Complaint Handling Policy

1. Scope

In accordance with the requirements of Articles 318-10 and 321-40 of the RGAMF, BDL Capital Management has established and maintains an operational procedure for the prompt and effective handling of complaints submitted by its clients.

A complaint is defined as a written or oral statement expressing the client's dissatisfaction with the portfolio management company. A request for information, advice, clarification, service or benefit is not a complaint.

1. Handling of client complaints

STEP 1: The complaint

Any complaint may be sent to the Compliance and Internal Control Officer:

By email to the following address: bdlcm-compliance@bdlcm.com

By post to the following address: BDL Capital Management 24, rue du Rocher 75008 PARIS

Where the relevant unitholder resides in another Member State of the European Union in which BDL Capital Management funds are marketed, any complaint may be submitted in the official language(s) of the State concerned, and a response will be provided in the same language.

BDL Capital Management will acknowledge receipt of the complaint within a maximum of ten business days from the date of sending the complaint (the postmark serves as proof for complaints sent by post), unless the response itself is provided to the client within this period. Except in duly justified circumstances, BDL Capital Management will provide a response to the client within two months of the client sending the complaint.

As access to the complaint handling procedure is free of charge, no specific fee may be charged to the client for the handling of their complaint.

STEP 2: In the event of a persistent disagreement

For France:

In the event of a persistent disagreement, the client may contact the AMF mediator.

The contact details of the AMF mediator are as follows:

AMF Mediator (Autorité des Marchés Financiers) 17, place de la Bourse 75082 Paris Cedex 02

The mediation request form to the AMF and the mediation charter are available on the website: https://www.amf-france.org/fr/le-mediateur

For Luxembourg:

In the event of a disagreement or in the absence of acknowledgement of receipt / absence of response within one month from the date of sending the complaint, the client may contact the competent authority:

BDL Capital Management undertakes that the one-month period will be respected between the date of receipt of the complaint and the date of sending the response. Failing this, the client/complainant may contact the competent authority:

By post addressed to the Commission de Surveillance du Secteur Financier (CSSF), L-2991 Luxembourg

By email to the following address: direction@cssf.lu

The resolution request form to the CSSF and the relevant texts are available on the website http://www.cssf.lu

The client/complainant may submit their request to the CSSF within one year from the date on which they submitted their complaint in accordance with the provisions of CSSF Regulation 16-07.

1. Cross-border complaint

You may also use FIN-NET for a cross-border complaint if you live in a European Economic Area country, if you have a complaint against a financial services provider in another European Economic Area country, if you have complained but are still not satisfied, and if you want to know which out-of-court dispute resolution body could resolve the dispute.

To send a complaint to a FIN-NET member, you can download and complete the contact form for cross-border complaints https://ec.europa.eu/info/file/fin-net-complaint-form_fr and send the form by email or post to any FIN-NET member in your country or in the country of the fund management company (France).

Contact a FIN-NET member directly and ask for advice; you will find the contact details of all members in each country via the following link: https://ec.europa.eu/info/business-economy-euro/banking-and-finance/consumer-finance-and-payments/retail-financial-services/financial-dispute-resolution-network-fin-net/fin-net-network/members-fin-net-country_fr

1. Personal data management

In the context of handling complaints received under the aforementioned regulations, BDL Capital Management collects personal data from data subjects such as the identity of the person making the complaint, their contact details and the subject or context of the complaint insofar as these refer to personal data such as the economic situation of the data subject. Failure to provide all or part of the required personal data may wholly or partially deprive the data subject of the benefit of the regulatory provisions on complaint handling.

The controller of this processing is BDL Capital Management, represented by its Chairman, who may be contacted at the details provided in this document.

Data is retained for at least five years in accordance with regulatory requirements. Persons making a complaint are informed that their rights of access, rectification, erasure, restriction of processing and objection may be exercised by written communication to the contact details provided in this document, and of the existence of the right to lodge a complaint with a supervisory authority.