This complaint-handling policy applies to all customers of Northstake A/S and its subsidiaries.

Northstake commits to handling all complaints promptly and to resolve complaints as soon as practicable within a reasonable period of time.

When considering and reviewing complaints raised by customers, Northstake shall:
- identify and remedy any recurring or systemic problems;
- analyse the causes of complaints so as to identity common root causes of complaints;
- consider whether such root causes may also affect other processes, services or products, including those not directly complained of; and
- correcting all such root causes.

Northstake commits to the following:
- Northstake shall acknowledge all complaints within one week of the complaint being made; and
- Northstake shall resolve all complaints within four weeks of the complaint being made, except in extraordinary circumstances in which case Northstake commits to providing the client with an update on the status of the complaint, and explain the extraordinary circumstances delaying its resolution, within four weeks of the complaint being made and shall resolve the complaint no later than eight weeks from when the complaint was made.

Clients may always raise a complaint through their usual contact at Northstake.

Alternatively, a form for filing a complaint concerning services provided by Northstake is available at the following link: https://www.northstake.dk/schedule-a-call or alternatively may be sent by e-mail to the following e-mail address: info@northstake.dk.

Clients must ensure to provide: (a) details of full name, along with (b) reasonable details of the transaction or interaction concerning the complaint.

No fees or any other form of payment are required to be made to raise a complaint with Northstake or in connection with the consideration of a complaint by Northstake.

Northstake commits to keeping records of the following:
- all complaints received from customers of Northstake;
- all measures taken in response to such complaints; and
- the resolution of all complaints.

If clients have any questions about this policy or they feel that a complaint has not been adequately addressed, they can write to: compliance@northstake.dk.

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1  Purpose of the policy

The purpose of this policy is to outline Northstake’ssetup with regards to both whistleblowing in accordance with the Danish AML Act(in Danish: hvidvaskloven) §§ 35 and 36 including the WhistleblowerProtection Act (in Danish: Lov om beskyttelse af whistleblowere) andwhistleblowing regarding all other types of incidents that are not related tothe current Danish AML Act. Additionally, this policy provides essentialbackground information for any Northstake employee who sees the need in blowingthe whistle on any type of incident.

2 Definition

A whistleblower could be any person in theorganisation of Northstake disclosing information about any wrongdoing, whichcould be in the form of fraud, corruption or breaches of the AML regulation,the person acquires through the person’s work-related activities.

2.1 Background information onwhistleblowing regarding AML related incidents

Since February 2022 Northstake has beenregistered with the Danish FSA (in Danish: Finanstilsynet) and iscovered by the Danish AML Act §§ 35 and 36 and is therefore obliged to put ascheme in place which enables Northstake’s employees to submit reports onviolations or potential violations of the AML regulations anonymously and to thewhistleblower responsible at Northstake (rev). Additionally, Northstake shallnot expose the employee or former employee to unfavorable treatment or adverseeffects as a result of reporting a violation or potential violation of the AMLregulation.

2.2 Background information onwhistleblowing regarding all other incidents

Northstake is committed to the higheststandards of openness, probity, and accountability. An important aspect ofaccountability and transparency is a mechanism to enable staff and othermembers of the company to voice concerns in a responsible and effective manner.It is a fundamental term of every contract of employment that an employee willfaithfully serve his or her employer and not disclose confidential informationabout the employer’s affairs. Nevertheless, where an individual discoversinformation which they believe shows serious malpractice or wrongdoing withinthe organisation then this information should be disclosed internally withoutfear of reprisal, and there should be arrangements to enable this to be doneindependently of line management (although in relatively minor instances theline manager would be the appropriate person to be told).

The list below provides exemplaryincidents which are not necessarily related to violations of the AMLregulation:

-     Financialmalpractice or impropriety or fraud

-     Dangersto Health & Safety or the environment

-     Criminalactivity

-     Improperconduct or unethical behaviour

-     Attemptsto conceal any of these

The Whistleblower Protection Act giveslegal protection to employees against being dismissed or penalised by theiremployers as a result of publicly disclosing certain serious concerns. Northstakehas endorsed the provisions set out below to ensure that no members of staffshould feel at a disadvantage in raising legitimate concerns.

Please note that other incidents such asbreach of internal guidelines on sick leave, smoking or similar is not coveredby the whistleblower program. This should be reported to HR or your directmanager.

3  Safeguards regarding blowingthe whistle on incidents related to the current AML regulation

3.1 Protection

All employees who are blowing the whistleon incidents which relate to violations or potential violations are protectedunder § 36 of the Danish AML Act. This means that Northstake shall not exposethe employee or former employee to unfavorable treatment or adverse effects asa result of reporting violations or potential violations of the AML act.

3.2 Anonymity

Under § 35 of the Danish AML Act Northstakeis obliged to ensure that violations or potential violations of the AMLregulation can be reported anonymously.

4 Safeguards regarding blowingthe whistle on incidents which are not related to current AML regulation

4.1  Protection

This policy is designed to offerprotection to those employees of Northstake who disclose such concerns providedthe disclosure is made:

-     ingood faith

-     inthe reasonable belief of the individual making the disclosure that it tends toshow malpractice or impropriety and if they make the disclosure to anappropriate person (see below). It is important to note that no protection frominternal disciplinary procedures is offered to those who choose not to use theprocedure. In an extreme case, malicious or wild allegations could give rise tolegal action on the part of the persons complained about.

4.2 Confidentiality

Northstake will treat all such disclosuresin a confidential and sensitive manner. The identity of the individual makingthe allegation may be kept confidential so long as it does not hinder orfrustrate any investigation. However, the investigation process may reveal thesource of the information and the individual making the disclosure may need toprovide a statement as part of the evidence required.

4.3 Anonymous Allegations

This policy encourages individuals to puttheir name to any disclosures they make. Concerns expressed anonymously aremuch less credible, but they may be considered at the discretion of Northstake.In exercising this discretion, the factors to be taken into account willinclude:

-     Theseriousness of the issues raised

-     Thecredibility of the concern

-     Thelikelihood of confirming the allegation from attributable sources

4.4 Untrue Allegations

If an individual makes an allegation ingood faith, which is not confirmed by subsequent investigation, no action willbe taken against that individual. In making a disclosure the individual shouldexercise due care to ensure the accuracy of the information. If, however, anindividual makes malicious or vexatious allegations, and particularly if he orshe persists with making them, disciplinary action may be taken against thatindividual.

5 Procedure for making adisclosure

A guide for filing a complaint is attachedand can be found at the end of this policy.

On receipt of a complaint of malpractice,the Chairman of the Board who receives and takes note of the complaint, mustpass this information as soon as it is reasonably possible, to the appropriatedesignated investigating officer as follows:

-     Complaints of malpractice will be investigated by the appropriate Director unless thecomplaint is against the Director or is in any way related to the actions ofthe Director. In such cases, the complaint should be passed to the ChiefExecutive / Business Owner for referral.

-     In the case of a complaint, which is any way connected with but not against theDirector, the Chief Executive / Business Owner will nominate a Senior Manageror external party to act as the alternative investigating officer.

-     Complaints against the Chief Executive / Business Owner should be passed to the Chairmanwho will nominate an appropriate internal / external investigating officer.

-     The Chairman has the right to refer the complaint back to management if he/shefeels that the management without any conflict of interest can moreappropriately investigate the complaint.

-     In case of a complaint about a violation or potential violation of AMLregulations, the Chairman of the Board will conduct and lead the investigation.

Should none of the above routes besuitable or acceptable to the complainant, then the complainant needs toevaluate if other channels of escalation are more appropriate.

If there is evidence of criminal activitythen the investigating officer should inform the competent authorities. Northstakewill ensure that any internal investigation does not hinder a formal policeinvestigation.

6 Timescales

Due to the varied nature of these sorts ofcomplaints, which may involve internal / external investigators and / or thecompetent authorities, it is not possible to lay down precise timescales forsuch investigations. The Chairman of the Board should ensure that theinvestigations are undertaken as quickly as possible without affecting thequality and depth of those investigations.

The Chairman of the Board should as soonas practically possible, send a written acknowledgement of the concern to thecomplainant and thereafter report back to them in writing the outcome of theinvestigation and on the action that is proposed. If the investigation is aprolonged one, the Chairman of the Board should keep the complainant informed,in writing, as to the progress of the investigation and as to when it is likelyto be concluded. All responses to the complainant should be in writing.

7 Investigating procedure

The Chairman of the Board should followthese steps:

-     Fulldetails and clarifications of the complaint should be obtained.

-     TheChairman of the Board should inform the member of staff against whom thecomplaint is made as soon as it is practically possible. The member of staffwill be informed of their right to be accompanied by a trade union or workcolleague at any future interview or hearing held under the provision of theseprocedures. At the discretion of the Chairman of the Board and dependent on thecircumstances of the complaint an alternative representative may be allowede.g. the individual’s legal representative.

-     TheChairman of the Board should consider the involvement of Northstake’s legaladvisor or accountant and the competent authorities at this stage.

-     Theallegations should be fully investigated by the Chairman of the Board with theassistance, where appropriate, of other individuals / bodies.

-     Ajudgement concerning the complaint and validity of the complaint will be madeby the Chairman of the Board. This judgement will be detailed in a writtenreport containing the findings of the investigations and reasons for thejudgement.

-     TheChairman of the Board will decide what action to take. If the complaint isshown to be justified, then they will invoke the disciplinary or otherappropriate company procedures.

-     Thecomplainant should be kept informed of the progress of the investigations and,if appropriate, of the final outcome.

-     Ifappropriate, a copy of the outcomes will be used to enable a review of companyprocedures.

If the investigation finds the allegationsunsubstantiated and all internal procedures have been exhausted, but thecomplainant is not satisfied with the outcome of the investigation, Northstakerecognises the lawful rights of employees and ex-employees to make disclosuresto prescribed persons or body. Incidents which are not related to the currentAML regulations, could for instance be reported to the HR Executive. Incidentswhich are relation to the AML regulations, could be reported to the Danish FSA.

8 Review of the Policy

The policy will be reviewed at least oncea year by Northstake’s MLRO.

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9 anonymous complaint

How to file an annonymous complaint:

1      Go to your email client or if anonymous go to: https://www.5ymail.com/

2     Enter recipient: whistleblower@northstake.com

3     Fill out the Subject field and Body of the email with the complaint/report

4     Submit

5     Theemail will be directly sent to Chairman of the Board.

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