Amended: September 2026 | Version: 2026.1

PROSPERGATE CAPITAL LTD, is a company registered under the laws of the Republic of Cyprus, with registration number C369583. It is a regulated Cyprus Investment Firm (“CIF“) authorised and regulated by the Cyprus Securities and Exchange Commission (“CySEC“) under license number 361/18. The Company also acts as the External Manager of PROSPERGATE FUND AIFLNP V.C.I.C LTD.

The registered office of the Company is situated at 2 Filiou Zannetou street, 3021 Limassol, Cyprus.

For the purposes of, inter alia, this Complaints Handling Policy, the Company operates under:

• Directive 2014/65/EU (“MiFID II“), as implemented in Cyprus by the Investment Services and Activities and Regulated Markets Law of 2017 (Law 87(I)/2017), as amended;
• The Alternative Investment Funds Law of 2018 (L.124(I)/2018) and, in respect of the Company’s role as External Manager, the Small Alternative Investment Fund Managers Law of 2020 (L.81(I) of 2020) (“the SMALL AIFM Law“), as amended and supplemented. 
• The Commission Delegated Regulation (EU) 2017/565 (Article 26), supplementing Directive 2014/65/EU (Article 16(2)) as regards organisational requirements and operating conditions for investment firms;
• The Joint Committee Guidelines of the European Securities and Markets Authority (“ESMA“) and the European Banking Authority (“EBA“) on Complaints Handling, and the applicable CySEC circulars and reporting requirements addressed to CIFs in relation to complaints (including the periodic complaints reporting obligation, currently submitted via CySEC’s Transaction Reporting System using Form 144-002-01).

Pursuant to the ESMA/EBA Joint Committee Guidelines, the Company has established and maintains an effective and transparent procedure for handling client complaints.

In accordance with this Policy, the Company keeps records of every complaint or grievance, together with all measures taken for its resolution, and reports complaints data to CySEC on the periodic basis required by applicable CySEC circulars.

This Policy does not, and is not intended to, create third-party rights or duties that would not otherwise exist, nor does it form part of any contract between the Company and a client.

Prospergate Capital Ltd aims to provide a prompt, helpful, open and informative response to every approach made by its clients. The Company welcomes clients’ views on its performance and recognises that, as with any organisation, things can occasionally go wrong. Every complaint is treated as an opportunity to correct erroneous procedures or practices and to learn from the experience.

The Company treats as a “complaint” any statement of grievance made by a client concerning the activities of the Company’s employees in connection with the investment services the Company provides. A complaint should be submitted by the client in writing, using the Complaint Form set out below.

The Company has appointed a Compliance Officer to handle client complaints efficiently, so as to resolve them and to apply the necessary corrective measures to prevent recurrence. The Company keeps all records relating to complaints in its internal complaints register.

How to submit a complaint

To submit a complaint, the client is requested to complete the Complaint Form attached to this Policy and submit it to [email protected]. Once the client has submitted the completed form, the Company’s Compliance Department handles and investigates the complaint.

Acknowledgement of receipt

The Company acknowledges receipt of a complaint within two (2) working days of receiving the Complaint Form, and provides the client with a unique reference number, to be used in all future correspondence with the Company, the Financial Ombudsman and/or CySEC regarding that complaint.

Responsible examining officer

The Compliance Officer is responsible for handling client complaints, except where the complaint concerns the Compliance Officer, in which case it is handled by the Managing Director. A complaint may be submitted by:

• Email: [email protected]
• Telephone: +357 25 366 551
• Postal address: 2 Filiou Zannetou street, 3021 Limassol, Cyprus

Complaint handling and timelines

Once receipt of the Complaint Form is acknowledged, the Company reviews it carefully, investigates the circumstances, and seeks to resolve the complaint without unnecessary delay. Within four (4) weeks of the date the Complaint Form was submitted, the Company provides the complainant with a final response, or a holding response explaining the position reached to date. During the investigation, the Company keeps the complainant updated and may contact them for clarification or further documentation.

Upon receipt, the examining officer registers the complaint in the Company’s internal register with a unique reference number, incorporating the Company’s CIF code for CySEC’s Transaction Reporting System, the year, and a serial number, and informs the complainant to use this reference in all future correspondence with the Company, the Financial Ombudsman and/or CySEC.

If a response cannot be provided within the timelines above, the Company informs the complainant of the reason for the delay and indicates when its investigation is likely to conclude. Where a holding response is issued, it will explain why the complaint has not yet been resolved and provide an estimated resolution date. If, after eight (8) weeks from receipt of the Complaint Form, the Company remains unable to resolve the matter, the examining officer notifies the complainant in writing, stating the reasons for the delay and an estimated resolution date.

After the Company’s final response, the complainant may submit a written reply to the Examining Officer’s findings. If the complainant does not respond within eight (8) weeks of receiving the final response, this will be taken, prima facie, to indicate that the complainant is satisfied with the Company’s response, and the complaint will be treated as resolved.

Where the complainant is not satisfied with the Company’s final decision, or has not received a final decision within three (3) months of submitting the Complaint Form, they may refer the matter to the Financial Ombudsman of the Republic of Cyprus (“Ombudsman“) and seek mediation and/or financial compensation. The Ombudsman must be contacted within six (6) months of receiving the Company’s final response, failing which the Ombudsman may decline to examine the complaint.

Contact details of the Financial Ombudsman:

• Postal address: 13 Lord Byron Avenue, 1096 Nicosia, Cyprus
• Telephone: +357 22 848 900 | Fax: +357 22 660 584 / +357 22 660 118
• Email: [email protected]
• Website: www.financialombudsman.gov.cy

A complainant may also notify CySEC of a complaint; however, CySEC has no power to award restitution and consequently does not investigate individual complaints.

A complainant’s right to take legal action against the Company is unaffected by the existence or use of any complaints procedure described above.

This Policy may be updated and changed from time to time in order to comply with new legal or regulatory requirements or amendments. Any updated version will be published on the Company’s website.

If you would like to contact us with any queries or comments, please send an email to [email protected]

Prospergate Capital Ltd is a Cyprus Investment Firm (“CIF”) authorised by the Cyprus Securities and Exchange Commission (“CySEC”) (licence number 361/18), with a licence to perform portfolio management services. The Company externally manages, on a discretionary basis, client funds held with global financial institutions pursuant to a pre-defined investment strategy. As the risk of investing in certain financial instruments is generally high and the market value of such instruments may be affected by factors such as economic and political conditions, foreign exchange fluctuations, and shifts in market sentiment, the investor bears full responsibility for the risks associated with such investments and acknowledges that investment yield and/or capital preservation are not guaranteed. Investors should ensure they are fully aware of the potential risks connected with portfolio management services and their chosen investment strategy, and should note that some strategies carry a higher degree of risk than others, which may result in the loss of all or part of the initial investment. Past performance does not guarantee, and should not be taken as an indication of, future returns.

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