1. Purpose

The purpose of this procedure is to regulate the activity and operation of the complaints and claims service of ADVENTUREES CAPITAL PFP, S.L. (hereinafter ADVENTUREES).

2. Scope of application

All complaints and claims that are directly related to the operation of ADVENTUREES will be subject to this procedure.

3. Scope of Action

It is the responsibility of the Administration Department of ADVENTUREES to investigate and process the complaint or claim presented by the Users, which will be resolved by the Director of the company.

4. Conflict of interest

In those complaints or claims in which the Director of the company has a personal interest or may produce a conflict of interest, the Director of the company will refrain from participating in the processing or resolution of such complaint or claim, and its resolution will correspond to the person who holds the position of head of the Administration Analysis area.

Likewise, when any of the members of ADVENTUREES has a personal interest or may produce a conflict of interest, he/she will abstain from participating in the processing or in the proposed resolution of the same.

5. Subjective scope

All Users who have effectively registered on the ADVENTUREES Website will be able to present a complaint and/or claim.

1. Deadline for submission

The time limit for the presentation of a complaint or claim will be two (2) months from the moment the affected User has knowledge of the facts that cause the complaint or claim.

2. Presentation of the complaint or claim

The presentation of the complaint or claim will be made preferably by electronic means, as long as it allows the reading, printing and conservation of the documents that support the complaint or claim, by sending it to the email address: quejasyreclamaciones@adventurees.com If not, this can be done in person or by means of representation on paper at any of the ADVENTUREES offices.

The procedure will be deemed to have been initiated by the presentation of the Complaints Document whose standardized template can be downloaded from the following link:

(pages 64 to 70 of the ESMA form): esma35-42-1183_final_report_-_ecspr_technical_standards.pdf (europa.eu)

The User concerned may attach to his letter any documentation in their possession that substantiates their complaint or claim.

Complaints and documentation must be submitted in Spanish or English.

The submission and processing of complaints is free of charge.

3. Acceptance of the complaint or claim

Once the complaint or claim has been received by the Administration Department of ADVENTUREES, a written acknowledgement of receipt will be sent to the interested party, stating the date of submission and providing the contact details of the Department to which the interested party can direct any questions regarding the complaint or claim and an indicative timeframe for resolution, and will proceed to open the corresponding file, whose acceptance or rejection will be confirmed within a maximum period of 10 working days.

Once the complaint or claim has been initially analyzed, if the identity of the complaining User is not sufficiently accredited or if the facts that are the subject of the complaint or claim cannot be clearly established, the User will be requested to complete the information or documentation submitted within a period not exceeding ten (10) calendar days, after which time the complaint or claim will be filed without further processing if the required information has not been submitted.

Complaints or claims may be rejected in the following cases:

1. When essential data for processing are omitted and are not corrected within the period provided in the preceding paragraph, including cases in which the reason for the complaint or claim is not specified.
2. When the facts and request that specify the issues that are the subject of the complaint or claim do not refer to specific projects or operations or do not fall within the scope of this procedure.
3. When the term granted for the presentation of the complaint or claim has elapsed.
4. When complaints or claims are reiterated by the same User in relation to the same facts already resolved previously.
5. When it is intended to process as a complaint or claim matters that correspond to other jurisdictions or have been resolved in other instances.

In the event that the admission of the complaint or claim is rejected, this decision shall be noted on the complaint or claim form, duly justified, and the complainant User shall be informed of the conclusion of the complaint or claim filed, explaining the reasons or criteria that led to this decision (in the case of a claim, communications shall be made in writing). The User will have a period of ten (10) calendar days to present their allegations and if after this period the affected User has not answered or the causes of inadmissibility continue, the complaint or claim will be closed and filed accordingly.

4. Instruction and resolution of the file

Once all the necessary information has been gathered for the study of the complaint or claim presented by the User, and in the case that it is not an easily solved problem that can be resolved quickly, it will be transferred to the ADVENTUREES Department directly involved so that they can make a report of the claim, determining, if necessary, the most appropriate actions to resolve the complaint or claim, documenting and planning them, coordinating the activities that are necessary for this. If, due to exceptional circumstances, it is found that the indicative resolution deadline initially provided cannot be met, the User will be informed of the reasons for the expected delay, as well as a new estimated resolution deadline.

The report and the proposed measures, if necessary, for the solution of the complaint or claim will be sent to the Director of ADVENTUREES, who will study the report and resolve the complaint or claim.

The User will be informed of the resolution of the Director of ADVENTUREES as well as in the case of being approved, the proposed measures to respond to your complaint or claim and the estimated time to carry them out.

5. Execution of the defined actions

Once the measures to be taken to respond to the complaint or claim presented, the execution will be carried out according to the defined plan, notifying the interested User of its completion. If the interested User is satisfied with the measures taken, the complaint or claim is closed (noting the date of resolution and attaching the documentation generated, if applicable) and filed as appropriate. Otherwise, the User concerned will have to analyze the reasons for his disagreement and if they are legitimate, design new actions for the resolution of the problem according to the procedure describe.

6. Withdrawal

The complainant User may withdraw their complaint or claim at any time, resulting in the immediate termination of the procedure and its archiving.

7. Completion and notification

The file must be finalized within a maximum period of two (2) months from the date on which the complaint or claim was filed.

The resolution will always be reasoned and will answer the issues raised in the complaint or claim filed.

The resolution will be notified to the interested Users within ten (10) calendar days from its date, in writing or by computer means, depending on the means used for the presentation of the complaint or claim or that which has been notified for communication with ADVENTUREES in said file.

8. Registration

ADVENTUREES will keep a record of all complaints received and actions taken.