“C-Quadart Ampega Asset Management Armenia” LLC / Approved by Supervisory Board of “C-Quadrat Ampega Asset Management Armenia” LLCon --.--. 2018
Chairman of the Supervisory Board
Ernst-Ludwig Drayss

REGULATION ON EXAMINATION OF CUSTOMERS’ COMPLAINT/CLAIMS

TABLE OF CONTENTS

SECTION 1.GENERAL PROVISIONS

CHAPTER 1.SUBJECT OF REGULATION

CHAPTER 2.MAIN CONCEPTS

SECTION 2.SUBMISSION, EXAMINATION AND DECISION MAKING ON CUSTOMER’S COMPLAINT/CLAIM

CHAPTER 3.PHASES OF EXAMINATION PROCEEDINGS OF COMPLAINTS/CLAIMS

CHAPTER 4.PARTICIPANTS OF PROCEEDINGS

CHAPTER 5.SUBMISSION OF COMPLAINT/CLAIM

CHAPTER 6.EXAMINATION OF COMPLAINT/CLAIM

CHAPTER 7.THE GROUNDS FOR REJECTING EXAMINATION OF COMPLAINTS/CLAIMS

CHAPTER 8.THE TERMINATION OF EXAMINATION OF COMPLAINT/CLAIMS

CHAPTER 9.COMPLAINTS/CLAIMS EXAMINATION

CHAPTER 10.TERMS OF EXAMINATION OF COMPLAINT/CLAIM

CHAPTER 11.ASSISTANCE TO THE CUSTOMER

CHAPTER 12.THE EXAMINATION OF COMPLAINTS/CLAIMS IN CASE OF THIRD PARTY INVOLVED

CHAPTER 13.THE FINAL DECISION OF THE COMPANY ON COMPLAINTS/CLAIMS

SECTION 3.THE EXAMINER OF COMPLAINT/CLAIMS BROUGHT AGAINST THE COMPANY

CHAPTER 14.THE EXAMINER OF COMPLAINT/CLAIMS BROUGHT AGAINST THE COMPANY

CHAPTER 15.ADMINISTERING AND REGISTERING COMPLAINT/CLAIMS CASES

SECTION 4.TRANSITIONAL PROVISIONS

CHAPTER 16.TRANSITIONAL PROVISIONS

SECTION 1. GENERAL PROVISIONS

CHAPTER 1. SUBJECT OF REGULATION

  1. The purpose of this regulation is to define the rules of examination of customers’ complaint/claims by “C-Quadrat Ampega Asset Management Armenia” LLC employees.
  2. This regulation is an internal legal act and should be adopted in accordance with Article 7 of RA law “On Financial System Mediator” based on Article 2 of RA law “On Legal Acts”.

CHAPTER 2. MAIN CONCEPTS

  1. The main concepts used in this Regulation should mean:

1)“Company” – “C-Quadrat Ampega Asset Management Armenia» Limited Liability Company.

2)“Customer” – a natural person using professional services of the company or establishing business relationships to access the professional services, which pays to the company for use of such services.

3)“Complaint/claim”- in accordance with the RA Law “On Financial System Mediator”a writtencomplaint/claim filed by the Customer to the Company related to the services provided by the Company, which contains property claim.

SECTION 2. SUBMISSION, EXAMINATION AND DECISION MAKING ON CUSTOMER’S COMPLAINT/CLAIM

CHAPTER 3. PHASES OF EXAMINATION PROCEEDINGS OF COMPLAINTS/CLAIMS

  1. The examination proceedings of complaints/claims of Customer (hereinafter proceedings) consists of Proceeding initiation current and final interconnected phases.
  2. The proceeding is initiated on the basis of submission of Customer’s complaints/claims (Initiation phase).
  3. In accordance with the complaint/claim, functions connected with the examination of complaint/claim and envisaged in this Regulation are implemented (Current phase).
  4. The Proceeding is perorated when the company makes the final decision (Final Phase).

CHAPTER 4. PARTICIPANTS OF PROCEEDINGS

  1. The participants of the Proceeding are:

1)The Customer or his/her representative,

2)The Company,

3)The investigating person of the complaint/claim against the Company,

4)Third parties in case if envisaged by this Regulation.

CHAPTER 5. SUBMISSION OF COMPLAINT/CLAIM

  1. The Company accepts to examine only those complaint/claims which are submitted within 1 year from the moment when the Customer has learned or could learn about the violation of his/her rights.
  2. The Company acceptsto examine only those complaint/claims which are signed by the Customer or the representative and at least include the following information:

1)Customer’s name, surname,

2)Customer’s residence and correspondence addresses, telephone number,

3)Description of complaint/claim,

4)Day, month and year of filing the claim,

5)Customer’s signature. If the claim is signed by Customer’s representative attached to the claim shall be a document confirming authorities of the representative (letter of attorney).

  1. If there are formal mistakes in the complaint/claims, which can be corrected, the Company indicates them to the Customer, giving him/her opportunity to correct the mistakes within 5 day period. If the list of documents attached to the claim is not complete, the Company offers the Customer to replenish the list maximum within 5 days. In that case complaint/claim is considered to be submitted when complete package of complaint/claim is filed to the Company.

CHAPTER 6. EXAMINATION OF COMPLAINT/CLAIM

  1. Within one business day after receiving the claim, the Company finds out:

1)Whether the person who submitted the complaint/claim is a Customer in context of this Regulation,

2)Whether the claim is submitted according to the time-schedule determined in point 1 of Chapter 5,

3)Whether the claim satisfies the requirements determined in point 2 of Chapter 5,

4) Whether there are grounds for Rejection determined in chapter 7,

  1. Finding out the grounds envisaged by point 1 of this Chapter, the Company makes decision on filing the claim or rejecting its examination.
  2. After making the decision on filing the claim or rejecting its examination the Company informs the Customer on its decision via telephone or e-mail within that day.
  3. In case when a decision on rejecting to examine the claim is made, the next day after the notice determined in the previous point, the Company submits to the Customer the hard copy of the decision on rejecting the examination of the claim which must be approved by the Company director and must include the definite grounds for rejection and clarifications on grounds for rejecting the examination.

CHAPTER 7. THE GROUNDS FOR REJECTING EXAMINATION OF COMPLAINTS/CLAIMS

  1. The examination of Customer’s complaint/claim shall be rejected, if

1)The complaint/claim is signed by a disable or partially disable person,

2)The claim is not submitted according to the time-schedule determined by the point 1 of the Chapter 5 of this Regulation,

3)The complaint/claim has already been examined by the Company, and exists a Company’s decision on it,

4)Before the submission of Customer’s complaint/claim, the Company has offered to compensate the losses borne by the Customer in written form and in Company’s opinion the compensation amount is sufficient to compensate the losses including omitted benefits borne by the Customer.

5)The complaint/claim does not correspond to the requirements envisaged in the point 2 of the Chapter 5.

6)The Customer has not corrected the formal mistakes in the complaint/claim and/or has not replenished the incomplete list of documents attached to the complaint/claimwithin 5 days period in accordance with the procedure provided by the point 3 of the Chapter 5.

CHAPTER 8. THE TERMINATION OF EXAMINATION OF COMPLAINT/CLAIMS

  1. The Company terminates the examination of complaint/claim by his decision, if

1)During the examination of complaint/claim it turns out that the claim is not subject to examination by the Company according to the law and this Regulation,

2)During the examination of complaint/claim it turns out that the court or arbitrage tribunal hasadmitted the claim with the same subject of the complaint/claim into proceedings ,

3) During the examination of complaint/claim theCustomer reclaims it.

CHAPTER 9. COMPLAINTS/CLAIMS EXAMINATION

  1. The Company providesa final written reply approved by the Company director to the Customer within the time-schedule determined by chapter 10 after receiving the complaint/claim.
  2. The Company organizes the examination of the claimwithin the next business day after making a decision on examination of the claim.
  3. The Company must examine the claim without any complication: holding additional discussions, conducting additional surveys, if there are no necessary reasons for clarification of facts of the case.
  4. If after initiating the proceeding the Company disposesrequired documents for the relevant decision making and the circumstances of the given case are clarified and adjusted at a sufficient level, the Company makes a decision after the emergence of the mentioned circumstances within reasonable terms without waiting for the expiry of the general period.
  5. The Company provides comprehensive, complete and objective examination of facts disclosing all circumstances of the case including those in favor of the proceeding participants.
  6. On own initiative or Customer request the Company may make the Customer and (or) his/her representative a participant in the procedure of examination.If the Customer becomes a participant of examination of the complaint/claim on Company’s own initiative, the no-show of the Customer is not ground for the rejection.
  7. Discussions may be not held if:

1)During the examination of complaint/claim a favorable decision for the Customer will be made,

2)It is necessary to make a straightwaydecision, as the delay can entail loss for the Customer.

  1. If the Customer does not receive a final reply from the Company within determined terms in accordance with point 1 of Chapter 10, he/she gets a right to submit acomplaint/claim to FinancialSystem Mediator in accordance with cases and manner envisaged inRA legislation.

CHAPTER 10. TERMS OF EXAMINATION OF COMPLAINT/CLAIM

  1. The final written decision on the complaint/claim must be provided to the Customer within 10 business days after receiving the complaint/claim.

CHAPTER 11. ASSISTANCETO THE CUSTOMER

  1. The Company provides clarifications tothe Customer on the rights and responsibilities related to the given proceedingonthe proposed issue of the Complaint/claims, as well asassists to formulate the complaint/claim and attached documents.

CHAPTER 12. THE EXAMINATION OF COMPLAINTS/CLAIMS IN CASE OF THIRD PARTY INVOLVED

  1. If according to the Company the Customer has borne losses because of the third party, the Company should also send the copy of the Complaint/claim to the third party within three business daysafter the day of receiving the Complaint/claim. Together with the copy a Company writingpresenting the necessity for the involvement of a third party is sent to the third party.
  2. On the day of sending the copy of the Complaint/claim to the third party the Company informs the Customer about it in writtenform, substantiating the necessity of sending the Complaint/claim to the third party.
  3. If in the Company’s reasoned opinion the Customer has borne losses because of the third party’s actions or inaction the Company involves the third party in the process of examination.

CHAPTER 13. THE FINAL DECISION OF THE COMPANY ON COMPLAINTS/CLAIMS

  1. Based on the results of the examination of the Complaint/claim the Company makes a decision on satisfying or partially satisfying the claim or rejecting it and delivers it to the Customer on the same day; as well as to the third party,if any involved.
  2. If the Company decides to satisfy or partially satisfy the claim, a period within which the Company must fulfill its undertaken liabilities is also envisaged.
  3. The Company’s decision shall be reasoned and shall take into account not only the legislative requirements of RA, but also the rules and ethicsof business conduct and business practice customs.
  4. The final response to the complain/claim, returned to the Customer by the Company, shall contain at least the following:

1) the explicit position of the company either to refuse the complain/claim, or to satisfy it partially or in-full,

2) the reasoning of the decision of the company,

3) information on the department or the person responsible for examination of the complain/claim (the name of the department or the name, surname, post of the person) and contact details (telephone number, electronic address, etc.),

4) information that the customer can approach the department (person), mentioned in sub-point 3 of this point, in case of having questions on the result of the examination of the complain/claim,

5) information that the customer can bring an action before the court, apply to the financial system mediator or to the Central Bank or to the arbitration court, if arbitration agreement exists, in order to defend his/her rights, in case of being dissatisfied with the written response to the complain/claim,

6) information on period of time, in which the customer has the right to apply to the financial system mediator, in case of being dissatisfied with the written response to the complain/claim.

SECTION 3. THE EXAMINER OF COMPLAINT/CLAIMSBROUGHT AGAINST THE COMPANY

CHAPTER 14. THE EXAMINER OF COMPLAINT/CLAIMSBROUGHT AGAINST THE COMPANY

  1. The Company has an examiner of complaint/claims brought against it, as well as a deputy officer, in case of his/her absence. The officers are appointed by the relevant government body of the Company for a period of one year.
  2. The examiner of complaint/claims, while examining the claims of the Customers shall be guided by the following principles:

1)legality,

2)Impartiality,

3)independence,

4)ban to abuse the formal claims,

5)ban on arbitrariness,

6)search for opportunities,to achieve bilateral beneficial result both forthe Customer and the Company

  1. The examiner of complaint/claims is obliged to:

1)receive, examine and make decisions on complaint/claims brought by the Customer,

2)in case of necessity, organize and conduct negotiations with the Customers who brought complaint/claims,

3)detect and prevent cases of damage to the Customers,

4)compile and maintain case related to Complaint/claims,

5)keep registers envisaged in the Chapter 15,

6)prepareprotocols of Complaint/claimsreview.

  1. The examiner of complaint/claims has the rights to:

1)request and receive any document or information from the Company's employees, which can help toexamine the complaint/claimsbrought by the customer and achieve bilateral beneficial decision,

2)propose amendments to the legal acts regulating Company's activity, that are aimed at further measures to ensure the protection of Clients' rights, as well as the improvement and perfection of the processes of complaint/claims receipt and examination,

3)undertake and perform other necessary functions connected to fairness, impartiality and effectiveness of the examination of complaint/claims.

CHAPTER 15. ADMINISTERING AND REGISTERING COMPLAINT/CLAIMS CASES

  1. Upon initiating proceeding, theexaminer of complaint/claims constitutes a separate case where all the documents relating to such proceedingor copies thereof are kept, including the company's decision on Complaint/claim examination.
  2. The examiner of complaint/claimskeeps unified registry of chronological and objective reporting of Complaint/claims, as well as of the company's decisions on examination of Complaint/claims.
  3. The registry provided by the previous point can also be conducted in electronic form.

SECTION 4. TRANSITIONAL PROVISIONS

CHAPTER 16. TRANSITIONAL PROVISIONS

  1. This Regulation shall enter into force upon its approval by the Supervisory Board of “C-Quadrat Ampega Asset Management Armenia” LLC.
  2. This Regulation shall be repealed upon its repealby the Supervisory Board of “C-Quadrat Ampega Asset Management Armenia” LLC.
  3. Amendments of this Regulation shall enter into force upon its approval by the Supervisory Board of “C-Quadrat Ampega Asset Management Armenia” LLC.

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