Provision of Response

The Company must review and investigate the Client's Complaint and, within a maximum of 15 business days from the date of receipt, provide a detailed, reasoned, and documented written Response. In exceptional cases where circumstances beyond the Company's control delay the Response beyond 15 business days, the Responsible Person shall send an interim written notice to the Client, explaining the reason for the delay and indicating the anticipated date of the final Response. In any event, the Complaint must be fully addressed, and a Response provided to the Client no later than 35 business days from its receipt.

At any stage during the Complaint review, the Client retains the right to withdraw their claim and cancel the Complaint. If the Client chooses to do so, the Company will terminate its investigation.

The Responsible Person shall decide on the Response to the Complaint, including whether the Complaint will be upheld or dismissed, except when, upon investigation, the Complaint is found to meet any of the following criteria:

• involves a claim exceeding EUR 10 000 (ten thousand euros) or equivalent,

• contains allegations of fraud or gross negligence by the Company,

• poses a significant reputational risk to the Company, or

• alleges a breach of information security or privacy laws.

If one of the abovementioned criteria is met, the Responsible Person must notify the CEO and transfer all relevant materials and information regarding the Complaint. In such cases, the CEO will review the Complaint, prepare a written recommendation/ opinion and forward it to the Chief Compliance Officer who assesses the recommendation/ opinion along with all supporting documentation and takes a final decision.

Based on a comprehensive review of the Complaint’s circumstances and in line with applicable laws and this Policy, the Chief Compliance Officer shall make one of the following determinations:

• fully uphold the Complaint;

• partially uphold the Complaint;

• reject the Complaint.

If the Company decides to partially uphold or reject the Client’s Complaint:

• the Company’s response will provide a reasoned explanation based on applicable legal provisions, supported by relevant documentation (e.g., copies of contracts with the Client, documents received from the Client, etc.), as applicable (incl., information on other available remedies for the Client, such as the option to pursue court action in accordance with applicable laws);

• the response will inform the Client that, if dissatisfied with the Company’s decision, they may escalate the Complaint to the Supervisory authority or appeal directly to the court.

The response person will additionally advise the Client that any Complaint submitted to the Supervisory authority must be filed within one year of submitting the Complaint to the Company. The Complaint may be submitted to the Supervisory authority via:

Ministry of Interior of the SR

Pribinova 2, 812 72 Bratislava

[phone]

[phone]

[email protected]

The Company's decision will be submitted to the Client in writing and in the language in which the Complaint was submitted by the Client. The Company shall register each Response to the Complaint in the Complaints Register.

The original of Company's Response to the Complaint (including any attachments) shall be delivered to the Client in the same manner as the Complaint was submitted unless otherwise requested by the Client in the Complaint.