Whistleblowing complaints

Modus Asset Management UAB (the Company) seeks to conduct its activities responsibly, ethically, openly and transparently. The Company believes that such responsible and transparent conduct benefits not only the Company, the collective investment undertakings (Funds) it manages, but also all stakeholders.

The Company enables and encourages employees (current and former) of the Company and companies controlled by the Funds, their family members, service providers or other parties to (pre)contractual relationships, members of management bodies, any other persons working under the supervision of the contractors of the Company / companies controlled by the Funds (Whistleblowers) to report actual or potential violations of legislation, internal policies and procedures, Code of Business Ethics without fear of any adverse consequences.

For more information about the procedure for providing, receiving, registering, evaluating and making decisions on violations disclosed in Whistleblowers’ reports can be found in:

Complaints of other persons (who do not fall under the definition of Whistleblowers provided above) shall be submitted and examined in accordance with the Information on the Submission and handling of Complaints.

Whistleblower’s report may be provided at the choice of the Whistleblower:

By anonymous reporting channel (see the electronic form of Whistleblower’s report provided below)
By e-mail pranesimai@modusam.com
Orally or in writing directly to the person responsible for handling of Whistleblowers’ reports (Compliance Officer of the Company, aldona.leksaite@modusam.com +37061692542) if the report is related / submitted due to the violation performed by the Compliance Officer of the Company.
Orally or in writing directly to the CEO (povilas.peciulis@modusam.com) or the Chairman of the Board of the Company (oleg.martyniuk@modus.group)

Details of the person reporting the breach

Name, last name (optional)

Personal code (optional)

Relationship with the company for which the breach is reported (employment relationship, contractual relationship, etc.) (optional)

Position (optional)

Telephone No. (optional)

Personal email or home address (optional)

Information about the violation

1. What violation are you reporting? What kind of violation it is?

2. Who made the violation? What might have been the person’s motives for committing the violation?

3. Place and time of the violation, when have you first noticed the violation?

Details of the person or persons who committed the violation

Name, last name

Workplace

Position

4. Are there other people who were involved or could have been involved in the violation? If so, please specify who they are.

5. Are there other witnesses to the violation? If so, provide their contact details.

Details of the witnesses of the violation

Name, last name

Position

Workplace

Telephone No.

6. What documents could you provide to support the investigation of the infringement? Please provide attached written or other details of the violation.

7. Have you already reported this violation to somebody else? If so, whom have you reported and have you received an answer? If you have received an answer, please indicate the essence of the answer.

8. Additional remarks and comments.

I confirm that I am familiar with the legal consequences of providing false information in the whistleblower protection policy of UAB Modus Asset Management, and that the information I provided is correct

Please do not provide me with any information on the examination of this report.

I confirm that I am familiar with UAB "Modus Asset Management" privacy notice and information about the processing of my personal data.