Regulatory Information

Requests & Complaints handling

Requests handling procedure

Any request of information or explanation filed with Cube Infrastructure Managers shall be made in writing by letter or email to the following address:

- Cube Infrastructure Managers, 41, avenue de la Liberté, L-1931 Luxembourg, Attn: Mrs. Susanne d’Anterroches, Head of Legal (SdAnterroches@cubeim.com).

Within a maximum period of 10 business days after the receipt of a request, Cube Infrastructure Managers will send to the applicant a written acknowledgement of receipt.

Cube Infrastructure Managers will provide the information or explanation as promptly as possible and in any case, no later than 1 month from the date at which the request was received.

Where an answer cannot be provided within this period, Cube Infrastructure Managers will inform the applicant of the causes of the delay and indicate the date at which the request of information or explanation is likely to be met.

Complaints handling procedure

For the purpose of the complaints handling procedure of Cube Infrastructure Managers, a complaint means a written statement filed with Cube Infrastructure Managers to recognize a right or to address a harm.

For confidentiality purposes, only complaints received from investors or from persons who have the investor’s express and written authorization will be handled by Cube Infrastructure Managers.

The complaints (including those in relation to any branch of Cube IM abroad, if any) shall be made in writing by letter to the following address:

- Cube Infrastructure Managers, 41, avenue de la Liberté, L-1931 Luxembourg, Attn: Mr. Henri Piganeau.

The complainant shall provide at least the following type of information when submitting a complaint:

- Description of the situation;

- Contact details of the complainant.

Within a maximum period of 10 business days after the receipt of a complaint, Cube Infrastructure Managers will send to the complainant a written acknowledgement of receipt. Unless the answer to the complaint is provided within this period, Cube IM will inform the investor of:

- The name and the contact details of the person handling the complaint.

- An indicative timetable for handling the complaint.

Cube Infrastructure Managers will inform the complainant about the decision made as promptly as possible and in any case, no later than 1 month from the date at which the complaint was received. Cube Infrastructures Managers ensures the prompt and effective analysis and handling of client complaints in order to ensure a thorough and respectful treatment of the complaints.

Where an answer cannot be provided within this period, Cube Infrastructure Managers will inform the complainant of the causes of the delay and indicate the date at which its examination is likely to be achieved.

Voting right policy summary

Cube Infrastructure Managers (“Cube IM”) manages Alternative Investment Funds (“AIFs”) which invest into infrastructure companies. Cube IM manages for the exclusive benefits of the AIF and its investors through the exercise of voting rights either at the board of directors / managers of an infrastructure company or at the board of directors / managers of the subsidiaries held directly or indirectly by an AIF managed by Cube IM.

Each infrastructure company operates under the supervision of its own board of directors/managers (hereafter “boards”). Cube IM appoints representatives (which are employees of Cube IM) as members of these boards (“AIFM representatives”). These AIFM representatives are usually members of the Management Committee or other senior employees of Cube IM.

According to the Alternative Investment Fund Manager (“AIFM”) Regulation, Cube IM has developed adequate procedures and measures that determine how voting rights held in the AIFs it manages are to be exercised, to the exclusive benefit of the AIF concerned and its investors.

This strategy ensures that Cube IM will be informed of any corporate actions at the level of the infrastructure company and that the exercise of the voting rights is always in accordance with the investment objective of the AIFs managed.

Any conflicts of interest arising in particular in respect to a mandate of an AIFM representative are disclosed to the compliance officer and dealt-with in accordance with the conflicts of interest policy of Cube IM. In case of a conflict of interest, the concerned person will abstain from voting during the meeting of the boards.

The voting rights exercise is verified by Cube IM as part of its compliance monitoring plan implementation.

For more information, please refer to Cube IM’s voting rights policy available upon request.

Out-of-court complaint resolution procedure with the CSSF

Where the complainant did not receive an answer or a satisfactory answer within the period of 1 month from the date at which the complaint was sent to Cube Infrastructure Managers, the complainant may file his/her request for an out-of-court complaint resolution with the Commission de Surveillance du Secteur Financier (CSSF) within 1 year after the complainant filed his/her complaint with Cube Infrastructure Managers.

Further information on the out-of-court complaint resolution procedure is available on the CSSF website (https://www.cssf.lu/en/consumer/complaints/).

Where Cube IM has undertaken to resort to the out-of-court complaint resolution procedure with the CSSF, Cube Infrastructure Managers will provide the complainant with the website reference relating to the Regulation CSSF No 16-07 or copy of that regulation.