COMPLAINTS HANDLING

YT Investor Services seeks to maintain its good reputation and is also committed to maintaining its responsiveness toward its clients and the investors of the funds administered. ​The purpose of the Complaints Handling Policy is to ensure that complaints are handled in a manner which is fair, objective and truth oriented.

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DEFINITION OF A COMPLAINT

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​A client complaint is an oral, written or electronic communication from a customer of YT Investor Services or an investor, former investor, or actively solicited potential investor of fund administered by YT Investor Services that expresses a grievance of dissatisfaction with a product or service provided or offered.

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GUIDING PRINCIPLES OF EFFECTIVE COMPLAINTS HANDLING

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• Disclosure

The Complaints Handling Policy is available on YT Investor Services's website and also internally.​

• Responsiveness

All complaints shall be treated in a careful and prompt manner. YT Investor Services endeavors to resolve complaints within one (1) month after receiving the complaint.

• Easiness​

Complaints can be filed in the official language or one of the official languages of the complainant’s member state. The complaint handling is free of charge.  Each complainant is informed of the name and the contact details of the person in charge of his/her file and therefore may correspond directly with this person. YT Investor Services endeavors to communicate in a plain and easily comprehensible language.

• Objectivity​

Each complaint is addressed in an equitable, objective and unbiased manner. YT Investor Services seeks to search the truth.

• Confidentiality​

​YT Investor Services shall ensure that the processing of personal data complies with the applicable rules on the personal data protection.​​

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COMPLAINT HANDLING RESPONSIBLE

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YT Investor Services has appointed Mr. Alessandro DI ROBERTO, as “responsible of the collection, centralization and treatment of all complaints filed by its clients and investors”(Complaints Officer). ​Mr. DI ROBERTO will also be responsible for the implementation and the efficient operation of a structure as well as the internal procedure for complaint handling (the Complaints Officer). Such appointment, as any further change, is and will be duly communicated to the CSSF.​​

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TERMS OF DEPOSIT AND CONTENT OF THE REQUEST

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The complaint shall be addressed in writing by letter to:

​YT Investor Services S.A.

Att: Mr. Alessandro DI ROBERTO

9-11, Grand-Rue

L-1661 Luxembourg

Fax: +352 28 26 41 99

E-mail: complaints@yt-is.com

​Clients will also have the possibility to lodge their complaints directly with financial intermediaries, such as local distributors and/or paying agent of the relevant country of distribution, who will escalate the complaint to YT Investor Services. ​The following information shall be provided to ensure a prompt handling of the complaint:

• ​Identity and contact details of the complainant

• Reason of the complaint and

• Where necessary, copies of any documentation supporting the complaint

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COMPLAINTS HANDLING PROCEDURE

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The complaint’s Complaints Handling Procedure is separated in several phases:

• Complaint reception

• Acknowledgement of receipt

• Registration and information

• Investigation

• Answer to the complainant

• Escalation of the complaint at a second level

• Existence of the out-of-court complaint resolution at the CSSF

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COMPLAINT RECEPTION​​

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The Complaints Officer is in charge of the collection and management of the complaints handling. ​Therefore all written complaints, which are not directly address to the Complaints Officer but generally addressed to YT Investor Services or through an intermediary shall immediately be transmitted to the Complaints Officer who will handle the complaint.

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ACKNOWLEDGEMENT OF RECEIPT

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​​The Complaints Officer shall send an acknowledgment of receipt within ten (10) days after the receipt of the complaint unless the answer itself is provided to the complainant within this period. ​The acknowledgment of receipt should inform the complainant of :

• The name and contact detail of the person in charge of his/her file and

• The timescale to respond to the complaint

​A copy of this complaint policy must be enclosed with the acknowledgement of receipt.

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REGISTRATION AND INFORMATION

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​​If the complaint can be resolved to the client’s satisfaction within twenty-four (24) hours of first being received, the Complaints Officer will record the request in the complaints register briefly outlining the nature of the complaint and the action/outcome agreed with the investor. No further record of the complaint needs to be kept. ​However, if the complaint is non-routine, of a serious nature or cannot be solved within twenty-four (24) hours or has come through the CSSF, the Complaints Officer shall immediately inform the Board of Directors of YT Investor Services.​​

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INVESTIGATION

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Once received, the Complaints Officer arranges to investigate without delay. ​The Complaint Officer receives the complaint and activates, in writing, the person in charge of all the functions involved in the resolution of the complaint (Competent Functions). ​The Competent Functions must collaborate with the compliance function. ​In particular, the Complaint Officer, where applicable, shall request the Competent Functions to:

• Review and investigate the reasons that have prompted the Client to submit the complaint

• Review and determine the times and procedures required to correct the issues that have emerged

• Produce the internal support documentation

​Subsequently, the Competent Functions must formulate a memorandum commenting on the reviews that were carried out and forward a copy, duly signed, to the Complaint Officer, along with the material collected for managing the claim. ​The Complaint Officer, after reviewing the documentation received from the Competent Functions must carry out the following tasks:

• Formulate the response to the client combining the information received from multiple offices if the complaint involves more than a single issue

• Submit the response for review and signature to competent Functions involved

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ANSWER TO THE COMPLAINANT​

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If the answer requires the involvement of Regulatory Authorities, and whenever appropriate in case of financial/reputational loss of YT Investor Services, the Day-to-Day Managers must involve the Board of Directors and a copy of the complaint could be forwarded to the Legal Advisor of YT Investor Services for its remarks/evaluations. ​​The Complaints Officer shall formulate the response and answer to the complainant by writing within one (1) month of receiving the complaint. ​If the complaint cannot be resolved within this period, the complainant will be informed by the Complaints Officer of (i) the reasons why the issue remains unresolved, (ii) the steps to be taken to resolve the matter as well as (iii) an indication of the date at which the examination of the complaint will be achieved and at the latest within two (2) months. 

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ESCALATION OF THE COMPLAINT AT A SECOND LEVEL

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​​Where the complainant did not obtain an answer or a satisfactory answer at the level of the Complaints Officer, he/she will have the opportunity to raise the complaint up to the level of the Board of Directors of YT Investor Services. ​The complainant shall transmit its complaint directly to the Board Members. ​The Board shall immediately inform the Complaints Officer of the escalation of the complaint and shall keep him updated of the complaint handling on a regular basis. ​The same principles as for the complaint handling at the first level shall apply, one of the Board member shall:

• Send an acknowledgment of receipt within ten (10) days after the receipt of the complaint unless the answer itself is provided to the complainant within this period

• Indicate the timescale to respond to the complaint and

• Send the answer within one month or explain the steps undertaken and the reasons of the delay

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EXISTENCE OF THE OUT-OF-COURT COMPLAINT RESOLUTION AT THE CSSF

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​Where the complaint handling at the level of the Board of Directors did not result in a satisfactory answer for the complainant, YT Investor Services shall in writing:

• Provide the complainant with a full explanation of his/her position as regards the complaint

• Inform the complainant of the existence of the out-of-court complaint resolution procedure before the CSSF aiming at facilitating the resolution of complaints without judicial proceedings

• Provide the complainant a copy of the CSSF regulation 13-02 relating to the out-of- court resolution complaints or the reference to the CSSF website and

• Indicate to the complainant the different means to contact the CSSF to file a request