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Complaints Handling Policy

1. Introduction

Cedrus Atlantica - Sociedade de Capital de Risco, S.A. ("Cedrus" or "Company") as a management company is obliged to clarify and analyze the questions and complaints of the participants of its collective investment undertakings ("CIUs").

The Company adopts this policy, which contains adequate, effective and transparent procedures for the appropriate and prompt handling of complaints it may receive from its participants.

2. Scope

This policy applies to all employees of the Company, including members of the Board of Directors.

3. Guiding Principles

In the context of the treatment of complaints from its participants, the Company must guide its actions to fully comply with a set of guiding principles, specifically:

  • Principle of equality: The Firm, in all contacts it maintains with the participants, guarantees equal treatment, refraining from practicing any acts or conducts that promote the differential treatment of situations that appear to be similar, and must always avoid any discriminatory behavior.
  • Principle of transparency: The Firm promotes transparent action towards its participants, namely by providing all the necessary information in a rigorous, clear, simple, reliable and objective manner, avoiding misinterpretaFons that may frustrate their expectations.
  • Principle of adequacy: The Society always acts diligently, carefully and competently, seeking to offer a complete response that is appropriate to the needs of each of its participants.
  • Principle of efficiency: The Company seeks to perform its functions in the most efficient way, namely, in the treatment of any questions addressed to it, and must always analyze the specific situation of the participant and obtain as much information as possible about him/her and/or his/her investments, to ensure the best possible treatment of the issue in question.
  • Principle of gratuity: The Company always ensures the existence of free channels so that its parFcipants, at any Fme, can contact it and submit complaints without any associated costs.
  • Principle of speed: The Company acts with the utmost commitment, effort and speed in the treatment of complaints and/or other questions addressed to it and must respond and/or present a solution to the problems in the shortest possible time.

4. Confidentiality and secrecy

The Company guarantees that all Employees involved in the handling of complaints are aware of this policy and that they are aware of the need to comply with the duty of secrecy and confidentiality imposed on them.

5. Competence to receive and handle complaints

The reception and handling of complaints is the direct responsibility of the Compliance officer, who is also responsible for preparing a proposal for a response to the complainant, to be approved by the Board of Directors, as well as archiving the entire process.

6. Procedure for handling Complaints

The Management Company has the necessary, adequate and sufficient means for the adequate and prompt handling of complaints submitted to it by its participants, also ensuring the existence of a detailed procedure for the reception, treatment and resolution of complaints received, described in the following points.

6.1. Receipt of complaints

The Firm provides on its website a set of means through which its retail investors can submit a claim, specifically:

At the marketing stage of its UCITS, the Company informs its investors of the existence of:

  • Free channels for submitting any complaints and/or requests for information.
  • A complaint handling policy that may be made available to you at your request.

The management and treatment of complaint processes is ensured by the Compliance Officer, except in cases where the complaint concerns him/her, in which case it will be sent directly to the Board of Directors, which will carry out the respective analysis and follow-up of the process.

The receipt of any complaint through these means always leads to the creation of an internal process number and respective registration in an existing computer file for this purpose.

6.2. Prior completeness analysis

To ensure the competent and adequate handling of complaints, the Compliance Officer must ensure that the complaint sent contains the information necessary for its analysis, namely, verifying that it contains, at least, the following elements:

  • Complete identification of the participant.
  • Direct contacts of the participant.
  • Nature of the relationship underlying the complaint.
  • Date/period of occurrence.
  • Brief description of the factual situation.
  • Submission of the request/question you wish to be examined.
  • Employees involved (if applicable).
  • Third parties involved (if applicable).

In cases where the complaints submitted do not contain the information described above, the Compliance Officer must contact the investor to complete the data and/or iinformation, indicating the maximum period for this purpose, as well as a warning that non-compliance will lead to the filing of the process. Ager the deadline has passed without the investor having responded or completed the request, the Compliance Officer archives the process and informs the participant by email.

6.3. Analysis and handling of complaints

Once the completeness of the complaint is verified, the Compliance Officer prepares a written analysis, which includes:

  • A summary of the situation described.
  • The legal framework of the situation.
  • The verification or non-verification of the compliance of the reported situation with the applicable legal framework and with the policies and procedures adopted by the Company.
  • A proposal to resolve the situation.

At the end of its analysis, the Compliance Officer sends it for validation by the Board of Directors.

6.4. Preparation of final response to the complaint

Ager validation of the response proposal by the Board of Directors, the Compliance Officer prepares a response to the investor, which must contain the following elements:

  • Brief summary of the situation.
  • Legal framework (if applicable).
  • Key findings from internal analysis.
  • Indication of the resolution measures applied in the specific case.
  • Presentation of a solution, which must include legal or financial grounds (as the case may be).
  • Infication that, if you do not agree with the analysis and/or solution proposed, you may complain to the Portuguese Securities Market Commission.
  • Copy of all relevant documents.

The process is finalized with the submission of the final response to the investor.

6.5. Registration and archiving

As soon as the response is sent to the investor, the Compliance Officer ensures that all elements related to the complaint are properly filed in a digital folder created for this purpose, with all the relevant elements, thus closing the process.

7. Deadlines

As a rule, responses to complaints submitted by customers are sent within a maximum period of 10 (ten) working days, counted from the receipt of the same.

In cases of special complexity or in which it has been necessary to request additional elements from the investor, the Company must seek to complete the processes within a maximum period of 20 (twenty) business days.

Whenever it is not possible to comply with the above-mentioned deadlines, the Company must contact the investor, explaining the reason for the delay in sending the response.

8. Revision

This policy is reviewed annually or at shorter intervals whenever necessary.