Complaint Management Policy

1. 1.1.Kudy Financials LLC (“the Company”, or “Kudy”) is committed to providing the highest standard of services to its Stakeholders.
2. 1.2.Kudy acknowledges that complaints are a common occurrence in all Stakeholders' business engagement. Kudy further recognises the right of any person covered under this compliance management policy (“Policy”) to raise an issue or make a complaint in the course of their dealing with Kudy and shall ensure that their complaints are dealt with in an efficient, responsive, impartial and courteous manner.
3. 1.3.A complaint is a written expression of dissatisfaction (justified or not) made about the standard of services, act or omission of Kudy affecting an individual client or group of clients, and which requires a response.
4. 1.4.The services concerned include fund management, fund performance, legal, contractual or commercial documentation, and relate to all products and services marketed and/or managed by Kudy.
5. 1.5.For the avoidance of doubt, the following shall not constitute a complaint under this Policy:
   • A request for information, clarification of services offered or provided.
   • Expression of expectations.
   • A request for benefits, which are part of the commercial negotiation and may give rise to deductions, discounts or exemptions granted by the entity concerned.
   • Complaints whose subject matter is being investigated by Competent Persons/Authorities or have been or are currently the subject of legal proceedings or arbitration, including an employee-related dispute.
6. 1.6.To be processed, a complaint must clearly state the reason for the dissatisfaction and include factual elements relating to a product or service offered by Kudy.

1. 2.1.Kudy undertakes to deal with any complaint following the following principles:
   • Transparency towards the client.
   • Objective, fair and harmonised handling of complaints.
   • Free access to the complaint-handling systems.
   • Processing time for a response appropriate to the complexity of the complaint.

1. 3.1.The Chief Compliance Officer (“CCO”) shall be responsible for handling all complaints received by Kudy. In this context, Complaints should be in writing and addressed to the Chief Compliance Officer at compliance@kudy.us.
2. 3.2.The CCO shall be responsible for ensuring that the proper process for managing complaints is followed and for monitoring compliance.
3. 3.3.The CCO shall designate an Officer to assist him/her in the discharge of these responsibilities.
4. 3.4.A copy of this Policy shall be made freely available on Kudy’s Website.

1. 4.1.Receipt and Acknowledgement
   • 4.1.1.Upon receipt of a Complaint, the Complaint will be recorded in the Complaint Register by the Compliance Officer.
   • 4.1.2.Receipt of an electronic Complaint via email shall be acknowledged as soon as possible (not exceeding 3 (three) working days from the date of receipt), whilst a Complaint received by post shall be acknowledged within 5 (five) working days from the date of receipt.
   • 4.1.3.Where a Complaint is resolved within the time frame for acknowledging complaints as set out in clause 4.1.2 above, and the response containing the decision regarding the Complaint sent to the Complainant (this means a person, organization or their legal representative who makes the complaint), this will be deemed to be sufficient acknowledgement and resolution of the Complaint.
   • 4.1.4.Sufficient records of Complaints received by email and the respective email acknowledging and records of complaints received and resolved via physical or post office box address shall be available to the SEC when required. Evidence of posting a response to the complaint shall be deemed sufficient proof that the Complaint received attention from Kudy.
2. 4.2.Resolving a Complaint
   • 4.2.1.The CCO shall have the capacity to investigate and take all reasonable steps to resolve complaints and to implement appropriate remedies as may be deemed required.
   • 4.2.2.Upon resolution of a complaint, the outcome shall be communicated to the Complainant, and the Compliance Officer shall record the decision in the Complaint Register.
   • 4.2.3.Where a Complainant is dissatisfied with the decision reached by Kudy, the Complainant may, if he/she so wishes, refer the complaint to a Competent Authority (means Self-Regulatory Organization (“SRO”) and/or Capital Market Trade Association).
3. 4.3.Timing of Complaint Resolution
   • 4.3.1.All complaints received shall be resolved and a final response sent to the Complainant within one (1) month of it being received by Kudy.
   • 4.3.2.Where Kudy is unable to resolve a particular complaint within the stipulated timeline above, the Complainant shall have the right to refer the Complaint to a Competent Authority.
   • 4.3.3.You, as Kudy’s client, shall be responsible for obtaining and maintaining all telephone, computer hardware, software, and other equipment needed to access and use this Website. Access to this Website may from time to time be unavailable, delayed, limited or slow due to, among other things, an overload of system capacities.

1. 5.1.Kudy shall maintain a Complaint Register, which shall be in an electronic form. The Complaint Register shall contain the following:
   
   
   1. Name of the Complainant
   2. Date the complaint was received
   3. Nature and description of the complaint
   4. Summary of the complaint
   5. Supporting documents, if any
   6. Decision/resolution made
2. 5.2.Copies of letters and memos sent, including any update letters, acknowledgement letters, and response/resolution documents, shall form part of the complaint management record that shall be kept in accordance with Kudy Document Management Policy.

Any improper use of the Complaint process by way of malicious accusations shall not be tolerated, and appropriate actions shall be taken within the confines of the law.

The identity of the Complainants shall be kept strictly confidential except where the concern raised is criminal and requires legal proceedings. However, Kudy will, to the best of its ability, ensure that the Complainant is protected from any form of retaliation, victimisation or retribution.

The CCO shall monitor the resolution status of all complaints and provide a quarterly report of complaints received and their status, independently verified by the Internal Audit, to Kudy’s Management Committee. The report shall serve as a monitoring tool which shall enable the Management Committee to monitor the effectiveness of Kudy’s complaint-handling procedure, other related policies and/or procedures and identify relevant trends (if any) which could indicate areas for future focus or improved performance.

This Policy shall be published on Kudy’s Website together with the details of the contact person(s) mentioned in clause 3 above and procedures described in clause 4 above.