Summary of Investor Rights

This is a summary of rights for Luxembourg-domiciled funds managed by AFFM SA (the “Company”) including the Alken Fund SICAV, afforded to you as an investor whose name appears on the share/unit register of a collective investment scheme managed by the Company (the “Funds”).

This summary of investor rights is prepared in relation to Regulation (EU) 2019/1156 of the European Parliament and of the Council of June 20, 2019 on facilitating cross-border distribution of collective investment undertakings and amending Regulations (EU) No 345/2013, (EU) No 346/2013 and (EU) No 1286/2014 (the “Regulation”). One of the objectives of the Regulation is to ensure that investors are provided with a summary of investor rights resulting from their investment in an undertaking for collective investment in transferable securities (“UCITS”) within the meaning of Directive 2009/65/EC or, under certain circumstances, in an alternative investment fund (“AIF”) within the meaning of Directive 2011/61/EU.

The summary is not intended to be an exhaustive list of all rights that you as an investor may have in respect of the Funds. Should you require further details, please refer to the prospectus, offering memorandum, articles of incorporation and/or management regulations of the relevant Fund or contact the Company. The below summary in English is also available in other languages upon request.

1) Entitlement to receive certain information relating to your investment

As an investor you have the right to receive from AFFM and/or the Funds the information that AFFM is legally required to publish. This includes:

• a copy of the prospectus or pre-contractual disclosure document of the Funds
• a copy of the articles of incorporation, management regulations of the Funds
• a copy of the latest annual and, if available, semi-annual financial statements of the Fund
• the Key Investor Information Document or Key Investor Document
• the latest net asset value per share/unit of a Fund
• Information about Engagement Policy / Proxy Voting / Voting Rights Policy
• Information about Conflicts of Interest Policy
• Information about Best Execution Policy
• Information about Remuneration Policy
• Complaints Handling Procedures
• Information about SFDR / Sustainability Risk / ESG Policies

This information is accessible on our website or will be made available to you on request and free of charge by contacting AFFM and/or the relevant central administration agent of the Fund.

Where applicable, you may request certain key documents (including the KIID or KID) in a language customary in your EEA country of residence.

As an investor, your right of information shall be guaranteed, and any material changes to certain information contained in the prospectus provided to you before you invested shall be notified to you in accordance with applicable regulatory requirements.

2) Entitlement to redeem your investment and receive dividend distributions

Investors are entitled to redeem their investment and receive the redemption proceeds relating to their shares/units within the timeframe and subject to the provisions detailed in the prospectus and the constitutive documents of the relevant collective investment scheme.

Depending on the type of shares/units subscribed, investors may be entitled to receive dividends, within the timeframe and subject to such conditions detailed in the relevant prospectus and constitutive documents.

Where permitted by the prospectus, investors may request the conversion (or switching) of their holding into another sub-fund or share class, subject to applicable terms.

Following any subscription, redemption, or conversion order, you are entitled to receive a confirmation detailing the transaction price, number of shares/units and settlement amount.

3) Voting rights and related matters

Save to the extent that an investor has chosen to invest in shares/units which do not carry voting rights, an investor has the right to vote (whether at an ordinary or extraordinary general meeting or, where so permitted under the relevant constitutive documents, by way of a written resolution) on resolutions relating to the relevant collective investment scheme, sub-fund or share/unit class thereof in accordance with the conditions set down in the relevant prospectus and constitutive documents.

Investors shall also be entitled to be treated fairly and equally, within the timeframe and subject to such conditions detailed in the relevant documentation, in case of liquidation of the relevant collective investment scheme, sub-fund or share/unit they are invested in.

No preferential treatment shall be granted to any investor unless such treatment is clearly disclosed in the relevant documentation and does not prejudice other investors.

4) Entitlement to make a complaint

As an investor, you are entitled to file a complaint free of charge. Any such complaint must be handled by AFFM SA or its delegates promptly and effectively.

Further information on AFFM SA complaints policy is available at https://www.alken-fund.com in the Documents section and/or at https://www.affm.lu in the Literature section.

Should you not be satisfied with the outcome or handling of your complaint, you may escalate the matter to the Commission de Surveillance du Secteur Financier (“CSSF”) under the out-of-court complaint resolution procedure (CSSF Regulation CSSF 16-07). Complaints must be filed within one year of your original complaint to AFFM. You also retain the right to pursue legal action in the courts at any time.

5) Investor rights against the relevant collective investment scheme and its service providers

As an investor, you have a right of action against the collective investment scheme of which you are an investor for any breach of contract.

Should you not be satisfied with the outcome or handling of your complaint, you may escalate the matter to the Commission de Surveillance du Secteur Financier (“CSSF”) under the out-of-court complaint resolution procedure (CSSF Regulation CSSF 16-07). Complaints must be filed within one year of your original complaint to AFFM. You also retain the right to pursue legal action in the courts at any time.

investment scheme in respect of: (i) any loss of an asset held in custody of the depositary or its delegates; or (ii) any other losses resulting from the depositary’s negligence or intentional failure to properly fulfil its obligations. Such action must not lead to a duplication of redress or to unequal treatment of investors.

6) Right to Data Privacy

As an investor, you have provided or will provide information to AFFM which may constitute personal data within the meaning of applicable data protection legislation (in particular, EU Regulation 2016/679 – the “GDPR”).

Please be aware that this personal data may be processed in accordance with its Privacy Policy, the current version of which is available on https://www.alken-fund.com and https://www.affm.lu.

You have the right to access, rectify, erase or restrict the processing of your personal data, the right to object to its processing, the right to data portability, and the right to lodge a complaint with the Luxembourg data protection authority, Commission nationale pour la protection des données (“CNPD”).

7) Terminate marketing arrangements within EU member states

The Funds may have been notified for distribution in different EU member states. Investors are hereby informed that AFFM may decide to terminate marketing arrangements regarding the distribution of its collective investment undertakings under the EU de-notification process.

The termination of such arrangements will not entail costs to investors, nor will it diminish their right to receive accurate information on the Funds’ continued activities.

8) General

Any person who would like to receive further information regarding the strategy followed for the exercise of voting rights of the relevant Fund, the conflict-of-interest policy, the best execution policy and the complaints handling procedure of AFFM SA can find this information on the websites listed above or may request it directly from AFFM.

It should be noted that this summary addresses rights conferred on investors under the applicable legislation governing the operation of the Fund in which you are invested. You may also be afforded rights under other legislation or regulatory frameworks which are not addressed above, including for example, your rights as a data subject under GDPR.

This summary may be updated from time to time and the most recent version is published on our website. The latest English version shall prevail in the event of discrepancies. Translations are available upon request.

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