1. INTRODUCTION

Admar SCR, SA (“Company”) is a private equity firm, authorized to manage Alternative Investment (“OIA”). The Company is dedicated to the highest standards of ethics and quality and commits itself every day to always doing what is right for the company, its employees, its customers and the community.

The Company, always committed to transparent communication, has established this Complaints Mechanism Policy (“Policy”), through which it is intended to define the principles adopted by the Company, within the framework of its relationship with customers or third parties, at all stages.

This Policy was drawn up in accordance with the applicable provisions and regulations, ensuring that processes are handled diligently, effectively and impartially, in resolving situations and with diligent and rigorous action.

2. SCOPE

This Policy applies to all employees, counterparties, clients, and investors of the Company.

3. PRINCIPLES OF COMPLAINTS MECHANISM POLICY

The Company is committed to upholding the principles of transparency, diligence, fairness, and timeliness in handling and managing complaints submitted by clients, CMVM (Portuguese Securities Market Commission), or other entities (“Complainants”).

The complaints management function is exercised by the Company’s Office Manager, who serves as the central point for receipt and response, ensuring full accessibility for complainants, impartial analysis, and mitigation of any conflicts of interest.

The Company guarantees the provision of clear, complete, and accurate information, tailored to the complainant’s profile and to the complexity of the situation. The complaints management process, including submission, handling, and response, is free of charge.

Confidentiality of complainants’ data, the content of complaints, and the specific circumstances is ensured, preventing unauthorized access by third parties.

4. COMPLAINTS PROCESS AND CHANNELS

4.1 Procedures for Complaints and Handling

The complaints management function is exercised by the Office & Human Resources Management Unit, through the Office Manager, who analyses complaints and related data. The Office Manager may escalate matters to the Compliance Officer.

Once a complaint is received, the Office Manager records and forwards it to the appropriate person for review, preparation of a proposed resolution, and draft response.

Complaints handling is free of charge. Complaints are assessed impartially by a person other than the one responsible for the act in question, and answered clearly and promptly, generally within 15 business days.

If an extension of up to 7 additional business days is required due to complexity, the Compliance Officer and the Board of Directors will be informed immediately.

All complaints and responses are archived by the Office Manager for 5 years.

The Office Manager and Compliance Officer may provide information on complaints to the CMVM or other competent authorities upon request.

If the complaint is not resolved, or the complainant considers it insufficiently addressed, and the matter involves an amount up to EUR 30,000, the complainant may resort to the Alternative Dispute Resolution (ADR) mechanism.

4.1.1 Alternative Dispute Resolution (ADR)
Regardless of the Company’s internal complaints procedure, complainants may submit disputes involving amounts up to EUR 30,000 to ADR.
The following ADR centers are available:
Lisbon
Porto
Coimbra
Guimarães
Braga / Viana do Castelo
Algarve
Madeira

4.2 Minimum Content of a Complaint
A complaint must include at least:
Full name of the complainant and, if applicable, representative;
Identification of complainant’s capacity (e.g., client, participant, investor);
Tax Identification Number (NIF);
Email and/or postal address;
Name of the product (AIF) concerned;
Description of facts, parties involved, and date of occurrence (if possible);
Date and place of the complaint.

4.3 Channels for Submitting Complaints
By email: geral@admarscr.pt
By post: Admar SCR, S.A.
Attn.: Office Manager – Administrative, Finance & HR Unit

Avenida de São Pedro, 33, Monte Estoril, 2765-446 Estoril

5. APPROVAL, DISCLOSURE AND EVALUATION
This Policy was approved by the Board of Directors and disseminated internally to all employees. It must be published on the Company’s website. Upon request, a copy may be provided to interested parties. The Compliance Officer and the Board of Directors are responsible for evaluating its effective application.

6. DOCUMENT CONTROL INFORMATION
Valid from: September 28, 2026
First version: June 28, 2024
Current version: September 29, 2025