Internal code of conduct

Bewater Asset Management S.G.E.I.C. de tipo cerrado (Closed-End Collective Investment Undertaking Management Firm) has a code of conduct applicable to its entire staff, based on a series of points that must govern the activities of all employees, managers and members of its governing body.

Check our Internal Code of Conduct (ICC) here.

Client services and its regulations

We make the Client Services Department available for our clients, through which they can channel complaints or claims:

  • By letter: Client Services Department. Bewater Asset Management SGEIC de tipo cerrado SA. Calle Serrano 213, Piso 1, A4, 28016 Madrid
  • Or by e-mail:

The procedure will start with the submission of a document stating:

  • Name, surname and address of the interested party and, if applicable, of the person representing them, duly accredited; Tax ID number, whether natural or legal person.
  • The reason for the complaint or claim, specifying the issues on which a ruling is requested.
  • Office, department or service where the facts that are the object of the complaint or claim occurred.
  • That the claimant is not aware of any administrative, arbitral or judicial proceedings being conducted on the subject matter of the complaint or claim.
  • Any other circumstances you deem appropriate.
  • Place, date and signature.
  • The documentary evidence in your possession on which your complaint or claim is based.

For further details, please refer to the Client Services Operating Regulations.

Prevention of money-laundering and terrorism financing

The purpose of preventing money-laundering and terrorism financing is to forestall and deter the use of the financial system and other economic sectors to launder the proceeds of any kind of involvement in the commission of a crime.

As a regulated entity, Bewater Funds complies with regulations in force, establishing prevention policies and programmes, appropriate internal control bodies, procedures manual, employee training programmes, systems and procedures for the detection of suspicious operations and analysis of operations subject to special examination and procedures for reporting Money Laundering and Monetary Offences (SEPBLAC).

In Spain, Law 10/2010 of 28 April on the prevention of money-laundering and the blocking of terrorism financing aims to protect the integrity of the financial system and other economic sectors by establishing prevention obligations for regulated entities. This Law transposes Directive 2005/60/EC of the European Parliament and of the Council of 26 October 2005.

Law 10/2010 of 28 April has had eight articles amended by Law 19/2013 of 9 December on transparency, access to public information and good governance, in its Sixth Final Provision.

The approval of Royal Decree 304/2014, of 5 May, approving the Regulations of Law 10/2010, of 28 April, is the culmination of the new risk-oriented approach to preventive regulations in Spain, also incorporating the main developments in international regulations arising from the approval of the new Recommendations from the Financial Action Task Force (FATF).

Having an effective system for the prevention of money-laundering and the financing of terrorism has been a primary objective, and that is why we have defined a framework based on the following pillars:

  • A 'Know Your Client' policy, as well as a thorough knowledge of the purpose or nature of the business relationship means having a comprehensive knowledge of the clients, and more specifically "knowing the professional or business activity" of the clients and the purpose of their business relationship.
  • Client acceptance policy: Involves knowing "which people cannot be clients of Indexa Capital" and which can; and among the persons accepted as clients, it implies knowing the associated money-laundering risk level.
  • Formal client identification policy: Involves knowing "who" the clients are, and for this purpose they must be asked for the appropriate identification documents.
  • Actual holder identification policy: Involves knowing whether clients are acting on their own behalf or on behalf of third parties, and in the latter case, it implies knowing on whose behalf they are acting. In the case of legal persons, it implies knowing their ownership or control structure.

This framework for action has been designed in accordance with the legal requirements of current legislation and with the approval and involvement of the Board of Directors.

Being a financial entity, we are required to have copies of certain client documents in order to verify their identity, business or professional activity, the source of their funds and the purpose of the business relationship. Failure to comply with this legal requirement may require us to cancel the clients' accounts should they not provide such documentation.

Governance structures procedure

There is a set of rules and procedures applicable to all the company's employees, executives and directors, geared towards protecting the company's solvency and establishing guidelines for correct, consistent behaviour that ensure the quality of the activities and operations carried out.

Check out our governance structures procedure now.