Pursuant to the decision of the Polish Financial Supervision Authority – KNF (DFII / I / 4031/100/20/16/17/U/AS) of 29 May 2017, ProService Finteco Sp. z o.o. mediates in the sale and repurchase of participation units of open-end investment funds, specialized open-end investment funds and participation titles of foreign funds. As part of ProService Finteco Sp. z o.o. Shares Distribution Department was established to provide customer service via the Internet, telephone, IVR system, fax and in a direct manner.

As part of the distribution of investment fund participation units, the Participant may contact ProService Finteco Sp. z o.o. in the following way:

1. By phone at the telephone numbers relevant for each investment fund:
   • Generali Investments TFI SA: (22) 58 81 884,
   • Nationale-Nederlanden TFI S.A: (22) 58 81 854,
   • Aviva Investors Poland TFI SA: (22) 58 81 881,
   • Noble Funds TFI SA: (22) 58 81 863,
   • Quercus TFI SA: (22) 33 89 114,
   • Skarbiec TFI SA: (22) 58 81 886,
   • Fundusze Inventum: (22) 32 04 785,
   • Rockbridge TFI SA : (22) 33 89 102,
   • BPS TFI SA: (22) 22 58 81 892,
   • BPS TFI SA ( ALTIUS Open-End Investment Fund and SEJF Parasol FIO): (22) 32 04 719,
   • Copernicus Capital TFI SA: (22) 32 04 798 or 801 809 975,
   • BNP Paribas TFI S.A. ( BNP Paribas Premium Specialist Open-End Investment Fund): (22) 32 04 790,
   • Opera TFI SA (NOVO Open-End Investment Fund): (22) 35 54 681,
   • Opera TFI SA (DB Funds FIO): (22) 35 54 679.

2. Through the Transactional Information System (TIS), respectively from the websites of individual investment funds:
   • nn.pl
   • aviva.pl
   • skarbiec.pl
   • rockbridge24.pl
   • superfund.pl
   • tfi.bnpparibas.pl
   • ipopematfi.pl
   • millenniumtfi.pl
   • bpstfi.pl
   • Open Finance FIO
   • fio.copernicus.pl

3. Directly at the Customer Service Center, ul. Konstruktorska 12A, Building B, Entrance C, 4th floor, 02-673 Warsaw, at times specified for each TFI separately:
   • Generali Investments TFI SA between 8 AM and 4 PM
   • Nationale-Nederlanden TFI S.A. between 8 AM and 4 PM
   • Aviva Investors Poland TFI SA between 8 AM and 4 PM
   • Noble Funds TFI SA between 8 AM and 4 PM
   • Skarbiec TFI SA between 9 AM and 5 PM
   • Inventum funds from 8 AM and 4 PM
   • BPS TFI SA between 8 AM and 4 PM
   • HSBC Global Asset Management from 9 AM and 5 PM

Services provided by ProService Finteco Sp. z o.o. in the scope of distribution of participation units of open-end investment funds and specialized open-end investment funds:

• Accepting orders and instructions of Participants by electronic media (telephone, fax, IVR system) and by correspondence;
• Accepting orders and instructions of Participants during personal visits to a Customer Service Point (CSP) operated by ProService Finteco Sp. z o.o .;
• Control of accepted orders and instructions via an online platform;
• Reporting of accepted orders and instructions to the transfer agent;
• Providing information to Participants and potential Participants about the rules of participation in the Funds and the state of their registers by phone, or directly during a visit to the Customer Service Center managed by ProService Finteco Sp. z o.o .;

Rules of Conduct applied by Employees of ProService Finteco Sp. z o.o. when accepting orders by phone, fax or in a direct manner:

• ProService Finteco Sp. z o.o. does not provide cash services to its customers. No employee of ProService Finteco Sp. z o.o. may accept cash.
• ProService Finteco Sp. z o.o. does not provide investment advice.
• Employees of ProService Finteco Sp. z o.o. (CSC) accepting an order from a participant (s) may not suggest in any way to the participant the choice of a given Company / Fund whose participation units are distributed by ProService Finteco Sp. z o.o. The participant decides independently on the selection of a given Company and a given Fund / Funds and submission of a given order regarding participation units. An employee of ProService Finteco Sp. z o.o. is obliged at the participant’s request to inform them about the rules of investing in individual funds, investment risk and costs, make sure that the knowledge possessed by the participant about the rules of investing in individual funds allows an informed submission of an order / instruction.

Starting on 18 May 2020, services to investment fund participants have been provided at the Customer Service Point at 12A Konstruktorska Street (Building B, Entrance C, 4th floor) with the following precautions and safety principles:

• Separating the customer from the CSP employee by a plexiglass cover
• Obligation to cover the mouth and nose
• Providing disinfectant liquids, masks and disposable gloves
• Only 1 customer allowed to stay in the CSP room
• Disinfection of sensitive surfaces after each customer’s visit

ProService Finteco serves participants of funds managed by the following Investment Funds:

• Generali Investments TFI SA between 8 AM and 4 PM, hotline number  (22) 58 81 884,
• Nationale-Nederlanden TFI S.A. between 8 AM and 4 PM, hotline number (22) 58 81 854,
• Aviva Investors Poland TFI SA between 8 AM and 4 PM, hotline number (22) 58 81 881,
• Noble Funds TFI SA between 8 AM and 4 PM, hotline number (22) 58 81 863,
• Skarbiec TFI SA between 9 AM and 5 PM, hotline number (22) 58 81 886,
• Inventum funds from 8 AM and 4 PM, hotline number (22) 32 04 785,
• BPS TFI SA between 8 AM and 4 PM, hotline number 22 58 81 892,
• HSBC Global Asset Management from 9 AM and 5 PM, hotline number (22) 58 81 867.

Due to the fact that only one person at a time can stay at our Customer Service Point, please call the telephone number of the relevant Fund hotline in advance to schedule the date and approximate time of visit.

The participant may obtain information on the rules of participation in the Funds / Sub-Funds by:

• Telephone contact with an employee of ProService Finteco Sp. z o.o. The employees of ProService Finteco Sp. z o.o. provide the customer with all information regarding the rules of participation in the Funds / Sub-Funds, fees charged, conditions for using the exemption and reduction of handling fees, rules for granting and revoking powers of attorney (to the extent indicated by the Funds / Sub-funds in advertising and information materials received from the Fund).
• Websites of selected Funds:
  • generali-investments.pl
  • nn.pl
  • aviva.pl
  • noblefunds.pl
  • quercustfi.pl
  • skarbiec.pl
  • rockbridge.pl
  • Fundusze Inventum
  • superfund.pl
  • tfi.bnpparibas.pl
  • bpstfi.pl
  • ipopematfi.pl
  • millenniumtfi.pl
  • Open Finance FIO
  • fio.copernicus.pl
  • assetmanagement.hsbc.com/pl
  • novofundusze.pl
  • opera.pl

Prospectuses of investment funds and foreign funds are also available on the above-listed websites along with current information about changes in these prospectuses and Key Investor Information:

• Generali Investments TFI SA
• Nationale-Nederlanden TFI
• Aviva Investors Poland TFI SA
• Noble Funds TFI SA
• Quercus TFI SA
• Skarbiec TFI SA
• Fundusze Inventum
• Rockbridge TFI SA
• SUPERFUND TFI SA
• BNP Paribas TFI SA ( BNP Paribas Premium Specialist Open Investment Fund)
• BPS TFI SA
• Ipopema TFI SA
• Open Finance FIO
• Millennium TFI SA
• Copernicus Capital TFI SA
• HSBC Global Asset Management
• Opera TFI S.A.( NOVO Open-End Investment Fund)
• Opera TFI S.A.( DB Funds Open-End Investment Fund)

• Also directly at the Customer Service Point run by ProService Finteco Sp. z o.o. in Warsaw at ul. Konstruktorska 12A, building B, entrance C, 4th floor, 02-673 Warsaw.

Costs and Commissions

ProService Finteco Sp. z o.o. is an entity operating pursuant to Article 32 section 2 of the Act on investment funds and management of alternative investment funds, and does not charge fees for distribution services provided to investment fund participants.

ProService Finteco Sp. z o.o., in accordance with Article 32a Section 7 of the Act on investment funds and management of alternative investment funds, may receive from investment fund companies managing investment funds, in the proces of selling and buying participation units, the following types of benefits:

1) cash or non-cash benefits accepted or transferred to a third party that is necessary to perform the service provided to the customer, in particular:

• a) fees to the supervisory authority,
• b) taxes, public law liabilities and other fees whose payment obligation results from legal provisions;

2) other cash or non-cash benefits if:

• a) they are accepted or transferred in order to improve the quality of the service provided by the entity referred to in Article 32 Section 2 of the Act on investment funds and management of alternative investment funds, for the benefit of the customer, and the amount of which is determined on the basis of costs incurred by ProService Finteco sp.z o.o. The justification for the payment of such benefits is verified by investment fund companies in accordance with the Act on investment funds and management of alternative investment funds;
• b) their acceptance or transfer has no negative impact on the operation of the entity referred to in Article 32 Section 2 of the Act on investment funds and management of alternative investment funds, in a reliable and professional manner, in accordance with the principles of fair trading and in accordance with the best interests of the client’s customer, in the form of training materials, advertising (such as calendars, notebooks, pens) and information or training employees of ProService Finteco Sp. z o.o., which allows you to obtain current knowledge about units or titles being the subject of the service and customer service rules so that the customer is provided with service according to current market standards.

The only fees that are collected by the Funds from Participants in connection with the orders placed are available in the tables of fees of individual investment fund companies on the websites:

• www.generali-investments.pl
• www.nn.pl
• www.aviva.pl
• www.noblefunds.pl
• www.quercustfi.pl
• www.skarbiec.pl
• www.rockbridge.pl
• www.superfund.pl
• www.tfi.bnpparibas.pl
• www.bpstfi.pl
• www.ipopematfi.pl
• www.millenniumtfi.pl
• Open Finance FIO
• Fundusze Inventum
• www.fio.copernicus.pl
• www.assetmanagement.hsbc.com/pl
• www.novofundusze.pl
• www.opera.pl

The participant may submit a complaint regarding the quality of services provided by ProService Finteco Sp. z o.o., as well as the method and correctness of the execution of orders and instructions, broken down into individual Funds, by:

1. Phone:
   • Generali Investments TFI SA: (22) 58 81 884,
   • Nationale-Nederlanden TFI: (22) 58 81 854,
   • Aviva Investors Poland TFI SA: (22) 58 81 881,
   • Noble Funds TFI SA: (22) 58 81 863,
   • Quercus TFI SA: (22) 33 89 115,
   • Skarbiec TFI SA: (22) 58 81 886,
   • Fundusze Inventum: (22) 32 04 785,
   • Rockbridge TFI SA: (022) 33 89 102,
   • BPS TFI SA: (22) 58 81 892,
   • Ipopema TFI SA: (22) 33 89 107,
   • BPS TFI SA (ALTIUS Open-End Investment Fund and SEJF Parasol FIO): (22) 32 04 719,
   • BNP Paribas TFI SA ( BNP Paribas Premium Specialist Open Investment Fund): (22)  32 04 790.
   • Copernicus Capital TFI SA: (22) 32 04 798 lub 801 809 975,
   • Opera TFI SA (NOVO Open-End Investment Fund): (22) 35 54 681,
   • Opera TFI SA (DB Funds FIO): (22) 35 54 679.

2. The Internet (TIS) on the websites of individual Funds.
3. Directly at the Customer Service Point operated by ProService Finteco Sp. z o.o.
4. By correspondence to the following address: ProService Finteco Sp. z o.o. 12A Konstruktorska Street, 02-673 Warsaw. The complaint should specify:
   • data of the order or instruction (type, date of submission, Fund / Subfund, order value) that is subject to a complaint;
   • Participant’s (register owner) data;
   • details of the person submitting the complaint;
   • the subject of the complaint.
   • The deadline for considering the complaint depends on the Funds concerned by the complaint and is specified in the procedures of a given Fund.
   • In cases of extending the deadline for examining complaints, relevant information including the reason and deadline for completing consideration of the complaint is sent to the Participant’s address.
   • Answers to complaints are provided by ProService Finteco Sp. z o.o. in writing, unless the applicant indicated a different form of sending the response.
   • Complaints are forwarded to the appropriate organizational unit of the transfer agent, which deals with their consideration, in accordance with specific procedures.
   • ProService Finteco Sp. z o.o. as a financial institution is subject to the supervision of the Polish Financial Supervision Authority.

ProService Finteco Sp. z o.o. developed internal regulations aimed at preventing conflicts of interest and protecting confidential information in the company. At the request of the customer, they may be provided with detailed information about the entity’s policies in the event of a conflict of interest.

Conflict of Interest – circumstances that may lead to a conflict between the interests of ProService Finteco Sp. z o.o., a Related Person, including the between management personnel, employees and agents, or any person directly or indirectly related to them by the control relationship, and their clients or between clients, and the obligation of ProService Finteco Sp. z o.o. in a reliable manner, taking into account the best interests of the customer, as well as circumstances that may lead to a conflict between the interests of customers of ProService Finteco Sp. z o.o., including conflicts of interest caused by receiving incentives or compensation from any third parties.

Related Person – a person who is part of the statutory bodies of ProService Finteco Sp. z o.o., a person remaining with ProService Finteco Sp. z o.o. in an employment relationship, order or other legal relationship of a similar nature, entities belonging to the same capital group as ProService Finteco Sp. z o.o.

In order to implement a solution aimed at identifying, managing and controlling real Conflicts of Interest, ProService Finteco Sp. z o.o. identified potential Conflicts of Interest that may occur in connection with the activities of ProService Finteco Sp. z o.o.

Identified Conflicts of Interest (incomplete list):

• ProService Finteco Sp. z o.o. or an employee of ProService Finteco Sp. z o.o. has an objective or financial reason to prefer one customer over another customer;
• ProService Finteco Sp. z o.o. or an employee of ProService Finteco Sp. z o.o. receives a financial benefit from a person other than the customer, other than standard fees, in relation to the service provided to the customer;
• ProService Finteco Sp. z o.o. or an employee of ProService Finteco Sp. z o.o. may obtain an advantage or avoid a loss as a result of incurring a loss or failure to obtain an advantage from the customer;
• ProService Finteco Sp. z o.o. or an employee of ProService Finteco Sp. z o.o. has an interest in the specific outcome of a service rendered to customers and may be divergent with the customer’s interests;
• ProService Finteco Sp. z o.o. or an employee of ProService Finteco Sp. z o.o. carries out the same activity as the business conducted by the client or employee of ProService Finteco Sp. z o.o. carries out the same activities as ProService Finteco Sp. z o.o .;
• ProService Finteco Sp. z o.o. or an employee of ProService Finteco Sp. z o.o. uses information about one customer to gain benefits or avoid loss for another customer;
• ProService Finteco Sp. z o.o. or an employee of ProService Finteco Sp. z o.o. uses confidential information to obtain benefits and avoid losses.

Conflicts of Interest management methods and procedures adopted

ProService Finteco Sp. z o.o. controls the undertaking of other gainful/social activity by an employee of ProService Finteco Sp. z o.o. and accepting gifts/benefits in tangible or intangible form, as well as employees’ own investments.

ProService Finteco Sp. z o.o. separates the function of a unit conducting activity in the field of intermediation in the sale and redemption of units from units responsible for the activities of a transfer agent.

ProService Finteco Sp. z o.o. assures that customers make the decision on the choice of a given Society and a given fund/funds and on the submission of a given order/instruction.

Obligation to keep confidential information confidential

Each employee of ProService Finteco Sp. z o.o. is obliged to keep Confidential Information a secret, not to disclose and not use information obtained as part of the work for purposes other than the proper performance of employee duties.

The obligation referred to above applies to all Confidential Information obtained while performing work at ProService Finteco Sp. z o.o.

The obligation mentioned above binds employees indefinitely also after the termination of employment relationship between the employee of ProService Finteco Sp. z o.o. and ProService Finteco Sp. z o.o..

ProService Finteco Sp. z o.o. implements technical and organizational solutions whose purpose is to limit access to information only to authorized persons.

Information on the processing of the Customer’s personal data (“PDO Guide”) based on Article 13 of the Regulation on the protection of personal data (GDPR)

Information on the processing of personal data of the Customer’s representative (“PDO Guide”) based on Article 14 of the Regulation on the protection of personal data (GDPR)

Legislation, below is the link to relevant website:

https://www.knf.gov.pl/dla_rynku/regulacje_i_praktyka/regulacje_prawne/akty_prawne_sektor_kapitalowy

Below is a link to the ODR platform, an access point for consumers who want out-of-court dispute resolution in connection with the conclusion of an online contract for the use of transaction and information service provided by ProService Finteco Sp. z o.o .:

https://webgate.ec.europa.eu/odr/main/?event=main.home.show

Insofar as they bind you to ProService Finteco Sp. z o.o. the agreements provide for the possibility of out-of-court resolution of any disputes before the Arbitration Court at the Polish Financial Supervision Authority; we provide a relevant link:

https://www.knf.gov.pl/dla_konsumenta/sad_polubowny/informacje_ogolne