Client Complaint Rights

In the context of the relationships established between investors or potential investors, complaints may arise regarding any aspects related to the activities of the Management Entity, and their receipt and assessment are always guaranteed in accordance with this policy.

Complaints submitted to the Management Entity, whether in the context of relationships directly established with investors or arising from relationships with the depositary, must be made in writing and will be reviewed and decided upon within a maximum period of fifteen (15) business days.

This period may be extended where necessary to obtain additional elements essential for the decision, namely consultation with market entities, including supervisory authorities, in which case the complainant shall be duly informed.

1.1.        Submission, Receipt, and Processing of Complaints

Investors of the Management Entity may submit complaints to the Management Entity regarding their investor interests under the following terms:

• Complaints to be submitted by investors of the Management Entity must be addressed to Compliance, in writing and in Portuguese or English, exclusively via email to the Management Entity’s designated address for this purpose, identifying the subject as “Complaint”, without prejudice to the possibility of physically delivering documents via postal mail or at the company’s premises.
• The review and decision of complaints are free of charge.

The complaint must include, at a minimum:

1. A summary statement by the complainant of the interests or rights in question justifying the complaint, with identification of the relevant acts, operations, contacts, as well as the employee(s) involved.
2. Where applicable, the remedy sought by the complainant.

The complaint must be received by Compliance, who shall acknowledge receipt to the complainant and inform them of the essential elements regarding the review and decision procedures, indicating the maximum estimated timeframe.

Employees of the Management Entity are prohibited from directly receiving investor complaints by any means; if contacted by a complainant, they must inform the interested party of the existence of the applicable procedure.

For this purpose, and immediately upon receipt of the complaint, the Compliance Officer shall identify the author of the act being complained of and inform the Chairman of the Board of Directors of the Management Entity.

The employee of the Management Entity who carried out the act subject to the complaint must refrain from any acts or measures that may obstruct the submission of the complaint.

Upon receipt of the complaint, Compliance shall process it with the elements deemed necessary for its review and decision, hearing the employee(s) involved and the person responsible for the relevant area or functions, and shall submit the duly substantiated file, with all relevant elements, to the Board of Directors, which is responsible for the decision, including a critical analysis and a proposed resolution.

Investors of the Management Entity may alternatively submit the complaint directly to the CMVM, preferably by completing the online complaint form, after first presenting the matter to the Management Entity, which has 15 business days to respond.

After this period, investors may submit the complaint directly to the CMVM, attaching the complaint initially submitted to the Management Entity (with proof of submission date) and, if applicable, the response received. Complaints may also be sent to the CMVM by email (cmvm@cmvm.pt) or by letter (Rua Laura Alves, no. 4, 1050-138 Lisbon), including, as far as possible, all elements of the online complaint form.

1.2.       Review and Decision

The complaint must be reviewed and decided by the Board of Directors within a maximum of fifteen (15) business days.

If it is not possible to comply with this period, the complainant shall be informed of this fact and of the estimated timeframe for the decision.

The decision must include, at a minimum:

1. Clear identification of the specific issue and of the documents and elements reviewed;
2. The reasoning for granting or rejecting the complainant’s request;

iii.        Indication to the complainant of the possibility of submitting a complaint regarding the decision to the CMVM via the email address cmvm@cmvm.pt.

The decision shall be communicated to the complainant within a maximum of five (5) business days from its issuance by the Board of Directors and may be consulted, free of charge, at the headquarters of the Management Entity.

1.3.       Record and Archive

Complaints are recorded and kept for a period of five years, including in the database the following elements:

1. The complaint itself;
2. Identification of the complainant;

iii.        Date of receipt of the complaint;

1. Identification of the financial intermediation activity involved – e.g., subscription order, redemption transaction, income payment;
2. Date of the events in question;
3. Identification of the employee who carried out the act being complained of;

vii.        Review carried out by the Management Entity;

viii.       Measures eventually taken;

1. Date of communication to the complainant.

The archive includes the documents, copies, or digitized versions of relevant documents.

1.4.       Complaints Book

The Management Entity has available at its premises a Complaints Book, in accordance with the provisions of Decree-Law No. 156/2005 of 15 September.

Additionally, the Management Entity:

1. Maintains an organized archive of closed Complaints Books for a minimum of 3 years;
2. If a complaint is submitted in the Complaints Book, forwards the original complaint and the response to the client, to the CMVM, within 15 business days after the complaint is made;

iii.        Cooperates with the CMVM, ensuring access to information, documents, or records requested by it; and

     3.  Reports the loss or misplacement of the Complaints Book to the CMVM within 5 business days.

Investors and counterparties of the Management Entity may also submit complaints through the website: https://www.livroreclamacoes.pt/inicio. Complaints submitted via the Electronic Complaints Book are automatically forwarded to the Management Entity and the competent authority. In the case of financial intermediation services and activities related to financial instruments or equivalent, the competent authority is the CMVM.

1.5.       Reporting to CMVM of Complaints by Non-Professional Investors

The Management Entity submits to the CMVM, on a semi-annual basis, by the last day of the month following the end of the semester to which the information relates, information on complaints submitted by non-professional investors, ongoing and concluded, concerning the management of CIUs, in accordance with CMVM Regulation No. 7/2020, covering the period between the first and the last day of each calendar semester.

(For more information, please refer to the Portuguese version of this document.)