Summary of Investor Rights

Cordiant Luxembourg S.A. (hereafter referred to as “AIFM”) is a Luxembourg based Alternative Investment Fund Manager, authorised under the Law of 12 July 2013 on alternative investment fund managers.

This document is intended as a summary of your key Investors Rights in relation to Fund(s) managed by the AIFM, in accordance with Article 4 of the Regulation (EU) 2019/1156 on facilitating cross-border distribution of collective investment undertakings (“CBDF”). This document is not intended to be and should not be considered as an exhaustive list of all rights which investors may be entitled to in relation to the Fund(s).

1. Entitlement to make an individual complaint

a. Liaising with Cordiant Luxembourg S.A.

As an investor in a Fund(s) managed by the AIFM, you are entitled to make a complaint free of charge in your language. Any such complaint must be handled by the AIFM promptly and effectively.

You will be able to provide us with your detailed complaint either:

• in writing to: Cordiant Luxembourg S.A. 3, Wirwelt L-9970 Leithum, Luxembourg.
• by email to: complaint@cordiant.lu
• Through our website at: https://www.cordiantcap.com/contact-us/

Cordiant Luxembourg S.A. will handle complaints promptly and effectively in accordance with applicable regulatory requirements.

b. Out-of-court complaint resolution with the CSSF

If after discussing with us, you still wish to proceed with an out of court complaint resolution, you may file your complaint with the CSSF only when it relates to a Luxembourg supervised entity (meaning Cordiant Luxembourg S.A. authorised as an AIFM in Luxembourg).

c. Out-of-court complaint resolution related to a financial service provider in your country

If your complaint relates to a financial service provider in your country of residence, such as a bank, an insurance company, an investment firm (e.g. a portfolio manager, an investment advisor …), you must first address your complaint to this financial service provider.

If after discussing with this entity, you still wish to proceed with an out of court complaint resolution, you may file a complaint directly to the appropriate Ombudsman of your country for the specific type of intermediary.

Please find the main Ombudsman (or equivalent) in your country (not an exhaustive list). Please verify that the entity for which you have a complaint is a member of this Ombudsman.

d. Liaising with the FIN-NET

For cross-border complaints relating to a financial service provider (e.g., a bank, insurance company, investment firm) located in another EU/EEA country than yours, you may either:

• Contact the relevant local Ombudsman in that country (please refer to the table above) or
• Submit your complaint via FIN-NET, the EU network of national organisations that resolve consumer financial disputes out-of-court under the principles set out in the Directive 2013/11/EU on alternative dispute resolution (ADR).

For more details, please visit the FIN-NET website: https://finance.ec.europa.eu/consumer-finance-and-payments/retail-financial-services/financial-dispute-resolution-network-fin-net/about-fin-net_en

The FIN-NET form for cross-border complaints are available in the following languages: English, Czech, Danish, Dutch, Finnish, French, German, Italian, Polish, Spanish and Swedish at https://finance.ec.europa.eu/consumer-finance-and-payments/retail-financial-services/financial-dispute-resolution-network-fin-net/make-complaint-about-financial-service-provider-another-eea-country_en

The FIN-NET member will confirm whether they are able to handle your complaint or may refer you to another competent body. You may be asked for additional information to assess your case properly. Most FIN-NET members provide service free of charge or at a low cost and usually reach an outcome within 90 days.

2. Collective redress mechanism

a. For collective litigation – at EU level

The applicable rules for collective action for litigation at European level are detailed in the Directive (EU) 2020/1828 (dated 25 November 2020).

Please find a short summary of your rights foreseen:

• Domestic or cross border representative actions to defend the collective interests of consumer in cases of mass harm can be taken by non-profit based qualified entities (e.g. consumer organisations or independent public bodies);
• Qualified entities can seek at least 2 types of measures for investor protection: injunctive and redress;
• Penalties under the form of fines, for non-compliance with decisions issued within the representative action will be set out by each Member State;
• Depending on the circumstances of the cases (e.g. interim or definitive measures to stop and prohibit a trader’s practice or to eliminate the continuing effects of the infringement), the qualified entities may be able to bring representative actions seeking different types of measures as appropriate.

b. For collective litigation – at EU level

A collective redress mechanism, as required under Directive (EU) 2020/1828 on representative actions for the protection of the collective interests of consumers, are available at national level for the following countries: Belgium, Czechia, Denmark, Ireland, Spain, France, Italy, Luxembourg, Netherlands, Poland and Sweden.

The complete and updated list of countries and respective national measures transposing Directive (EU) 2020/1828 can be consulted on EUR-LEX at the following link: https://eur-lex.europa.eu/legal-content/EN/NIM/?uri=CELEX:32020L1828.

Important Information

It should be noted that this summary addresses rights conferred on Investors under the applicable legislation governing the operation and marketing of the Fund(s) in which you are invested.

The ability to exercise certain rights may depend on how you have invested in the Fund(s) and whether you are an Investor on the Fund(s) Investor register or whether you have acquired your interests through an intermediary. This may affect your ability to exercise some of the rights set out above. Where interests are held through an intermediary, some rights may need to be exercised through that intermediary in accordance with applicable law and the Fund’s constitutive documentation.

You may also be afforded rights under other legislation or regulatory frameworks which are not addressed above.