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Complaints and Alternative Dispute Resolution

Complaint Management Policy

Purpose
C WorldWide Asset Management Fondsmæglerselskab A/S (CWW AM) always aims to act correctly, in good faith and in accordance with client fiduciary responsibilities. However, if a complaint is filed to CWW AM we find it essential to have effective and transparent complaint management policies and procedures in accordance with relevant legislation.

Who can complain?
All of CWW AM’s clients and potential clients can file a complaint. There is no fee for filing a complaint.

Where can complaints be filed?
Any complaints about CWW AM must be filed in writing to compliance@cworldwide.com or by letter to:

C WorldWide Asset Management Fondsmaeglerselskab A/S
Attn.: Compliance
Dampfaergevej 26
2100 Copenhagen
Denmark

Process for handling a complaint
The Compliance & Risk Management department “Compliance” acts as “Complaint Management Function” which implies that Compliance in CWW AM secures the process and investigation of the Complaint.

The Complaint Management Function will:

• Ensure that an acknowledgement of the complaint is sent to the client or potential client without undue delay and within one week after the complaint has been received.
• Ensure that the complaint is investigated.
• Ensure that handling of the complaint is completed without undue delay and that the complainant is informed about CWW AM’s position on the complaint.
• Inform the complainant about their further options, e.g. possibility of alternative dispute resolution, as described below, or the complainant might be able to take civil action.

Unresolved disputes
Unsolved disputes with CWW AM regarding the purchase of goods and services may (on the conditions described further below) be submitted to the following alternative dispute resolution board (ADR):

Ankenævnet for Fondsmæglerselskaber
C/O Det finansielle ankenævn
St. Kongensgade, 62, 2. Sal
DK-1264 Copenhagen K
Web: The Complaint Board of Danish Securities and Brokerings Companies

The ADR only accepts complaints from consumers and equal client relationships. The ADR does not accept complaints regarding services if the complaint concerns a transaction above DKK 500,000; or the market value of the client’s personal portfolio of securities exceeds DKK 5 million at the time of submission of the complaint. The ADR charges a fee for the dispute resolution.

Information to clients or potential clients
Information about this policy shall be sent to clients or potential clients on request or when acknowledging a complaint.

Information to relevant competent authorities
CWW AM shall provide information on complaints and complaints handling to the relevant competent authorities and where applicable under national law, to an alternative dispute resolution (ADR) entity.

Analysis of received complaints
Compliance will analyse received complaints and complaints handling data to ensure that any risks or issues are identified or addressed.

Reporting
If complaints have been received it shall be reported to management and Board of Directors in the Compliance & Operational Risk reports. Serious complaints of substance will be elaborated. Serious complaints will be reported to senior management as soon as possible.

Records
CWW AM will keep records of the complaints received and the measures taken for their resolution.