Purpose and scope

The purpose of the complaints handling policy (the Policy) is to describe how FundRock Distribution S.A. ("FRD") intends to:

• establish an efficient and transparent framework for handling a complaint and
• ensuring that a complaint is treated fairly and promptly
  meet its regulatory obligations
• ensure that systematic and recurring matters are identified and rectified
• improve the internal service delivery function

The scope of this Policy requires all FRD employees (FRD Employees) to:

• understand the definition of a complaint and a complainant
• be aware of what to do if they receive a complaint
• understand their role in respect of complaint handling
• co-operate with staff handling a complaint and treat complaints as a priority.

FRD Employees are responsible for adhering to the requirements of this Policy and related Complaint Resolution Procedure (the Procedure). FRD Employees should consult their Supervisor/Line Manager and or the Compliance if they are uncertain with respect to the Policy.

Receipt of a complaint by a complainant

For the purpose of this Policy and related Procedure, a complaint is to be considered as a filed statement in one of the official languages of Luxembourg to recognize a right or to redress a harm addressed to FRD by a natural or legal person relating to the provision of the services rendered by FRD.

The complainant is defined as a natural or legal person who is presumed to be eligible to have a complaint considered by FRD and who has already lodged a complaint (the Complainant). The Complainant can address its complaint directly to FRD or indirectly through an FRD delegated party (Central Administrator and Sub-distributor).

FRD Employees shall inform the Complainant of the name and contact details of the CSSF approved person in charge of handling complaints on behalf of FRD (the Complaints Handling Officer) upon receipt of a complaint.

The Complaints Handling Officer will acknowledge receipt of a complaint in writing, within 48h hours of receipt and in any event not exceeding 10 business days of receipt.

Upon receipt of the complaint, the Complaints Handling Officer shall inform the persons responsible at FRD management level and the Compliance Department and distributes the complaint to the relevant FRD department or to the relevant delegate swiftly.

The Complaints Handling Officer will thoroughly investigate the complaint to ascertain all the relevant facts and endeavor to resolve the complaint as fairly as possible and at the earliest opportunity.

Within one month of receiving the complaint, the Complaints Handling Officer will report in writing to the Complainant on the outcome of the investigation, and, where the complaint is upheld, propose a fair resolution.

If a complaint is particularly complex, it may take longer to investigate or to reach a final decision; in which case, the Complaints Handling Officer still contacts the Complainant in due time after receiving the complaint and will inform when FRD expect to be able to provide a response. The contact details to be provided to a Complainant are:

Via email to frd_complaints@fundrock.com
Via post to FundRock Distribution S.A., Attention: Complaints Handling, 9A Rue Gabriel Lippmann, Munsbach, L-5365, Luxembourg.

These details are made publically available in the relevant Fund Prospectus.

Please refer to the Complaints Procedure for details regarding the Complaints Handling Officer as well as the senior person responsible for complaints at FRD management level (the Conducting Officer).

Admissibility of a complaint

To be considered as admissible, any complaint addressed directly to FRD should be in writing (regular mail or email), even though the Complainant initially raises the complaint verbally. FRD Employees must request that the Complainant submit a formal written complaint in line with the Procedure, addressed directly to the Complaints Handling Officer at the above contact details.

A complaint is not to be confused with a query which is a request for information or a question that can be either handled at the first point of contact or requires further investigation but it does not denote real dissatisfaction to recognize a right or to redress a harm related to a financial product or service rendered by FRD.

Technical aspects to be respected

The Complaints Handling Officer should provide a written response to the Complainant either via a letter or by electronic mail regarding the resolution of a complaint in line with the deadline set above.

The response should contain:

• the outcome of the investigation
• a clear explanation as to why the complaint has been upheld or rejected
• details of any redress or compensation offered where applicable
• details of measures that will be considered in order to prevent further similar complaints

Where the Complainant did not obtain an answer or a satisfactory answer at the level at which s/he submitted his/her complaint in the first instance, the internal procedure shall give him/her the opportunity to raise the complaint up to the level of the Conducting Officer. In this respect, the Complaints Handling Officer shall provide the professional contact details of the Conducting Officer.

Where the complaint handling at the Conducting Officers did not result in a satisfactory answer for the Complainant, the Complaints Handling Officer and or the Conducting Officer shall provide the Complainant with a full explanation of FRD as regards the complaint and inform the Complainant in writing of the existence of the out-of-court complaint resolution procedure at the CSSF and send a copy of this regulation or the reference to the CSSF website, as well as the different means to contact the CSSF to file a request.

FRD’S duties and responsibilities

Organisational arrangements

Although FRD Employees must be aware of the Policy and Procedure, the set of tasks and responsibilities are assigned to and shared between:

• senior Management
• a Complaints Handling Officer
• Compliance Department
• Internal Audit

Key requirements and key tasks

Senior Management:

• is in charge of the respect of the Policy and Procedure
• shall review the annual complaint handling report for the CSSF regarding the activity on complaints handling
• Present quarterly complaints report to the Board of Directors.

Complaints Handling Officer:

• is responsible for the setup of the written FRD internal complaint resolution procedure including the maintenance of a complaints registry in order to have a complete record of all complaints at all times
• is in charge of the day-to-day management of the complaint handling process and notably the proper follow up of the complaints
• will prepare and file the annual complaint handling report to be provided to the CSSF
• will prepare monthly report to the Management Committee and to the Conducting Officers for the executive committee.

Compliance Officer:

• draft and reviews on an annual basis the adequacy of the complaint policy with relevant laws and regulations
  shall inform the relevant staff of any change in the existing regulation
• shall ensure that compliance with the procedure is checked as part of the Compliance Monitoring Plan
• shall ensure, in collaboration with the DPO that the complainant’s personal data are processed in accordance with the applicable legal provisions

Internal Audit:

• Must review as part of their audit plan the proper application of the policy / procedure and the adequacy of the policy / procedure with relevant laws and regulations.