(1)L2010 - 5%/10% FDI counterparty risk - Art. 43

(2)L2010 - 5%/10%/40% - issuer TS/

(3)L2010 - 35% TS/

(1)L2010 - 20% UCITS/UCI - Art. 48

(2)L2010 - significant influence - Art. 50

(2)L2010 - 10% borrowings on a temporary basis - Art. 52 L2010 - No uncovered sales - SIF - 30% issuer 38/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file - Money Market Fund regulation - ESMA guidelines (Eligibility/Diversification of collateral) - Breach of specific prospectus rules (Other) - Breach of specific prospectus rules (ESG/SFDR related) - Breach of other investment restriction rule (Please describe further in the field "Description and cause of the investment breach") In presence of simultaneous non-compliances with investment rules caused by the same transaction please indicate all investment breaches in the field “Description and cause of the non-compliance with investment rules” Description and cause of the non-compliance breDescription with investment rules Only if the answer to the question “prePreOrCompNotification” is “Complete notification”. Please provide a detailed description/explanation allowing the CSSF to have a good and clear understanding of the circumstances and reasons leading to the non-compliance with investment rules. Concrete measures/actions to correct the breMesuresActionsToCorrectErro Only if the answer to the question “prePreOrCompNotification” is non-compliance with investment rules r “Complete notification”. UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 39/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Please provide a detailed description/explanation allowing the CSSF to have a good and clear understanding of operations having permitted to correct the non-compliance with investment rules. Concrete corrective measures/actions breMesuresActionsDecided decided at the level of fund's organisation “Complete notification”. and control environment in order to avoid recurrence of the same kind of Only if the answer to the question “prePreOrCompNotification” is Please provide a detailed description/explanation allowing the CSSF non- to have a good and clear understanding of correction operations at compliance with investment rules the level of the Fund's organisation and control procedures/processes in order to avoid recurrence of comparable non-compliances with investment rules. Impact of the non-compliance with breImpact investment rules Only if the answer to the question “prePreOrCompNotification” is “Complete notification”. Please select the appropriate choice from the below list: Please provide a clear justification on the reason why the non-compliance breJustificationWithoutImpact - Loss - Gain - Without impact Only if the answer to the question “breImpact” is “Without impact”. with investment rules is to be considered as without impact UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 40/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Please indicate the currency of the sub-fund breCurrencySubfund Only if the answer to the question “breImpact” is not equals “Without impact”. Please select the appropriate choice from the below list: see Annex VII Amount of the impact expressed in the sub- breAmountImpactSubfundCurren Only if the answer to the question “breImpact” is not equals “Without fund currency cy impact” and “breCurrencySubfund” is not equals “EUR”. Amount of the impact in EUR breAmountImpact Only if the answer to the question “breImpact” is not equals “Without impact”. Please provide comprehensive details on the determination of the amount of the impact in the separate impact calculation file. A special audit report by the “REA” (réviseur d’entreprises agréé (approved statutory auditor)) must only be submitted to the CSSF for UCITS and UCI part II where the total compensation amounts exceeds 50,000 EUR or the amount for a single investor exceeds 5,000 EUR. Calculation method used for the breCalculationMethod determination of the impact Only if the answer to the question “breImpact” is not equals “Without impact”. Please select the appropriate choice from the below list: - UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 Economic method 41/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file For the economic method, please indicate the comparative breBenchmarkUsed benchmark/performance Accounting method Only if the answer to the question “breCalculationMethod” is “Economic method”. used Method applied breMethodApplied Only if the answer to the question “breCalculationMethod” is “Accounting method”. Please select the appropriate choice from the below list: Details concerning method applied or other breMethodAppliedDetails information / comments - LIFO - FIFO - Average cost - Other Only if the answer to the question “breImpact” is not equals “Without impact”. Please provide a detailed description/explanation allowing the CSSF to have a good and clear understanding Did the non-compliance with investment breCauseNavCalculationError rules cause a significant NAV calculation error Only if the answer to the question “breImpact” is not equals “Without impact”. Please select the appropriate choice from the below list: - UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 Yes 42/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file - No For each active non-compliance with the investment rules, it must be verified what impact the non-compliant transactions had on all NAVs that were calculated during the entire period of non-compliance. In the event that during the period of non-compliance, the impact of non-compliant transactions on a given NAV was greater than the applicable tolerance threshold, the resulting NAV calculation error must, in addition, be corrected in accordance with the rules of conduct laid down in Chapter 4 of Circular CSSF 24/

1. Please indicate the type of UCI breTypeUci Only if the answer to the question “breCauseNavCalculationError” is “Yes”. Please select the appropriate choice from the below list: UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 - UCITS or UCI PART II or SIF subject to the MMF Regulation - Bond UCITS - Mixed UCITS - Equity UCITS or other assets UCITS - Bond - UCIs Part II (for retail investors) - Mixed - UCIs Part II (for retail investors) - Equity - UCIs Part II (for retail investors) - Other assets - UCIs Part II or ELTIF (for retail investors) 43/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file - Other assets - UCIs Part II or ELTIF (for retail investors) applying different threshold based on derogation procedure - UCIs Part II, ELTIF, SIFs, SICARS, EuVECA and EuSEF (for well-informed or professional investors) Tolerance threshold applied (in %) breToleranceThreshold Only if the answer to the question “breCauseNavCalculationError” is “Yes”. The percentage must be between 0% and 5%
2. Details relating to the subsequent NAV calculation error Period of the NAV calculation error - Start breNavPeriodStartDate Date Period of the NAV calculation error - End “Yes”. breNavPeriodEndDate Date Period of the significant impact - Start Date Only if the answer to the question “breCauseNavCalculationError” is Only if the answer to the question “breCauseNavCalculationError” is “Yes”. breNavPeriodImpactStartDate Only if the answer to the question “breCauseNavCalculationError” is “Yes”. If, during the error period, days with significant impact alternate with days on which the impact was not significant, please indicate as the start date the first day of the significant NAV calculation error and as the end date the last day on which the error was significantly incorrect. UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 44/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file The individual sub-periods with a significant error do not need to be specified individually. Period of the significant impact - End Date breNavPeriodImpactEndDate Only if the answer to the question “breCauseNavCalculationError” is “Yes”. This date must be greater than or equal to “breNavPeriodImpactStartDate”. If, during the error period, days with significant impact alternate with days on which the impact was not significant, please indicate as the start date the first day of the significant NAV calculation error and as the end date the last day on which the error was significantly incorrect. The individual sub-periods with a significant error do not need to be specified individually. Impact of the NAV calculation error breNavImpact Only if the answer to the question “breCauseNavCalculationError” is “Yes”. Please select the appropriate choice from the below list: UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 - With impact - Without impact 45/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file In case no subscription or redemption requests have been processed during the error period, please select "without impact" Please provide a clear justification on the breNavJustificationWithoutImpac Only if the answer to the question “breNavImpact” is “Without reason why the NAV calculation error is to be t impact”. Amount to be indemnified to the sub-fund in breNavAmountIndemnifiedSubfu Only if the answer to the question “breNavImpact” is “With impact”. EUR nd considered as without impact (Please reference "0" if no compensation is required.) Please provide comprehensive details on the compensation amounts/percentage in the separate impact calculation file (impacts on subscription/redemption for respectively UCI and investors) in the relevant currencies. A special audit report by the REA must only be submitted to the CSSF for UCITS and UCI part II where the total compensation amounts exceeds 50,000 EUR or the amount for a single investor exceeds 5,000 EUR. Amount to be indemnified in cash to the breNavAmountIndemnifiedCashI investors in EUR (Please reference "0" if no nvestors compensation is required.) Only if the answer to the question “breNavImpact” is “With impact”. Please provide comprehensive details on the compensation amounts/percentage in the separate impact calculation file (impacts on subscription/redemption for respectively UCI and investors) in the relevant currencies. UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 46/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file A special audit report by the REA must only be submitted to the CSSF for UCITS and UCI part II where the total compensation amounts exceeds 50,000 EUR or the amount for a single investor exceeds 5,000 EUR. Amount to be indemnified by allocation of breNavAmountIndemnifiedUnitsI new units to the investors in EUR (Please nvestors reference "0" if no compensation is For Investors who received a corresponding number of shares as indemnification, please indicate the amount in EUR required.) Please indicate if indemnification amount for Only if the answer to the question “breNavImpact” is “With impact”. breNavSingleInvestor a single investor exceeds EUR 5,000 Only if the answer to the question “breNavAmountIndemnifiedCashInvestors” is greater than 5000 or “breNavAmountIndemnifiedUnitsInvestors” is greater than
3. Please select the appropriate choice from the below list: Maximum impact in % of the NAV breNavMaxImpactNav - Yes - No Only if the answer to the question “breNavImpact” is “With impact”. Please indicate for the NAV calculation error the highest percentage of the impact during the period "De minimis" amount applied breNavDeMinimisAmount Only if the answer to “breNavAmountIndemnifiedCashInvestors” is the question greater than “breNavAmountIndemnifiedUnitsInvestors” is greater than
4. UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 47/102 0 or Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Please select the appropriate choice from the below list: Please indicate the threshold level of the "De - Yes - No breNavDeMinimisThreshold Only if the answer to the question “breNavDeMinimisAmount” is “Yes”. breNavCurrency Only if the answer to the question “breNavDeMinimisAmount” is “Yes”. minimis" fixed in the internal procedures Please indicate the currency Please select the appropriate choice from the below list: see Annex VII
5. Details concerning the indemnification procedure Date of booking / recording of the provision breBookingDate (in the accounting of the UCI) Optional only if the answer to the question “breImpact” is “Loss” and “breCauseNavCalculationError” is “Yes”. Booking date of the indemnification amounts Sub-fund payment date breSubfundPaymentDate Only if the answer to the question “breImpact” is “Loss” or “breNavAmountIndemnifiedSubfund” is greater than
6. This date must be greater than or equal to “breDetectionDate” and “brePeriodEndDate” and “breNavPeriodImpactEndDate”. If the compensation payments were realized on different days, please indicate in this field, the last payment date. UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 48/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Investors payment date breInvestorsPaymentDate Only if the answer to “breNavAmountIndemnifiedCashInvestors” is the question greater than 0 or “breNavAmountIndemnifiedUnitsInvestors” is greater than
7. This date must be greater than or equal to “breDetectionDate” and “brePeriodEndDate” and “breNavPeriodImpactEndDate”. If the compensation payments were realized on different days, please indicate in this field, the last payment date. Total indemnification amount in EUR breTotalIndemnificationAmount Only if the answer to the question “breImpact” is “Loss” or “breNavImpact” is “With impact”. Please indicate the sum of all indemnification in EUR (indemnification to the (sub-)fund and/or investors) Other information / comments concerning breNavOtherInformation the non-compliance with investment rules, impact or indemnification calculation Optional only if the answer to the question “prePreOrCompNotification” is “Complete notification”. Please indicate here any other elements of relevance concerning the error/non-compliance as well as any specificities in the correction and impact calculation processes a.o. whether the financial impact has been determined using the compound method or the non-compound method. UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 49/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Entity(ies) responsible for the payment of breEntityResponsibleForPayment the indemnification amount UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 Only if the answer to the question “breImpact” is “Loss” “breNavImpact” is “With impact”. 50/102 or
8. Annex III – Synopsis on information to be transmitted for “Other errors - Incorrect application of swing pricing / other anti-dilution tool” *CSSF guidance: Please refer to annex VII for the code to be used in the notification for closed questions (Yes/No answers, or answers referring to a predefined list) Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Contact person email address contactPersonEmail The contact person must have an eDesk account linked to the notifying entity on eDesk. This person will receive the email in case of exchange of comments.
9. General information Complete or pre-notification ospPreOrCompNotification Please select the appropriate choice from the below list: - Complete notification - Pre-notification The CSSF expects a complete notification to be submitted, in principle, within 4 to 8 weeks of the detection of the incident. The pre-notification option can only be used on an exceptional basis in duly justified cases where the calculations and compensation processes necessary to correct the incorrect application of swing pricing / other anti-dilution tool are particularly complex and timeconsuming and thus do not allow entities to provide the CSSF, within 4 to 8 weeks, with a complete notification. UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 Internal/external reference (please check the options in the guide) or delete if not needed 51/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Please describe the incorrect application of ospPreNotificationDescription swing pricing / other anti-dilution tool AND Only if the answer to the question “ospPreOrCompNotification” is “Pre-notification”. justify why a pre-notification is necessary Please describe the typology, duration, and estimated impact of the incorrect application of swing pricing / other anti-dilution tool that occurred and provide all available details. Then, please provide a detailed justification allowing the CSSF to have a clear and thorough understanding of why the correction process of the investment allocation error cannot be finalized within 4 to 8 weeks and why the Fund is unable to submit a complete notification form with all the fields duly filled out.
10. Details relating to the incorrect application of swing pricing / other anti-dilution tool Detection date of the incorrect application of ospDetectionDate swing pricing / other anti-dilution tool Only if the answer to the question “ospPreOrCompNotification” is “Complete notification”. This date must be less than or equal to the reception date of the notification. Period of the incorrect application of swing ospPeriodStartDate pricing / other anti-dilution tool - Start Date Only if the answer to the question “ospPreOrCompNotification” is “Complete notification”. This date must be less than or equal to the reception date of the notification. Period of the incorrect application of swing ospPeriodEndDate pricing / other anti-dilution tool - End Date Only if the answer to the question “ospPreOrCompNotification” is “Complete notification”. This date must be greater than or equal to “ospPeriodStartDate”. UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 52/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Please specify the type of incorrect ospSwingFactorError application of swing pricing / other anti- Only if the answer to the question “ospPreOrCompNotification” is “Complete notification”. dilution tool Please select the appropriate choice from the below list: - Non-application of the swing factor as set for the UCI - Application of a swing factor that exceeds the factor set at the level of the UCI - Application of a swing factor that was insufficient compared to the factor set for the UCI - Other swing pricing error / other anti-dilution tool error In accordance with points 99 and 100 of CSSF Circular 24/856, this questionnaire applies to: - the swing pricing; - the anti-dilution levy; - the liquidity fees in order to reflect the cost of providing liquidity by a UCI; - commissions for the benefit of the UCI that charge investing and/or divesting investors the transaction costs, taxes or other elements, these commissions applying either as lump sum or on an individually calculated basis. Description and cause of the incorrect ospDescription application of swing pricing / other antidilution tool Only if the answer to the question “ospPreOrCompNotification” is “Complete notification”. Please provide a detailed description/explanation allowing the CSSF to have a good and clear understanding of the circumstances and UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 53/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file reasons leading to the incorrect application of swing pricing / other anti-dilution tool. Concrete corrective measures/actions ospMesuresActionsDecided decided at the level of fund's organisation Only if the answer to the question “ospPreOrCompNotification” is “Complete notification”. and control environment in order to avoid Please provide a detailed description/explanation allowing the CSSF recurrence of the same kind of the incorrect to have a good and clear understanding of correction operations at application of swing pricing / other anti- the level of the Fund's organisation and control procedures/processes dilution tool in order to avoid recurrence of comparable incorrect application of swing pricing / other anti-dilution tool. Loss to be indemnified to the sub-fund in EUR (Please reference "0" if ospLossIndemnifiedSubfund no Only if the answer to the question “ospSwingFactorError” is not equal “Application of a swing factor that exceeds the factor set at the level compensation is required.) of the UCI” Please provide comprehensive details on the compensation amounts/percentage in the separate impact calculation file (impacts on subscription/redemption for respectively UCI and investors) in the relevant currencies. A special audit report by the “REA” (réviseur d’entreprises agréé (approved statutory auditor)) must only be submitted to the CSSF for UCITS and UCI part II where the total compensation amounts exceeds 50,000 EUR or the amount for a single investor exceeds 5,000 EUR. Did the incorrect application of swing pricing ospCauseNavCalculationError / other anti-dilution tool cause a significant NAV calculation error Only if the answer to the question “ospPreOrCompNotification” is “Complete notification”. Please select the appropriate choice from the below list: - UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 Yes 54/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Please indicate the type of UCI ospTypeUci No Only if the answer to the question “ospCauseNavCalculationError” is “Yes”. Please select the appropriate choice from the below list: - UCITS or UCI PART II or SIF subject to the MMF Regulation - Bond UCITS - Mixed UCITS - Equity UCITS or other assets UCITS - Bond - UCIs Part II (for retail investors) - Mixed - UCIs Part II (for retail investors) - Equity - UCIs Part II (for retail investors) - Other assets - UCIs Part II or ELTIF (for retail investors) - Other assets - UCIs Part II or ELTIF (for retail investors) applying different threshold based on derogation procedure - UCIs Part II, ELTIF, SIFs, SICARS, EuVECA and EuSEF (for well-informed or professional investors) Tolerance threshold applied (in %) ospToleranceThreshold Only if the answer to the question “ospCauseNavCalculationError” is “Yes”. The percentage must be between 0% and 5%
11. Details relating to the subsequent NAV calculation error Period of the NAV calculation error - Start ospNavPeriodStartDate Date Period of the NAV calculation error - End Only if the answer to the question “ospCauseNavCalculationError” is “Yes”. ospNavPeriodEndDate Date UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 Only if the answer to the question “ospCauseNavCalculationError” is “Yes”. 55/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Period of the significant impact - Start Date ospNavPeriodImpactStartDate Only if the answer to the question “ospCauseNavCalculationError” is “Yes”. If, during the error period, days with significant impact alternate with days on which the impact was not significant, please indicate as the start date the first day of the significant NAV calculation error and as the end date the last day on which the error was significantly incorrect. The individual sub-periods with a significant error do not need to be specified individually. Period of the significant impact - End Date ospNavPeriodImpactEndDate Only if the answer to the question “ospCauseNavCalculationError” is “Yes”. This date must be greater than or equal to “ospNavPeriodImpactStartDate”. If, during the error period, days with significant impact alternate with days on which the impact was not significant, please indicate as the start date the first day of the significant NAV calculation error and as the end date the last day on which the error was significantly incorrect. The individual sub-periods with a significant error do not need to be specified individually. Impact of the NAV calculation error ospNavImpact Only if the answer to the question “ospCauseNavCalculationError” is “Yes”. Please select the appropriate choice from the below list: UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 - With impact - Without impact 56/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file In case no subscription or redemption requests have been processed during the error period, please select "without impact" Please provide a clear justification on the ospNavJustificationWithoutImpac Only if the answer to the question “ospNavImpact” is “Without reason why the NAV calculation error is to be t impact”. Amount to be indemnified to the sub-fund in ospNavAmountIndemnifiedSubfu Only if the answer to the question “ospNavImpact” is “With impact”. EUR nd considered as without impact (Please reference "0" if no compensation has occurred.) Please provide comprehensive details on the compensation amounts/percentage in the separate impact calculation file (impacts on subscription/redemption for respectively UCI and investors) in the relevant currencies. A special audit report by the REA must only be submitted to the CSSF for UCITS and UCI part II where the total compensation amounts exceeds 50,000 EUR or the amount for a single investor exceeds 5,000 EUR. Amount to be indemnified in cash to the ospNavAmountIndemnifiedCashI investors in EUR (Please reference "0" if no nvestors compensation is required.) Only if the answer to the question “ospNavImpact” is “With impact”. Please provide comprehensive details on the compensation amounts/percentage in the separate impact calculation file (impacts on subscription/redemption for respectively UCI and investors) in the relevant currencies. A special audit report by the REA must only be submitted to the CSSF for UCITS and UCI part II where the total compensation amounts exceeds 50,000 EUR or the amount for a single investor exceeds 5,000 EUR. UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 57/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Amount to be indemnified by allocation of ospNavAmountIndemnifiedUnitsI new units to the investors in EUR (Please nvestors reference "0" if no compensation is For Investors who received a corresponding number of shares as indemnification, please indicate the amount in EUR required.) Please indicate if indemnification amount for Only if the answer to the question “ospNavImpact” is “With impact”. ospNavSingleInvestor a single investor exceeds EUR 5,000 Only if the answer to the question “ospNavAmountIndemnifiedCashInvestors” is greater than 5000 or “ospNavAmountIndemnifiedUnitsInvestors” is greater than
12. Please select the appropriate choice from the below list: Maximum impact in % of the error ospNavMaxImpact - Yes - No Only if the answer to the question “ospNavImpact” is “With impact”. Please indicate for the NAV calculation error the highest percentage of the impact during the period De minimis amount applied ospNavDeMinimisAmount Only if the answer to the question “ospNavAmountIndemnifiedCashInvestors” is greater than 0 or “ospNavAmountIndemnifiedUnitsInvestors” is greater than
13. Please select the appropriate choice from the below list: Please indicate the threshold level of the "De ospNavDeMinimisThreshold minimis" fixed in the internal procedures Please indicate the currency - Yes - No Only if the answer to the question “ospNavDeMinimisAmount” is “Yes”. ospNavCurrency UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 Only if the answer to the question “ospNavDeMinimisAmount” is “Yes”. 58/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Please select the appropriate choice from the below list: see Annex VII
14. Details concerning the indemnification procedure Date of booking / recording of the provision ospNavBookingDate (in the accounting) Optional only if the “ospLossIndemnifiedSubfund” answer is to the question greater than 0 or “ospNavAmountIndemnifiedSubfund” is greater than
15. Booking date of the indemnification amounts Sub-fund payment date ospNavSubfundPaymentDate Only if the answer to the question “ospCauseNavCalculationError” is “Yes” and “ospNavAmountIndemnifiedSubfund” is greater than
16. If the compensation payments were realized on different days, please indicate in this field, the last payment date. Investors payment date ospNavInvestorsPaymentDate Only if the answer to the question “ospNavAmountIndemnifiedCashInvestors” is greater than 0 or “ospNavAmountIndemnifiedUnitsInvestors” is greater than
17. If the compensation payments were realized on different days, please indicate in this field, the last payment date. Total indemnification amount in EUR ospTotalIndemnificationAmount Only if the answer to the question “ospLossIndemnifiedSubfund” is greater than 0 or “ospNavImpact” is “With impact”. Please indicate the sum of all indemnification in EUR (indemnification to the (sub-)fund and/or investors) Other information / comments concerning ospNavOtherInformation the incorrect application of swing pricing / UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 Optional only if the answer to the “prePreOrCompNotification” is “Complete notification”. 59/102 question Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file other anti-dilution tool, impact or Please indicate here any other elements of relevance concerning the indemnification calculation error/non-compliance as well as any specificities in the correction and impact calculation processes a.o. whether the financial impact has been determined using the compound method or the non-compound method. Entity(ies) responsible for the payment of ospNavEntityResponsibleForPay Only if the answer to the question “ospLossIndemnifiedSubfund” is the indemnification amount ment greater than 0 or “ospNavImpact” is “With impact”. UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 60/102
18. Annex IV – Synopsis on information to be transmitted for “Other errors - Noncompliant payment of costs/fees at UCI level” *CSSF guidance: Please refer to annex VII for the code to be used in the notification for closed questions (Yes/No answers, or answers referring to a predefined list) Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Contact person email address contactPersonEmail The contact person must have an eDesk account linked to the notifying entity on eDesk. This person will receive the email in case of exchange of comments.
19. General information Complete or pre-notification ocfPreOrCompNotification Please select the appropriate choice from the below list: - Complete notification - Pre-notification The CSSF expects a complete notification to be submitted, in principle, within 4 to 8 weeks of the detection of the incident. The pre-notification option can only be used on an exceptional basis in duly justified cases where the calculations and compensation processes necessary to correct the non-compliant payment of costs/fees at UCI level are particularly complex and time-consuming and thus do not allow entities to provide the CSSF, within 4 to 8 weeks, with a complete notification. Please describe the non-compliant payment ocfPreNotificationDescription of costs/fees at UCI level AND justify why a Only if the answer to the question “ocfPreOrCompNotification” is “Prenotification”. pre-notification is necessary UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 61/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Please describe the typology, duration, and estimated impact of the non-compliant payment of costs/fees at UCI level that occurred and provide all available details. Then, please provide a detailed justification allowing the CSSF to have a clear and thorough understanding of why the correction process of the investment allocation error cannot be finalized within 4 to 8 weeks and why the Fund is unable to submit a complete notification form with all the fields duly filled out.
20. Details relating to the non-compliant payment of costs/fees at UCI level Detection date of the non-compliant ocfDetectionDate payment of costs/fees at UCI level Only if the answer to the question “ocfPreOrCompNotification” is “Complete notification”. This date must be less than or equal to the reception date of the notification. Period of the non-compliant payment of ocfPeriodStartDate costs/fees at UCI level - Start Date Only if the answer to the question “ocfPreOrCompNotification” is “Complete notification”. This date must be less than or equal to the reception date of the notification. Period of the non-compliant payment of ocfPeriodEndDate costs/fees at UCI level - End Date Only if the answer to the question “ocfPreOrCompNotification” is “Complete notification”. This date must be greater than or equal to “ocfPeriodStartDate”. Please specify the type of non-compliant ocfDirectionNonCompliantPayme Only if the answer to the question “ocfPreOrCompNotification” is payment of costs/fees nt “Complete notification”. Please select the appropriate choice from the below list: - UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 UCI paid an excess amount of costs/fees 62/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Please specify the correction process ocfCorrectionProcess Only UCI paid an insufficient amount of costs/fees if the answer to the question “ocfDirectionNonCompliantPayment” is “UCI paid an insufficient amount of costs/fees”. Please select the appropriate choice from the below list: - UCI has not been charged retroactively for the insufficient costs/fees - UCI has been charged retroactively for the insufficient costs/fees Description and cause of the of the non- ocfDescription compliant payment of costs/fees at UCI level Only if the answer to the question “ocfPreOrCompNotification” is “Complete notification”. Please provide a detailed description/explanation allowing the CSSF to have a good and clear understanding of the circumstances and reasons leading to the non-compliant payment of costs/fees at UCI level. Concrete corrective measures/actions ocfMesuresActionsDecided decided at the level of fund's organisation “Complete notification”. and control environment in order to avoid recurrence of the same kind of Only if the answer to the question “ocfPreOrCompNotification” is Please provide a detailed description/explanation allowing the CSSF non- to have a good and clear understanding of correction operations at compliant payment of costs/fees at UCI level the level of the Fund's organisation and control procedures/processes in order to avoid recurrence of comparable non-compliant payments of costs/fees at UCI level. Amount of the costs/fees which has not been ocfAmountCostsNotCharged charged retroactively UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 Only if the answer to the question “ocfCorrectionProcess” is “UCI has not been charged retroactively for the insufficient costs/fees”. 63/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Amount of the costs/fees which has been ocfAmountCostsCharged charged retroactively Only if the answer to the question “ocfCorrectionProcess” is “UCI has been charged retroactively for the insufficient costs/fees”. In the event that the UCI retroactively withdraws the amount of insufficiently paid costs/fees from its assets, the UCI must in accordance with point 105 of Circular CSSF 24/856 fully correct the erroneous NAVs (due to insufficiently paid fees) for the entire error period without applying the tolerance threshold specified in Chapter 4 of the Circular concerning significant NAV calculation errors. On this basis, only some fields in the subsequent NAV calculation error section (as requird based on the notification form) need to be completed. Please provide comprehensive details on the compensation amounts/percentage in the separate impact calculation file (impacts on subscription/redemption for respectively UCI and investors) in the relevant currencies. A special audit report by the “REA” (réviseur d’entreprises agréé (approved statutory auditor)) must only be submitted to the CSSF for UCITS and UCI part II where the total compensation amounts exceeds 50,000 EUR or the amount for a single investor exceeds 5,000 EUR. Amount to be indemnified to the sub-fund in ocfAmountIndemnifiedSubfundC Only if the answer to the question EUR (costs/fees in excess) ostsExcess “ocfDirectionNonCompliantPayment” is “UCI paid an excess amount of costs/fees”. Please provide comprehensive details on the compensation amounts/percentage in the separate impact calculation file (impacts on subscription/redemption for respectively UCI and investors) in the relevant currencies. UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 64/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file A special audit report by the REA must only be submitted to the CSSF for UCITS and UCI part II where the total compensation amounts exceeds 50.000 EUR or the amount for a single investor exceeds 5.000 EUR. Did the non-compliant payment of costs/fees ocfCauseNavCalculationError cause a significant NAV calculation error Only if the answer to the question “ocfDirectionNonCompliantPayment” is “UCI paid an excess amount of costs/fees”. Please select the appropriate choice from the below list: - Yes - No For UCIs that paid too much costs/fees, it must be verified on all NAVs that were calculated during the entire period of non-complaint payment if the compensation amount caused a significant NAV calculation error and the resulting NAV calculation error must, in addition, be corrected in accordance with the guidelines laid down in Chapter 4 of Circular CSSF 24/
21. For UCIs that did retroactively withdraw the amounts of insufficiently paid costs/fees from the UCI’s assets, the UCI must fully correct the erroneous NAVs (through insufficiently paid fees) over the whole error period without applying the tolerance threshold provided for in Chapter 4 of Circular CSSF 24/
22. Please indicate the type of UCI ocfTypeUci Only if the answer to the question “ocfCauseNavCalculationError” is “Yes”. Please select the appropriate choice from the below list: - UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 UCITS or UCI PART II or SIF subject to the MMF Regulation 65/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file - Bond UCITS - Mixed UCITS - Equity UCITS or other assets UCITS - Bond - UCIs Part II (for retail investors) - Mixed - UCIs Part II (for retail investors) - Equity - UCIs Part II (for retail investors) - Other assets - UCIs Part II or ELTIF (for retail investors) - Other assets - UCIs Part II or ELTIF (for retail investors) applying different threshold based on derogation procedure - UCIs Part II, ELTIF, SIFs, SICARS, EuVECA and EuSEF (for well-informed or professional investors) Tolerance threshold applied (in %) ocfToleranceThreshold Only if the answer to the question “ocfCauseNavCalculationError” is “Yes”. The percentage must be between 0% and 5%
23. Details relating to the subsequent NAV calculation error Period of the NAV calculation error - Start ocfNavPeriodImpactStartDate Date Period of the NAV calculation error - End Only if the answer to the question “ocfCauseNavCalculationError” is “Yes”. ocfNavPeriodImpactEndDate Date Only if the answer to the question “ocfCauseNavCalculationError” is “Yes”. This date must be greater than or equal to “ocfNavPeriodImpactStartDate”. Period of the significant impact - Start Date ocfNavPeriodImpactStartDate2 Only if the answer to the question “ocfCauseNavCalculationError” is “Yes”. UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 66/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file If, during the error period, days with significant impact alternate with days on which the impact was not significant, please indicate as the start date the first day of the significant NAV calculation error and as the end date the last day on which the error was significantly incorrect. The individual sub-periods with a significant error do not need to be specified individually. Period of the significant impact - End Date ocfNavPeriodImpactEndDate2 Only if the answer to the question “ocfCauseNavCalculationError” is “Yes”. If, during the error period, days with significant impact alternate with days on which the impact was not significant, please indicate as the start date the first day of the significant NAV calculation error and as the end date the last day on which the error was significantly incorrect. The individual sub-periods with a significant error do not need to be specified individually. Impact of the NAV calculation error ocfNavImpact Only if the answer to the question “ocfCauseNavCalculationError” is “Yes” or “ocfCorrectionProcess” is “UCI has been charged retroactively for the insufficient costs/fees”. Please select the appropriate choice from the below list: - With impact - Without impact In case no subscription or redemption requests have been processed during the error period, please select "without impact" Please provide a clear justification on the ocfNavJustificationWhitoutImpac Only if the answer to the question “ocfNavImpact” is “Without reason why the error is to be considered as t impact”. without impact UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 67/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Amount to be indemnified to the sub-fund in ocfNavAmountIndemnifiedSubfu EUR nd (Please reference "0" if no compensation is required.) Only if the answer to the question “ocfNavImpact” is “With impact”. Please provide comprehensive details on the compensation amounts/percentage in the separate impact calculation file (impacts on subscription/redemption for respectively UCI and investors) in the relevant currencies. A special audit report by the REA must only be submitted to the CSSF for UCITS and UCI part II where the total compensation amounts exceeds 50,000 EUR or the amount for a single investor exceeds 5,000 EUR. Amount to be indemnified in cash to the ocfNavAmountIndemnifiedCashI investors in EUR (Please reference "0" if no nvestors compensation is required.) Only if the answer to the question “ocfNavImpact” is “With impact”. Please provide comprehensive details on the compensation amounts/percentage in the separate impact calculation file (impacts on subscription/redemption for respectively UCI and investors) in the relevant currencies. A special audit report by the REA must only be submitted to the CSSF for UCITS and UCI part II where the total compensation amounts exceeds 50,000 EUR or the amount for a single investor exceeds 5,000 EUR. Amount to be indemnified by allocation of ocfNavAmountIndemnifiedUnitsI new units to the investors in EUR (Please nvestors reference "0" if no compensation is For Investors who received a corresponding number of shares as indemnification, please indicate the amount in EUR required.) Please indicate if indemnification amount for Only if the answer to the question “ocfNavImpact” is “With impact”. ocfNavSingleInvestor a single investor exceeds EUR 5,000 Only if the answer to the question “ocfNavAmountIndemnifiedCashInvestors” is greater than 5000 or “ocfNavAmountIndemnifiedUnitsInvestors” is greater than
24. UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 68/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Please select the appropriate choice from the below list: Maximum impact in % of the error ocfNavMaxImpactError - Yes - No Only if the answer to the question “ocfNavImpact” is “With impact”. Please indicate for the NAV calculation error the highest percentage of the impact during the period De minimis amount applied ocfNavDeMinimisAmount Only if the answer “ocfNavAmountIndemnifiedCashInvestors” to the is greater question than 0 or “ocfNavAmountIndemnifiedUnitsInvestors” is greater than
25. Please select the appropriate choice from the below list: Please indicate the threshold level of the "De - Yes - No ocfNavDeMinimisThreshold Only if the answer to the question “ocfNavDeMinimisAmount” is “Yes”. ocfNavCurrency Only if the answer to the question “ocfNavDeMinimisAmount” is “Yes”. minimis" fixed in the internal procedure Please indicate the currency Please select the appropriate choice from the below list: see Annex VII
26. Details concerning the indemnification procedure Date of booking / recording of the provision ocfNavBookingDate (in the accounting of the UCI) Only if the answer to the question “ocfAmountCostsNotCharged” is greater than 0 or “ocfAmountIndemnifiedSubfundCostsExcess” is greater than 0 or “ocfNavImpact” is “With impact”. Booking date of the indemnification amounts UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 69/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Sub-fund payment date ocfNavSubfundPaymentDate Only if the answer to the question “ocfAmountIndemnifiedSubfundCostsExcess” is greater than 0 or “ocfNavAmountIndemnifiedSubfund” is greater than
27. This date must be greater than or equal to “ocfDetectionDate” and “ocfPeriodEndDate” and “ocfNavPeriodImpactEndDate”. If the compensation payments were realized on different days, please indicate in this field, the last payment date. Investors payment date ocfNavInvestorsPaymentDate Only if the answer to “ocfNavAmountIndemnifiedCashInvestors” the is question greater than 0 or “ocfNavAmountIndemnifiedUnitsInvestors” is greater than
28. This date must be greater than or equal to “ocfDetectionDate” and “ocfPeriodEndDate” and “ocfNavPeriodImpactEndDate”. If the compensation payments were realized on different days, please indicate in this field, the last payment date. Total indemnification amount in EUR ocfTotalIndemnificationAmount Only if the answer to the question “ocfAmountIndemnifiedSubfundCostsExcess” is greater than 0 or “ocfNavAmountIndemnifiedSubfund” is “ocfNavAmountIndemnifiedCashInvestors” greater is than greater than 0 or 0 or “ocfNavAmountIndemnifiedUnitsInvestors” is greater than
29. Please indicate the total indemnification amount, thereby following the guidance hereafter for the different types of non-compliant payment of costs/fees: If the UCI paid an excess amount of costs/fees, please indicate here (i) the indemnification amount paid to the UCI for the corresponding UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 70/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file excess amount of costs/fees and (ii) if applicable, the indemnification amounts paid to the (sub-)fund and/or investors in case the error caused a significant NAV calculation error. If the UCI did pay an insufficient amount of costs/fees and if the UCI did not retroactively charge the insufficient amount of costs/fees from the UCI’s assets, then please indicate "0" as no indemnification occurred at level of the UCI and/or the investors. If the UCI retroactively withdraws the amount of insufficiently paid costs/fees from the UCI’s assets, then please provide the total amount of retroactively charged costs/fees withdrawn from the UCI, as well as, if applicable, the indemnification amounts paid to the (sub-)fund and/or investors as a result of the correction of the erroneous NAV calculations (due to the insufficiently paid fees) over the entire error period, without applying the tolerance threshold outlined in Chapter 4 of the Circular relating to significant NAV calculation errors. Other information concerning the / helpful error, comments impact ocfNavOtherInformation or Only if the answer to the question “ocfPreOrCompNotification” is “Complete notification”. reimbursement calculation Please indicate here any other elements of relevance concerning the error/non-compliance as well as any specificities in the correction and impact calculation processes a.o. whether the financial impact has been determined using the compound method or the non-compound method. Entity(ies) responsible for the payment of ocfNavEntityResponsibleForPaym Only if the answer to the question “ocfAmountCostsNotCharged” is the indemnification amount ent greater than 0 or “ocfAmountIndemnifiedSubfundCostsExcess” is greater than 0 or “ocfNavAmountIndemnifiedSubfund” is greater than UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 71/102 Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file 0 or “ocfNavAmountIndemnifiedCashInvestors” is greater than 0 or “ocfNavAmountIndemnifiedUnitsInvestors” is greater than
30. UCI NOTIFICATION IN ACCORDANCE WITH CIRCULAR CSSF 24/856 72/102
31. Annex V – Synopsis on information to be transmitted for “Other errors - Incorrect application of cut-off rules” *CSSF guidance: Please refer to annex VII for the code to be used in the notification for closed questions (Yes/No answers, or answers referring to a predefined list) Information to be provided Technical attribute to be CSSF guidance* provided in the JSON file Contact person email address contactPersonEmail The contact person must have an eDesk account linked to the notifying entity on eDesk. This person will receive the email in case of exchange of comments.
32. General information Complete or pre-notification ocoPreOrCompNotification Please select the appropriate choice from the below list: - Complete notification - Pre-notification The CSSF expects a complete notification to be submitted, in principle, within 4 to 8 weeks of the detection of the incident. The pre-notification option can only be used on an exceptional basis in duly justified cases where the calcula