Complaints Handling Procedure

1. How to file a complaint

You may file a complaint free of charge, in writing, clearly describing the subject of the complaint and the outcome sought. Complaints are handled under a documented procedure supervised by a member of authorised management.

2. Available channels

Complaints may be sent by e-mail to complaints@asteo.eu or by post to: Complaints Officer, ASTEO LUXEMBOURG S.A., 120 Boulevard de la Pétrusse, L-2330 Luxembourg, Grand Duchy of Luxembourg.

3. Information to include

To allow effective handling, a complaint should state:

• your name and account or relationship reference;
• a description of the facts and circumstances;
• relevant documentation or correspondence;
• the outcome or remedy requested;
• contact details for the reply.

4. Acknowledgement of receipt

We acknowledge receipt of the complaint in writing within ten business days, unless a final response has already been provided within that period.

5. Internal review

The complaint is examined objectively, impartially and independently of the functions involved in its subject matter. We may request further information where needed for a full assessment.

6. Response times

We provide a reasoned response as soon as possible and in any event within one month of receipt. Where that deadline cannot be met, we inform you of the reasons for the delay and of the expected response date.

7. Final response

The final response sets out the outcome of the review and, where the complaint is upheld, any measures taken. Where the complaint is rejected, the reasons are explained.

8. Escalation

If you consider the response unsatisfactory, or in the absence of a response within one month, you may refer the matter to the Commission de Surveillance du Secteur Financier (CSSF) under CSSF Regulation No 16-07, within one year of filing the complaint with the firm: CSSF, 283 route d'Arlon, L-1150 Luxembourg — reclamation@cssf.lu.

9. External bodies for Italian clients

Retail clients resident in Italy may, where applicable, refer the matter to the competent alternative dispute resolution scheme. [APPLICABLE ITALIAN ADR BODY TO BE CONFIRMED]

10. Record keeping

We retain documentation relating to complaints and responses for the period required by applicable law and report to the competent authorities where required.