Complaints management policy

INTRODUCTION

This Complaints Management Policy (the “Policy”) outlines how GRIT Fund Management Company Ltd (“GRIT”) handles customer complaints, including details on how customers can submit a complaint and the process that is followed when handling a complaint. This Policy is prepared and annually reviewed by the Compliance Function and approved by GRIT’s board of directors.

This Policy is available to GRIT’s customers free of charge upon request and on GRIT’s website. Additionally, the Policy is made available to all relevant staff of GRIT.

Definition of a Complaint

A complaint, in the context of this Policy, is defined as a statement of dissatisfaction addressed to GRIT by a non-professional investor, whether a natural or legal person, relating to the provision of a supervised activity provided by, or the conduct of, GRIT. In the context of this Policy, the term customer refers exclusively to customers who qualify as customers of GRIT under applicable financial services legislation. A person or entity submitting a complaint is referred to as a complainant.

Complaints management function

The complaints management process of GRIT is handled by the Compliance Function, headed by the Compliance Officer. In the absence of the Compliance Officer, or in the event of a conflict of interest between the Compliance Officer and the complainant, the complaints management process is managed by their stand-in as defined in the Compliance Policy of GRIT.

Filing a Complaint

Customers can file a complaint free of charge either via e-mail, telephone, or post addressed to the postal address listed at the end of this Policy. The complaint shall include the name and contact information of the complainant, reasons for filing the complaint, and a detailed description of the matter.

Complaints handling process

The Compliance Function oversees and coordinates the handling of complaints to ensure they are acknowledged, investigated, and responded to without undue delay. Acknowledgement of the receipt of a complaint shall be issued within three business days. The Compliance Function is responsible for deciding on any actions taken as a result of a complaint. When the investigation has been concluded, GRIT provides a response on the complaint to the complainant. The response shall be in clear and easily understandable language. In cases where the complainant is not satisfied with the response to their complaint, the complainant shall be informed on options for alternative dispute resolution.

GRIT does not process complaints regarding activities of other entities for which GRIT has no legal or regulatory responsibility and where those activities form the substance of the complaint. In such cases the investor shall be informed of GRIT’s position and be referred to the entity responsible for handling the matter.

Personnel receiving a complaint from a complainant shall immediately inform the Compliance Function of the complaint. The Compliance Function maintains an internal checklist to enable personnel to determine whether an issue qualifies as a complaint. The Compliance Function analyzes complaints and complaints-handling data to ensure that any risks or issues are identified and addressed.

To safeguard the integrity and interests of the complainant, complaints shall be handled confidentially and disclosed only to those personnel whose involvement is necessary for the proper handling of the complaint.

The Compliance Function shall keep records of complaints received and the actions taken to resolve them for five years. Complaints are periodically reported by the Compliance Function to the board of directors. This information is provided to the Finnish Financial Supervisory Authority as necessary.

Alternative dispute resolution

In case of a dispute between a complainant and GRIT that cannot be settled by mutual negotiations, a non-professional investor may refer the complaint to an independent body, such as the Investment Complaints Board with the Finnish Financial Ombudsman Bureau.

Contact details

GRIT Fund Management Company Ltd
Compliance Function
Storalånggatan 34 C
FI-65100 VAASA FINLAND

The Finnish Financial Ombudsman Bureau
Investment Complaints Board
Porkkalankatu 1
FI-00180 HELSINKI FINLAND.

Updated 25 March 2026