Whistleblowing complaints

UAB Modus Asset Management (Company) seeks to conduct its activities responsibly, ethically, openly and transparently. The Company believes that such responsible and transparent conduct benefits not only the Company, the collective investment undertakings (Funds) it manages, but also all stakeholders.

The Company enables and encourages employees (current and former) of the Company and companies controlled by the Funds, their family members, service providers or other parties to (pre)contractual
relationships, members of management bodies, any other persons working under the supervision of the contractors of the Company / companies controlled by the Funds (Whistleblowers) to report actual or potential violations of legislation, internal policies and procedures, Code of Business Ethics without fear of any adverse consequences.

For more information about the procedure for providing, receiving, registering, evaluating and making decisions on violations disclosed in Whistleblowers’ reports can be found in:

Complaints of other persons (who do not fall under the definition of Whistleblowers provided above) shall be submitted and examined in accordance with the

Whistleblower’s report may be provided at the choice of the Whistleblower:

(a)

by anonymous reporting channel (see the electronic form of Whistleblower’s report provided below);

(b)

by e-mail address

,

)

(c)

orally or in writing directly to the person responsible for handling of Whistleblowers’ reports (Compliance Officer of the Company,

if the report is related / submitted due to the violation performed by the Compliance Officer of the Company.

(d)

orally or in writing directly to the CEO

)

(

or the Chairman of the Board of the Company

)

(

Details of the person reporting the breach

Information about the violation

Details of the person or persons who committed the violation

Details of the witnesses of the violation

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