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PROCEDURE E POLITICHE MANAGEMENT COMPANY

In compliance with the CSSF Rule 10-04 and the CSSF Circular 11/512 under this section there are the Company’s rules of Conduct and Procedure envisaged for the administration of the following topics.

- Strategy for the exercise of voting rights (art 28.3 of the CSSF Rule 10-04)

- Complaint handling (sec II.2 of the CSSF Circular 11/512)

- Conflict of interest procedure (sec III.1 of the CSSF Circular 11/512)

- Best execution practice (art 28.3 of the CSSF Rule 10-04)