Claims Policy

GUIDELINES FOR SETTLING CLAIMS
(CLAIMS POLICY)

AVANT investiční společnost, a.s. (hereafter the Company) pursuant to Act No. 240/2013 Coll. on Investment Companies and Investment Funds, as amended (hereafter the Act):

1. GENERAL PROVISIONS

1.1. The Company is obligated to execute its duties arising from applicable legislation or contracts concluded with persons to whom it provides services (hereafter Investors) with due diligence and in compliance with the provisions stipulated in the contract as well as in applicable legislation.

1.2. An Investor who believes the Company has failed to act in compliance with paragraph 1.1. is entitled to file a claim pursuant to this claims policy and applicable legislation.

1.3. A claim is a defined as a complaint filed by an Investor. A legal requirement for a claim is a duly concluded contract on the basis of which the Company provides the Investor with services (hereafter Contract).

1.4. The claim procedure comprises a set of tasks intended to determine shortcomings and the legitimacy of the claim, to settle the claim, and to execute necessary accounting operations relating to the given claim.

2. FILING A CLAIM

2.1. In the event of a shortcoming, the Investor may file a claim with Company in writing within the time limit set forth in paragraph 3.1. A written claim may also be filed by fax.

2.2. A claim filed by an Investor must contain information and documents to be used by the Company in verifying the legitimacy of the claim (i.e. name and surname/legal name, residence/place of business, national identification number/company identification number, reason for the claim, contact address, list of appendices, datum and handwritten signature as well as all appendices supporting the legitimacy of the claim) and deciding whether it is justified.

2.3. If the claim does not contain the information and documents necessary for verifying its legitimacy, the Company will ask the Investor to provide them. If the Investor fails to provide the information or documents within the given time limit (not shorter than 7 days), the Company will reject the claim as unjustified.

3. CLAIM TIME LIMITS

3.1. Unless otherwise stipulated in the contract, the Investor is obligated to file a claim without undue delay upon discovering a shortcoming.

3.2. The Company is obligated to take a position on a complaint or claim and settle it within 30 days of receiving it pursuant to paragraphs 2.2. and 2.3. and inform the Investor about whether the complaint or claim will be validated, the manner in which it will be handled (or is already being handled), or, contrarily, the reasons the Company has decided to reject the complaint or claim. In so doing, the Company must proceed in compliance with the provisions of this claims policy.

4. CLAIM SETTLEMENT

4.1. The settling of claims and claim procedure are the responsibility of the Company’s compliance officer.

4.2. In the event of a claim sent to the Company by post, the administration department enters the claim in the Claims Book under the appropriate reference number and then, without undue delay, transfers the claim to the compliance office. If a claim is delivered to the Company in person, it is received by the administration department or another authorized person. The Investor may request confirmation of receipt of the claim from the person receiving it.

4.3. The person who takes receipt of the claim discusses it in detail with the Investor and immediately enters it in the Claims Book under the appropriate reference number. The claim and all accompanying materials are then transferred to the compliance office.

4.4. The Company is obligated to discuss such a claim, take a position on it, and settle it (rectify the shortcoming) without undue delay and no later than 30 days of receiving it and then inform the Investor about these actions in writing.

4.5. All written correspondence relating to the settlement of a claim will be kept by the Company for a minimum of five years unless a longer period is stipulated by applicable legislation.

5. CLAIM REJECTION

5.1. A claim is rejected if it is determined to be based on inaccurate information, and reliable documents are available that support rejection.

6. CLAIM SETTLEMENT

6.1. In compliance with the provisions of paragraphs 4.2. and 4.3., all correspondence relating to the settlement of a claim is transferred to the compliance officer as the person responsible for seeing that the claim is settled to a high standard and that a claim settlement document is issued. Based on the nature of the claim, the compliance officer also determines who settlement is assigned to.

6.2. In the event of a complaint about the employee authorized to settle a claim, the Investor will negotiate directly with the compliance officer, who will personally handle settlement of the claim.

7. CHANGES TO THE CLAIMS POLICY

7.1. In the event of changes to the claims policy, the Company is obligated to inform Investors in writing in a timely fashion and also publish each change to the claims policy at Company headquarters and on the Company website www.avantfunds.cz. The method of informing an Investor about the new wording of the claims policy, and the qualified means by which the Investor consents to the changes, are stipulated by the provisions of the contract concluded between the Investor and the Company.

8. FINAL PROVISIONS

In conducting its investment fund management activities, the Company is obligated to adhere to its internal policies issued in compliance with the Act and related implementing regulations.

In Prague on 11 July 2014

CLAIMS POLICY

This claims policy specifies the rules and procedures for the settlement, free of charge, of complaints and claims from shareholders (hereafter Investors) of qualified investor funds managed by AVANT investiční společnost, a.s. (hereafter the Company).

1. A complaint or claim must be filed with the Company by an Investor in written form only. A written complaint or claim may also be filed by fax.

2. A legal requirement for filing a complaint or a claim is a duly concluded contract or contract documentation analogous to a contract on the basis of which the Company provides the Investor with services (hereafter Contract).

3. If not stipulated otherwise, the Investor is obligated to file a complaint or claim without undue delay upon discovering shortcomings or errors in a contract.

4. A claim filed by an Investor must contain information and documents to be used by the Company in verifying the legitimacy of the claim (i.e. name and surname/legal name, residence/place of business, national identification number/company identification number, reason for the claim, contact address, list of appendices, datum and handwritten signature as well as all appendices supporting the legitimacy of the claim).

5. If the claim does not contain the information and documents necessary for verifying its legitimacy, the Company will ask the Investor to provide them. If the Investor fails to provide the information or documents within the given time limit (not shorter than 7 days), the Company will reject the claim as unjustified.

6. The Company is obligated to take a position on a complaint or claim and settle it within 30 days of receiving it or the addition of necessary information and documents as stipulated in the previous paragraph. Within this time limit, the Company must always inform the Investor about whether the complaint or claim will be validated, or the about reasons for its rejection. If, for objective reasons, the Company cannot settle a complaint or claim within 30 days, it must inform the Investor and, if necessary, provide information as to how the claim will be handled (or is being handled), including a new time limit for settlement.

7. The Company settles a complaint or claim by either validating or rejecting it, of which the Investor is informed in writing.

8. A complaint or claim will be rejected by the Company if it is determined to be unjustified or based on inaccurate information, and reliable documents are available that support rejection.

9. If a complaint or claim is validated by the Company, the shortcoming will be immediately rectified, and the Investor is given the name of the employee of the Company who will handle settlement.

10. In the event of a complaint about the employee authorized to settle a claim, the Investor will negotiate directly with the compliance officer, who will personally handle settlement of the claim.