In accordance with CSSF regulation 16-07, PANDOO Administration, as Professional of the Financial Sector (PSF), has an internal complaint handling policy which is available to its customers on request.
A complaint might be launched in writing by post, email or fax, or by telephone.
All complaints relating to a suspected breach of the professional secrecy or to a fraud must be submitted in writing.
In any event, complaints must clearly indicate the customer’s contact details and include a brief description of the reason for the complaint.

Complaints may be addressed:

PANDOO Administration
To the attention of the Head of Compliance
31, rue de Hollerich
L-1731 Luxembourg
Grand Duchy of Luxembourg

Phone. +352 266 365 391
Fax.      +352 266 365 350
compliance@pandoo.lu

As soon as PANDOO Administration receives a complaint, the latter will be sent to the departments concerned in order to be analysed and resolved as soon as possible.
If PANDOO Administration is unable to deal with the substance of the complaint within 10 days of receipt, a written acknowledgement will be sent to the complainant within this time frame. This acknowledgement will include the name and contact details of the person handling the complaint.

PANDOO Administration undertakes to ensure that complaints will be answered within one month from the date of receipt. If this time frame cannot be respected, PANDOO Administration will inform the complainant of the reasons for the delay and give an indication as to when the complaint is expected to be resolved.

In the absence of a response or a satisfactory response, the complaint may be submitted again in writing to Mr John Wantz, Managing Director in charge of complaints.
If you are not satisfied with the resolution or response given by the Managing Director, you can file a request for an out-of-court complaint resolution, in accordance with the provisions of regulation 16-07 issued by the Luxembourg financial regulator (CSSF).

PANDOO Management’s (“PANDOO Management”) priority is to provide the highest quality of services to its clients and the funds managed by PANDOO Management. If, however, they are not satisfied or should encounter a problem PANDOO Management complaints handling policy and procedures will ensure that complaints are handled in a fair, objective and truth oriented manner.

A “complaint” is defined, for the purpose of this section, as a written expression of dissatisfaction towards PANDOO Management to recognize a right or to redress a harm. A complaint is not necessarily founded on valid arguments, but should be formulated in a manner which sets out the basic facts and legal reasons that the filing party believes are sufficient to support a claim against PANDOO Management. The party making the complaint (“Complainant”) may be a direct client of PANDOO Management or a related party.

The Complainant shall kindly use the form (see PDF) as a guide to include all necessary details and send its written complaint(s) to 

PANDOO Management
To the attention of the Chief Compliance Officer
31, rue de Hollerich
L-1731 Luxembourg
Grand Duchy of Luxembourg
compliance@pandoo-management.lu

Complaint Handling Process
The Chief Compliance Officer of PANDOO Management is in charge of the collection and management of the complaints handling. Therefore all written complaints, which are not directly addressed to the Chief Compliance Officer, but generally addressed to PANDOO Management or through an intermediary or a delegated party (in connection to services provided on behalf of PANDOO Management), should immediately be transmitted to the Chief Compliance Officer who will instruct the complaint. 

The Chief Compliance Officer shall send an acknowledgment of receipt without undue delay and within ten (10) days after the receipt of the complaint to the Complainant.

The Chief Compliance Officer arranges to investigate without undue delay the complaint and shall collect from the employees, intermediaries, service providers or delegated parties all data and information that are necessary for the examination of the complaint. Should extensive investigations be necessary, the Complainant will receive a response within one (1) month after the initial filing of the complaint. If the complaint cannot be resolved within one (1) month, the Complainant will be informed by the Chief Compliance Officer of a) the reasons why the issue remains unresolved, b) the next steps to be taken to resolve the matter and c) an indication of the date at which the examination of the complaint will be achieved.

If the Complainant is not satisfied with the quality of the response, the Complainant can escalate its request to Mr Frederik Leser who has been appointed by the Board of Directors as the “Conducting Officer in Charge of Complaint Handling”.

If, after having contacted the Conducting Officer in Charge of Complaint Handling, the Complainant does not receive a response – or satisfactory response – within a period of one (1) month, the Complainant can address his/her complaint to the CSSF that foresees an out-of-court complaint resolution procedure in accordance with CSSF Regulation No 16-07.
The respective form to fill out and other useful information (e.g. time limits) can be found on the CSSF website at https://www.cssf.lu/en/customer-complaints

By visiting the Website, downloading information and/or requesting for information, you specifically acknowledge that data may be traced. Any data stored, including IP address, is used for administrative purposes only and is held strictly confidential. PANDOO Administration will neither sell your personal data to third parties nor market it in any other way.

In this context, you are specifically reminded that the use of the Internet network does not constitute a safe means of communication or exchange of information. Consequently, you specifically recognise that you are using this network at your own risks.

By accepting this disclaimer you acknowledge that the personal data relating to you, will be stored and processed in compliance with the annexed PANDOO Management Data Privacy Policy (PDF).

By visiting the Website, downloading information and/or requesting for information, you specifically acknowledge that data may be traced. Any data stored, including IP address, is used for administrative purposes only and is held strictly confidential. PANDOO Management will neither sell your personal data to third parties nor market it in any other way.

In this context, you are specifically reminded that the use of the Internet network does not constitute a safe means of communication or exchange of information. Consequently, you specifically recognise that you are using this network at your own risks.

The following laws and regulations are the primary legal framework to be followed when managing conflicts of interest (CoI) at PANDOO Management: Conflicts of Interest (PDF).

The following laws and regulations are the main legal framework to be respected when exercising Voting Rights on AIF portfolio asset companies at PANDOO Management: Voting Rights (PDF).

The objective of this procedure is to explain the principles of whistleblowing at PANDOO Management: Whistleblowing (PDF).