Regulatory Disclaimer

1. Corporate status and development phase

Tungstenum, owned and controlled by Ziken Labs Società a Responsabilità Limitata Semplificata, is currently in an early stage of corporate and strategic development. At this time, Tungstenum does not operate as a licensed financial institution and does not hold authorisations from supervisory authorities such as CONSOB, ESMA or equivalent international regulators. Accordingly, Tungstenum is not authorised to provide investment services, financial advice, portfolio management, or to distribute financial instruments directly to the public or to professional clients.

2. Scope of activities

The activities carried out by Tungstenum are limited in scope and strictly focused on:

  • The research, design and development of investment strategies, with particular focus on smart-beta methodologies and index construction.
  • The production of research papers, market insights and analytical tools intended for companies, institutional actors and professional service providers.
  • The collaboration with licensed partners who may evaluate, adapt, or integrate Tungstenum’s research outputs into regulated financial products or platforms.

Tungstenum does not accept deposits, does not manage client funds, and does not solicit or distribute financial products to retail or professional investors. Any reference to “strategies” or “indices” within Tungstenum materials must be understood as conceptual and research-based outputs, and not as directly investable products.

3. Licensing and regulatory status

At present, Tungstenum has no financial licenses in any jurisdiction. Any future intention to obtain such licenses will be clearly communicated, and only once full regulatory approval has been granted. Until then, Tungstenum operates exclusively in the domain of research, strategy development, and institutional knowledge-sharing.

In agreement with applicable laws and regulations, during this development phase Tungstenum may explore opportunities to create and distribute research-based financial products through third-party licensed platforms, which themselves bear full regulatory responsibility for compliance, investor protection, and product distribution.

4. Future outlook

In line with its long-term vision, Tungstenum may, in the future, support the launch of Exchange-Traded Funds (ETFs) or other regulated investment vehicles, potentially making its strategies accessible to the broader investing public. Such developments will be contingent upon:

  • The establishment of partnerships with authorised financial institutions.
  • The acquisition of relevant licenses and approvals from regulatory bodies.
  • Full compliance with applicable laws and investor protection frameworks.

Until such a stage is reached, Tungstenum’s activities shall remain confined to the research and advisory layer, providing non-binding intellectual capital and strategic models to entities that themselves bear responsibility for regulatory compliance and product distribution.

5. No offer, no solicitation

Nothing contained in Tungstenum’s communications, documents, website, or research outputs shall be construed as:

  • An offer to sell or a solicitation to buy any financial instrument.
  • A recommendation or personalised financial advice.
  • An invitation to participate in any investment product.

All content is intended solely for informational and educational purposes, aimed at corporate partners, industry peers, and professional stakeholders.

6. Limitation of liability

While Tungstenum exercises diligence in the preparation of its research and strategic outputs, all information provided is made available “as is”, without warranty of any kind, either express or implied. Tungstenum makes no representations or guarantees as to the accuracy, completeness, reliability or timeliness of the content.

  • Tungstenum shall not be held liable for any direct, indirect, incidental, consequential, or special damages arising out of or in connection with the use of its materials.
  • Any decisions or actions taken by third parties on the basis of Tungstenum’s strategies, research, or analytical tools remain the sole responsibility of those parties.
  • Licensed institutions or platforms that may integrate Tungstenum’s intellectual property into regulated products bear full regulatory and fiduciary responsibility for such products.

7. Responsibility and transparency

Tungstenum and Ziken Labs are committed to conducting their activities with integrity, transparency and strict respect for regulatory boundaries. By clearly defining the nature of our work, we aim to avoid any misunderstanding regarding our role in the financial ecosystem.

8. Approval

This disclaimer has been reviewed and approved by the management of Ziken Labs, parent company of Tungstenum, and will be updated periodically to reflect changes in corporate status, licensing, or business activities.