

For legal, regulatory or compliance enquiries:

Legal Information

  • GREN Holding S.à.r.l. VAT Number: 20262404391 | RCS B304429 Parc d'Activités Capellen, L-8308 Capellen, Luxembourg JL Towers Mazaya Business Avenue BB2, Dubai UAE

  • GREN World Management S.à.r.l. VAT Number: 20262404634 | RCS B304466 Parc d'Activités Capellen, L-8308 Capellen, Luxembourg

  • GREN Fund 1 SCSp VAT Number: 20265802436 | RCS B304625 Parc d'Activités Capellen, L-8308 Capellen, Luxembourg

  • GREN Italia S.r.l. VAT Number: 18286421005 | REA: 1774515 Viale Luigi Schiavonetti, 270 Pal. E, 00173 Rome RM

info@grenfinance.com | legal@grenfinance.com

Gren Italia S.r.l. is not an investment firm and does not provide investment services under MiFID II. This website is intended exclusively for professional investors and institutional counterparties. The information contained on this website is for informational purposes only and does not constitute an offer or solicitation to invest. Any reference to investment funds is provided for informational purposes only and does not constitute marketing under Directive 2011/61/EU (AIFMD).

Key Regulatory References

This disclaimer takes into account, among others, the following regulatory provisions:

  • Loi du 10 août 1915 sur les sociétés commerciales, as amended (Luxembourg Companies Law)

  • Loi du 23 juillet 2016 relative aux fonds d'investissement alternatifs réservés (RAIF Law)

  • Directive 2011/61/EU (AIFMD – Alternative Investment Fund Managers Directive)

  • Directive (EU) 2019/1160 and Regulation (EU) 2019/1156 (CBDF – Cross-Border Distribution Framework)

  • Directive 2014/65/EU (MiFID II – Markets in Financial Instruments Directive)

  • Regulation (EU) 2017/1129 (Prospectus Regulation)

  • Regulation (EU) 1286/2014 (PRIIPs – Packaged Retail and Insurance-based Investment Products)

  • Regulation (EU) 2023/1114 (MiCA – Markets in Crypto-Assets)

  • Regulation (EU) 2016/679 (GDPR – General Data Protection Regulation)

  • Legislative Decree 58/1998 (TUF – Consolidated Law on Finance, Italy)

  • Legislative Decree 196/2003 as amended by Legislative Decree 101/2018 (Italian Privacy Code)