I. GLOVAL VALUATION is a Valuation Company authorised by the Bank of Spain with number 4311.

II. Article 29 of Spanish Law 44/2002 of 22 November on measures to reform the financial system (the “Financial Law”) sets forth the financial entities’ duty to address and solve claims and complaints filed by their clients in connection with their legally recognised rights and interests. For such purposes, the Financial Law lays down the creation of a customer service or department.

III. Spanish Order ECO/734/2004 of the Ministry of Economy, by virtue of Art. 31 of the Financial Law, regulates the requirements and procedures to be met by the customer service or department. In particular, Art. 8 of the Order sets forth the entities’ duty to adopt the Rules for Customer Protection that will regulate the activity of the customer department or service.

IV. These Rules have been agreed based on the Second Addition Provision of ORDER ECO/734/2004 of 11 March “on customer service and departments and consumer protection in financial entities” that establishes how Valuation Companies should proceed to address and solve claims and complaints from clients and users.

V. In view of the above and pursuant to the Order, as a Valuation Company, GLOVAL VALUATION (hereinafter, the “Company”) has agreed to adopt these Rules for Consumer Protection (the “Rules”) which aim to establish the system to address and solve claims and complaints from the Company’s clients.

Article 1. Purpose
The purpose of these Rules is to regulate the structure, procedures and actions of the Customer Service Department (the “Customer Service” or the “Department”) in GLOVAL VALUATION (“GLOVAL” or the “Company”).

In accordance with the purpose and aim of these Rules, the following terms are defined as:

1. Complaint: Complaints will be statements filed by clients due to delays, lack of attention or any other type of action in the service provided.

2. Claim: Claims will be statements filed by clients with a view to having their interests or rights restored. They contain specific facts on actions or omissions in the service provided that harm the client’s interests or rights and that arise from alleged breaches of the valuation regulations or best practices and customs which a valuation company should follow.

Article 2. Customer Service1. The Company’s Customer Service, created as agreed by the Company’s Board of Directors, aims to address and solve the claims and complaints filed by its clients following the procedure set forth in these Rules.

2. The Customer Service is in charge of registering and solving the claims and complaints filed by a natural or legal person, Spanish or foreign, in their capacity as users of the Company’s services, provided that the claims and complaints refer to their legally recognised interests and rights.

Article 3. Characteristics of the Customer Service
The Customer Service will always make decisions independently in order to avoid conflicts of interest. For such purposes, it will combine the following characteristics:

a. It will be independent of all other commercial and operating services in the Company;

b. The exchange of information requested by the Customer Service from all other services in the Company will be fast, secure, efficient and coordinated. In this regard, requests for information sent to all other services in the Company will follow this procedure:

i. The Service Officer, as defined in the article below, will send a printed or digital request for information to the relevant service, clearly showing the reasons for this request and the contents of the information needed. If printed, it will be sent by internal post in a sealed envelope.
ii. Once the relevant service has received the request for information, they will have five (5) business days to answer the request. They will send their reply in print or digitally with the information needed.
iii. The Service Officer may ask for as many clarifications as necessary and the service must reply to these requests within two (2) business days. These time frames may be extended by the Service Officer when justified.
iv. Customer Service will keep a record of all the exchanges with other services, including the documents sent, that will be kept for six (6) years. The Service Officer will ensure that the Service always has the necessary human, material, technical and organisational resources needed to perform its duties. For such purposes:

c. The Service Officer will ensure that the number of employees making up the Department is appropriate and proportional to the Company’s operations and the staff has an adequate and up-to-date knowledge of the regulations on transparency and consumer protection in financial services. In this regard, the staff will be trained through courses, talks and conferences on the applicable regulations and their amendments.

d. Furthermore, the Service Officer will be in charge of keeping digital records of all complaints made by the users of financial services. The computer system will allow an individual record of each complaint, its processing, unfolding, solution and if this channel is exhausted, the potential appeal before the Commissioner for Consumer Protection in Banking Services.

All other services and departments in the Company undertake to provide the information requested by the Customer Service under the terms set forth in this Article 3.

Article 4. Appointment and term of office
1. The Company’s Board of Directors will agree the appointment, re-appointment or replacement of the Customer Service Officer (the “Service Officer”). The appointment, re-appointment or replacement will be reported to the Bank of Spain (“BdE”) and the Commissioner for Consumer Protection in Banking Services.

2. The Service Officer will hold his/her position for an initial five (5) years but the term may be extended for another five (5) years.

Article 5. Requirements
The Service Officer will be chosen from among the candidates who have duly proved that they meet the following requirements:

1. Good commercial and professional standing upon observing the trade laws and other laws that regulate the financial activity and businesses as well as best commercial and financial practices throughout his/her career.

2. Appropriate knowledge and experience to perform his/her role after performing functions related to the Company’s financial business.

Article 6. Causes for incompatibility, ineligibility and dismissal
1. The Service Officer will be deemed ineligible if he/she fails to meet the aforementioned requirements, lacks independence by being part of the Company’s commercial and operating services, or if he/she performs an executive role in the Company.

2. The Service Officer will be incompatible if:

a. He/she is related to one of the persons affected by the claim or complaint with up to a third degree of consanguinity or affinity, direct or collateral;
b. He/she has a close relationship or friendship with or clear animosity towards one of the persons affected by the claim or complaint;
c. He/she has a direct interest in the subject of the claim or complaint for whichever circumstances.

When the Service Officer is subject to one of these circumstances, he/she will not be involved in handling the complaint and will report it to the Chairperson of the Company’s Board of Directors who will call a meeting to appoint another person to handle and solve the complaint in question.

3. The Service Officer will be dismissed:
a. In the event of a circumstance that renders him/her ineligible;

b. If the term of office expires and his/her position is not renewed;

c. If the Service Officer dies or is physically unable to carry out his/her duties;

d. In the event of a serious breach of his/her duties.

4. The Board of Directors of GLOVAL VALUATION will determine if there are reasons for ineligibility or dismissal.

Article 7. Matters assigned to the Service
The Customer Service will be in charge of knowing and solving all the claims and complaints filed by natural or legal persons in their capacity as clients or users of the Company’s services, provided they are in connection with their legally recognised interests and rights within the scope of these Rules.

Article 8. Time frame for claims/complaints
1. The client/user of the Company’s services, whether a natural or legal persons, will have two (2) years to file their claim or complaint from the date they learn of the event that causes the claim or complaint.

2. In any case, the Customer Service will have two (2) months from the date of the claim or complaint to announce its final decision. At the end of this period, the claimant may challenge this decision before the Commissioner for Consumer Protection in Banking Services.

Article 9. Method, contents and place to file claims and complaints
1. Claims and complaints may be filed in person or by a representative, on paper or digitally, as long as the documents are legible and can be printed and stored. The use of digital media will be in accordance with Spanish Law 59/2003 of 19 December on digital signatures.

2. The procedure will begin by filing a document that should include:
a. Name, last name(s), address of the interested party and, if any, of their duly identified representative. It should also include the National Identity Card or Foreigner’s Identity Number for natural persons or the Tax Identification Code for legal entities with the Company House details of their incorporation.

b. Reason for the claim or complaint with a clear statement of the matters for which they pursue action, including the reference of the asset and/or number of the valuation record.

c. Offices, departments or services where the events of the claim or complaint took place.

d. That the claimant is not aware of any arbitration or administrative or legal proceedings involving the subject of the claim or complaint.

e. Place, date and signature.

The claimant must provide, along with the aforementioned document, any documented proof he/she has to support the claim or complaint.

3. Claims and complaints can be filed with the Customer Service at the Company’s offices opened to the public where they may ask for a complaint/claim form, or on the Company’s website (www.gloval.es) or by email to atencionalcliente@gloval.es.

Article 10. Entry
1. Upon receiving a complaint, the Customer Service opens a record for it. If the claimant does not provide sufficient proof of his/her identity or the events of the complaint cannot be established clearly, the Customer Service will ask the sender to provide the necessary documents within ten (10) calendar days. Otherwise, the complaint will be filed away. This period will not be included in the two (2) month period stipulated in Art. 8.2 herein. In any case, the claim or complaint will be acknowledged as received in writing and the date will be recorded to determine the start and end of this period.

2. The claim or complaint may only be filed once and will not be filed again with other departments in the Company.

3. Claims and complaints will only be rejected in the following cases:
a. Omission of basic details required when this cannot be remedied, like failing to specify the reason for the claim or complaint.

b. When the claim or complaint consists of different appeals or actions that fall under the jurisdiction of administrative, arbitration and/or legal bodies, or is pending resolution or trial, or the matter has already been settled by one of those proceedings.

c. When the events, reasons and request surrounding the claim or complaint do not refer to specific operations or do not refer to legally recognised interests and rights of the users of the services provided by the Company, regardless of whether they derive from the agreements, the regulations on transparency and consumer protection or the best practices and customs in finances, in particular the principle of equity.

d. When a claim or complaint is a repeat of a previously settled claim or complaint.

e. When the period set to file claims and complaints in these Rules has ended.

4. The following types of claims and complaints will be excluded:
a. Claims where the person asks for the recognition and quantification of damages as a result of a possible professional liability of the Company or its employees or collaborators or any other dispute referring to the recognition and quantification of damages, given that the statements made may affect the liability of the professionals who helped prepare the report or, if any, the Insurance Companies who cover such risk for GLOVAL VALUATION and the professionals.

b. Claims or complaints referring to an employment relationship.

c. Claims or complaints related to matters that are within the Company’s discretionary power, such as arranging or refusing certain agreements or services, as well as the pacts, conditions and timetable to provide the services.

d. Claims or complaints aimed at stopping the Company from exercising its rights against the Client.

e. Claims or complaints filed by clients or users of the services after the two-year period from the date when the Client learnt about the events behind the claim or complaint.

5. This decision to reject the claim or complaint will be notified to the interested party with the reasons that led to this decision. The Client will then have ten (10) calendar days to send his/her arguments against it. If the interested party does send arguments to challenge the decision but the reasons for the rejection are upheld, the Company will notify its final decision.

Article 11. Processing
1. During the processing of claims and complaints, the Service may gather the information it deems appropriate from the claimant and from different departments and services in the Company. The departments and services will answer the requests for information in the time frame and under the principles established in Art. 3 herein.

2. When the Customer Service becomes aware that the subject of a claim or complaint is the object of administrative, arbitration or legal proceedings under way, the Service will stop processing it.

Article 12. Remedy and withdrawal
1. If the Company should remedy the situation upon receiving the claim or complaint and the Client is satisfied with said remedy, this will be reported to the competent body with documented proof unless the interested party expressly states that he/she will withdraw the claim. In this case, the claim or complaint will be ended and filed away.

2. Interested parties may withdraw their complaints at any time and this will end the procedure.

Article 13. End and notice
1. The procedure should last no longer than two (2) months from filing the complaint and the end will be notified with a reasoned decision and clear conclusions on the claim made in the complaint. Should the decision be different from the criteria expressed in previous similar cases, the Company must explain the reasons that justify it.

2. This notice will be sent within ten (10) calendar days, on paper or digitally, provided the documents are legible and can be printed and stored, by the means specified by the claimant. Otherwise, the notice will be sent by the same means used to file the claim or complaint.

3. The notice that ends the procedure will expressly mention the claimant’s right to challenge this decision before the appropriate Commissioner for Customer Protection in Banking Services. Customer Service Rules.

Article 14. Relationship with the Commissioners
The Company will reply to any requests made by the Commissioners in the course of their role, through the contact person appointed for these purposes.

Article 15. Yearly Report
1. During the first quarter of each year, the Company’s Customer Service will submit a report on its performance during the previous year to the Company’s Board of Directors. This report will include at least the following details:

a. Statistical summary of claims and complaints addressed, with information on how many were filed, how many entered or rejected, the reasons and matters discussed in the claims and complaints and the amounts involved.

b. Summary of the decisions made, specifying if they were in favour or against the claimant.

c. General criteria followed for the decisions.

d. Recommendations or suggestions derived from the lessons learnt with a view to better reaching the goals behind the action.

2. The Company’s annual corporate report will include at least a summary of this Customer Service report.

GLOVAL VALUATION
March 2019