COMPLAINT HANDLING GUIDELINES

The Complaint procedure pertains to CSSF Regulation N° 16-07 substituting the CSSF Regulation 13-02 (the “Regulation”) relating to the out-of-court complaint resolution was published by the Commission de Surveillance du Secteur Financier (“CSSF”) in November 2016.

The Regulation provides a framework to the processing of customer complaints (the “Complainant”).

The purpose of this document is to provide clear, precise and up-to-date information on the procedures implemented by Apex Fund Services (Malta) Ltd, Luxembourg Branch (hereafter “Apex Luxembourg”) in regards to how it manages the complaints process for any customer that wishes to make a complaint, or formally express dissatisfaction with the services provided by Apex Luxembourg.

Definitions:

A Shareholder Complaint is defined as being any complaint that may arise from an investor of an investment fund serviced by Apex Luxembourg.

A Client Complaint is defined as being any complaint received from an investment fund serviced by Apex Luxembourg, a promoter of any investment fund serviced by Apex Luxembourg, a management company of an investment fund serviced by Apex Luxembourg or a distributor of an investment fund serviced by Apex Luxembourg.

Making a complaint:

As a principle, all complaints must be formally presented in writing in order to be acknowledged, even if the complaint has already been expressed verbally to Apex Luxembourg.

For Shareholder or Client Complaints the written communication must be addressed to the Investor Services Team as well as to the Compliance Officer and sent to the following address:

Apex Fund Services (Malta) Ltd, Luxembourg Branch | Attn : Mr Michel Donckel | 2, boulevard de la Foire | L-1528 Luxembourg

Email address: ApexInvestorsServicesLU@apexfunds.lu

Handling your complaint:

Upon receipt of any complaint, Apex Luxembourg will record the relevant details, including the date and time of receipt. A written acknowledgement will be issued to the Complainant within 5 Business Days unless the complaint has been fully resolved within the intervening period.

The acknowledgment letter will also include the name and contact details of the person in charge of the complaint handling process and Apex Luxembourg complaint handling procedure.

In accordance with the CSSF Regulation 16-07, Apex Luxembourg will provide the Complainant with a written explanation of the outcome of the investigation and any actions taken to solve the complaint. This will be issued no later than one month after date of receipt of the formal written complaint.

Other Circumstances:

In instances where an answer cannot be provided within the above stated timescale, Apex Luxembourg will inform the Complainant of the causes of the delay and indicate the date at which a response is likely to be provided.

Should a Complainant remain unsatisfied with the final complaint response, they will be provided with details of how to contact the CSSF for out-of-court resolution. Should the Complainant not receive a response within one month they may contact the CSSF directly.

Complaints may be forwarded to the CSSF utilising the form at the following link: http://www.cssf.lu/en/consumer/complaints/

CSSF Out-of-court resolution of complaints:

If the complaint handling by Apex Luxembourg does not result in a satisfactory answer for the Complainant, Apex Luxembourg will inform its customers of the existence of the out-of-court dispute settlement procedure with the CSSF.

Complainants can refer their complaint to the CSSF in French, German, Luxembourgish or English:

    • By post at the following address : CSSF | 283, route d’Arlon | L-2991 Luxembourg | Grand Duchy of Luxembourg
    • By fax at the following number: (+352) 26 25 1 – 601
    • By filing the form available at the CSSF website: Click Here

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