Rulebook on Compensation of UCITS Fund Investors and/or UCITS Fund for Damage

II. INCORRECT CALCULATION OF SHARE PRICE
Article 2.
(1) The share price in a UCITS fund is the net asset value of the UCITS fund per share, calculated in accordance with current regulations.
(2) An incorrect calculation of the share price exists when the initially calculated share price in the UCITS fund differs from the subsequently accurately determined share price for the same day.
(3) The period of incorrect calculation is the period during which a material error in the calculation of the share price referred to in Article 3 of this Rulebook existed.

Material Error in Share Price Calculation
Article 3.
(1) The compensation procedure for incorrect share price calculation prescribed by this Rulebook is conducted when the difference between the initially calculated and subsequently accurately determined share price for the same day exceeds 1% of the value of the initially calculated share price (material error in share price calculation). (2) Exceptionally from paragraph 1 of this Article, for money market UCITS funds operating in accordance with Regulation (EU) 2017/1131 of the European Parliament and of the Council of 14 June 2017 on money market funds, the Company is obliged to conduct a compensation procedure when the difference between the initially calculated and subsequently accurately determined share price for the same day exceeds 0.3% of the value of the initially calculated share price, and for bond UCITS funds when that difference exceeds 0.7%. (3) The compensation procedure for a material error in share price calculation consists of preparing a compensation plan referred to in Article 7 of this Rulebook, delivering the notification referred to in Article 8 of this Rulebook to investors, and compensating damaged investors and/or the UCITS fund.

Calculation of Higher Share Price
Article 4. (NN 150/22)
(1) A calculation of a higher share price exists when the initially calculated share price is higher than the subsequently accurately determined share price for the same day.
(2) In the case of a calculation of a higher share price, the Company is obliged to compensate the resulting damage to investors who acquired shares in the UCITS fund during the period of incorrect calculation, by payment of funds or allocation of shares, regardless of whether they are still investors in the UCITS fund at the time of damage payment. The Company is obliged to define in the rules of the UCITS fund the situations in which damage compensation is carried out by payment of funds and in which by allocation of shares. The amount of damage the Company is obliged to compensate is equal to the difference between the initially determined share price and the subsequently accurately calculated share price multiplied by the number of issued shares during the period of incorrect calculation. (3) In the case of a calculation of a higher share price, the Company is obliged to compensate the resulting damage to the UCITS fund when shares in the UCITS fund were redeemed during the period of incorrect calculation. The amount of damage the Company is obliged to compensate is equal to the difference between the initially calculated share price and the subsequently accurately determined share price multiplied by the number of redeemed shares during the period of incorrect calculation. (4) Damage compensation shall not be carried out for those investors for whom the determined amount of damage incurred during the period of incorrect calculation is less than 1.50 euros.

Calculation of Lower Share Price
Article 5. (NN 150/22)
(1) A calculation of a lower share price exists when the initially calculated share price is lower than the subsequently accurately determined share price for the same day.
(2) In the case of a calculation of a lower share price, the Company is obliged to compensate the resulting damage to investors whose shares were redeemed during the period of incorrect calculation, by payment of funds or allocation of shares, regardless of whether they are still investors in the UCITS fund at the time of damage payment. The Company is obliged to define in the rules of the UCITS fund the situations in which damage compensation is carried out by payment of funds and in which by allocation of shares. The amount of damage the Company is obliged to compensate is equal to the difference between the initially calculated share price and the subsequently accurately determined share price multiplied by the number of redeemed shares during the period of incorrect calculation. (3) In the case of a calculation of a lower share price, the management company is obliged to correct the number of allocated shares to investors who acquired shares in the UCITS fund during the period of incorrect calculation. (4) Damage compensation under paragraph 2 of this Article shall not be carried out for those investors for whom the determined amount of damage incurred during the period of incorrect calculation is less than 1.50 euros.

New Calculation of Share Price
Article 6.
The Company is obliged to prepare a new calculation of the share price for each day of the period of incorrect calculation referred to in Article 3.

Compensation Plan
Article 7.
(1) In the cases referred to in Article 3, paragraphs 1 and 2 of this Rulebook, the Company shall, without undue delay and no later than within 60 days of becoming aware of the material error in share price calculation, prepare a compensation plan and deliver it to HANFA without delay, and if the UCITS fund is managed by a Company from another Member State, also to the competent authority of the home Member State of the UCITS fund. (2) The compensation plan referred to in paragraph 1 of this Article must contain:

1. an appropriate deadline, method and procedures by which the damage to the UCITS fund and/or investors will be compensated,
2. measures to be taken with the aim of eliminating the identified material errors and compensating for damage,
3. a new calculation of the share price for each day of the period of incorrect calculation, and
4. the number of investors who acquired and/or redeemed shares during the period of incorrect calculation, and the individual and total amount of compensation to be paid to investors and/or the UCITS fund, by payment of a monetary amount or allocation of a proportional number of shares.

Notification of Investors
Article 8. (NN 66/26)
(1) When there is an obligation for the Company to compensate damage to specific damaged investors due to a material error in share price calculation, the Company is obliged to notify investors to whom damage needs to be compensated on that basis about the existence of the material error in share price calculation.
(2) The notification referred to in paragraph 1 of this Article contains the following information:

1. what is the cause and what constitutes the material error in share price calculation,
2. the amount of damage and the obligation to compensate,
3. deadlines and method of damage compensation.
   (3) The notification referred to in paragraph 1 of this Article is delivered in electronic form or in printed form, if the investor requested receipt of information and/or documents in printed form, in accordance with Article 112 of the Act, within 10 days of preparing the compensation plan.

Implementation of Compensation Procedure
Article 9.
(1) After the Company prepares a compensation plan in accordance with Article 7 of this Rulebook, it shall proceed without delay to compensate damaged investors and/or the UCITS fund.
(2) Costs incurred for the purpose of implementing the compensation procedure and measures for incorrect calculation of share price are costs of the Company and cannot be charged to the UCITS fund or investors.

III. EXCEEDING INVESTMENT RESTRICTIONS
Article 10.
(1) For the purposes of this Rulebook, exceeding investment restrictions or breach of investment restrictions refers to unauthorized exceedances of investment restrictions under Article 259, paragraph 4 of the Act, i.e., those exceedances that are the result of transactions concluded by the Company, whereby investment restrictions prescribed by the Act, regulations adopted on the basis of the Act and/or the UCITS fund prospectus were breached at the time of their conclusion. (2) The compensation procedure for breach of investment restrictions prescribed by this Rulebook is conducted when:

1. the exceedance of investment restrictions amounts to more than 10% of the total permitted investment prescribed by Article 254, paragraph 1 and Articles 255, 256, 257 and 258 of the Act, and
2. a loss or damage to the UCITS fund and/or investor was incurred by implementing transactions or adjusting investments in another appropriate manner referred to in Article 13, paragraph 1 of this Rulebook.
   (3) The compensation procedure for exceeding investment restrictions under paragraph 2 of this Article consists of preparing a compensation plan referred to in Article 11 of this Rulebook, delivering the notification referred to in Article 12 of this Rulebook to investors, and compensating damaged investors and/or the UCITS fund. (4) The period of investment exceedance is the period from the moment of unauthorized exceedance of investment restrictions under paragraph 2 of this Article until its elimination.

Compensation Plan
Article 11.
(1) In the case referred to in Article 10, paragraphs 1 and 2 of this Rulebook, the Company shall, without undue delay and no later than within 60 days of becoming aware of the exceedance of investment restrictions, prepare a compensation plan and deliver it to HANFA without delay, and if the UCITS fund is managed by a Company from another Member State, also to the competent authority of the home Member State of the UCITS fund. (2) The compensation plan referred to in paragraph 1 of this Article must contain:

1. an appropriate deadline, method and procedures by which the damage to the UCITS fund and/or investors will be compensated,
2. information on the asset position in the UCITS fund portfolio in relation to which the exceedance of investment restrictions occurred, the duration and reasons for such exceedance,
3. measures to be taken with the aim of adjusting investments and compensating for damage,
4. the number of investors who acquired and/or redeemed shares during the period of investment exceedance, and the individual and total amount of compensation to be paid to investors and/or the UCITS fund.

Notification of Investors
Article 12. (NN 66/26)
(1) When there is an obligation for the Company to compensate damage to specific damaged investors due to exceedance of investment restrictions, the Company is obliged to notify investors to whom compensation needs to be paid on that basis about the existence of the said exceedance of restrictions.
(2) The notification referred to in paragraph 1 of this Article contains the following information:

1. what is the cause and what constitutes the exceedance of investment restrictions,
2. the amount of damage and the obligation to compensate,
3. deadlines and method of damage compensation.
   (3) The notification referred to in paragraph 1 of this Article is delivered, in accordance with Article 112 of the Act, in electronic form or in printed form, if the investor requested receipt of information and/or documents in printed form, within 10 days of preparing the compensation plan.

Amount of Compensation
Article 13. (NN 150/22)
(1) The Company is obliged to immediately upon becoming aware of the exceedance of investment restrictions adjust investments by implementing transactions necessary for the complete elimination of the exceedance of investment restrictions or ensure adjustment in another appropriate manner (e.g., maturity of deposits, new payments or payments to investors causing the cessation of the exceedance of investment restrictions, change of method and methodology for valuing positions that caused the exceedance of investments when applicable, etc.). The Company is obliged to adjust investments in such a way as to completely eliminate the exceedance of investment restrictions. (2) When a profit was incurred by implementing a transaction or adjusting investments in another appropriate manner under paragraph 1 of this Article, the said profit shall be allocated to the UCITS fund. The Company is obliged to compensate the UCITS fund for costs incurred by implementing transactions that caused the exceedance of investment restrictions, as well as costs incurred to eliminate the said exceedance of investment restrictions. (3) When a loss was incurred by implementing transactions or adjusting investments in another appropriate manner under paragraph 1 of this Article, the Company is obliged to compensate the UCITS fund for such loss by paying an amount corresponding to the difference between the purchase and sale price of the asset that led to the exceedance of investment restrictions. In cases where the elimination of the exceedance of restrictions is carried out in another appropriate manner, the Company is obliged to compensate the UCITS fund for such loss by paying an amount corresponding to the difference in the value of the asset that led to the breach of investment restrictions on the day the breach occurred and the value of the asset on the day of adjustment of the investment exceedance. The Company is obliged to compensate the UCITS fund for costs incurred by implementing transactions that caused the exceedance of investment restrictions, as well as costs incurred to eliminate the said exceedance of investment restrictions. (4) In the cases referred to in paragraph 3 of this Article, the Company is obliged to compensate damaged investors who redeemed shares from the UCITS fund, during the period from the adjustment of investments to the compensation of the UCITS fund's loss, by payment of funds or allocation of shares. The Company is obliged to define in the rules of the UCITS fund the situations in which damage compensation is carried out by payment of funds and in which by allocation of shares. (5) Damage compensation shall not be carried out for those investors for whom the determined amount of damage incurred during the period from the adjustment of investments to the compensation of the UCITS fund's loss is less than 1.50 euros.

Implementation of Compensation Procedure
Article 14.
(1) The Company shall, after preparing a compensation plan, proceed without delay to compensate damaged investors and/or the UCITS fund.
(2) Costs incurred for the purpose of implementing the compensation procedure and measures for exceedance of investment restrictions are costs of the Company and cannot be charged to the UCITS fund or its investors.

Article 15.
The provisions of this Rulebook relating to the exceedance of investment restrictions under Article 259, paragraph 4 of the Act also apply to the case of exceedance of investment restrictions under Article 259, paragraph 2 of the Act which lasts longer than the expiration of the periods prescribed by Article 259, paragraphs 2 and 3 of the Act. The day of the occurrence of the exceedance of investment restrictions is considered to be the first day after the expiration of the period determined by Article 259, paragraphs 2 and 3 of the Act.

IV. AUDIT OF COMPENSATION PLAN
Article 16.
(1) Implemented compensation procedures in the case of incorrect calculation of share value and in the case of breach of investment restrictions are audited by an auditor within the audit of annual reports of the UCITS fund.
(2) In the case referred to in Article 7 of this Rulebook, the auditor's report and opinion must contain the auditor's assessment of whether, in the compensation procedure, the new calculation of share prices under Article 6 of this Rulebook was accurately determined and whether the calculation procedures and the amount of compensation paid to the UCITS fund and/or investors were in accordance with the conditions of this Rulebook. (3) In the case referred to in Article 11 of this Rulebook, the auditor's report and opinion must contain the auditor's assessment of whether the calculation procedures under Article 13 of this Rulebook and the amount of compensation paid to the UCITS fund and/or investors were in accordance with the conditions of this Rulebook. (4) If an exceedance of investment restrictions or incorrect calculation of share price is identified within the audit of the UCITS fund's financial statements, the Company is obliged to take appropriate measures without delay in accordance with the provisions of this Rulebook.

V. OTHER CASES OF DAMAGE COMPENSATION
Article 17. (NN 150/22, 66/26)
(1) The Company is responsible to the UCITS fund and investors for the proper and diligent conduct of business and is liable for damage caused to the assets of the UCITS fund, which resulted from the Company's omission in performing and executing its duties prescribed by the Act, regulations adopted on the basis of the Act, rules and prospectus of the UCITS fund. (2) The Company is also liable for damage incurred by holders of UCITS fund shares due to the issuance or redemption of UCITS fund shares, as well as due to the failure to redeem UCITS fund shares, if the holder of shares performed or omitted such actions or omissions based on documents or notifications under Article 183 of the Act, which contained untrue or incomplete data and information or data and information that were misleading, or based on inaccurate or incomplete data and statements forwarded to the holder of shares by persons who, on behalf and for the account of the Company, perform the business of offering shares of the UCITS fund. (3) Damage compensation under paragraphs 1 and 2 of this Article shall not be carried out for those investors for whom the determined amount of damage incurred during the period of incorrect calculation is less than 1.50 euros. (4) The compensation procedure in the cases referred to in paragraphs 1 and 2 of this Article consists of preparing a compensation plan referred to in Article 18 of this Rulebook, delivering the notification referred to in Article 19 of this Rulebook to investors, and compensating damaged investors and/or the UCITS fund.

Compensation Plan
Article 18.
(1) In the case referred to in Article 17, paragraphs 1 and 2 of this Rulebook, the Company shall, without undue delay and no later than within 60 days of becoming aware of the occurrence of damage, prepare a compensation plan and deliver it to HANFA without delay, and if the UCITS fund is managed by a Company from another Member State, also to the competent authority of the home Member State of the Company. (2) The compensation plan referred to in paragraph 1 of this Article must contain:

1. an appropriate deadline, method and procedures by which the damage to the UCITS fund and/or investors will be compensated and measures to be taken with the aim of eliminating the cause of the damage,
2. information on the reasons for the occurrence of damage,
3. the number of investors who suffered damage and the individual and total amount of compensation to be paid to investors and/or the UCITS fund.

Article 19. (NN 66/26)
(1) When in the case referred to in Article 17, paragraphs 1 and 2 of this Rulebook there is an obligation for the Company to compensate damage to specific damaged investors, the Company is obliged to notify investors about the existence of the said obligation.
(2) The notification referred to in paragraph 1 of this Article contains the following information:

1. the cause of the occurrence of damage,
2. the amount of damage and the obligation to compensate,
3. deadlines and method of damage compensation.
   (3) The notification referred to in paragraph 1 of this Article is delivered, in accordance with Article 112 of the Act, in electronic form or in printed form, if the investor requested receipt of information and/or documents in printed form, within 10 days of preparing the compensation plan.

Implementation of Compensation Procedure
Article 20.
(1) After the Company prepares a compensation plan in accordance with Article 18 of this Rulebook, it shall proceed without delay to compensate damaged investors and/or the UCITS fund.
(2) Costs incurred for the purpose of implementing the compensation procedure and measures for incorrect calculation of share price are costs of the Company and cannot be charged to the UCITS fund or investors.

VI. SIMPLIFIED COMPENSATION PROCEDURE
Article 21. (NN 150/22)
(1) When the total amount of payment for damage compensation in accordance with the provisions of this Rulebook is less than 6,500.00 euros and the amount of payment for damage compensation per investor is less than 330.00 euros, compensation plans under Articles 7, 11 and 18 of this Rulebook do not need to be delivered to HANFA. (2) In the cases referred to in paragraph 1 of this Article, it is not necessary to conduct an audit of implemented compensation procedures within the audit of annual reports of the UCITS fund.

VII. DELIVERY OF DOCUMENTATION
(NN 66/26)
Article 21.a
(1) The Company is obliged to deliver documentation under Articles 7, 11 and 18 of this Rulebook in the manner and in accordance with the Technical Instruction for the Use of the System for Electronic Data Delivery of the Croatian Financial Services Supervisory Agency reports.hanfa.hr and the Instruction for Filling Out Web Forms for Management Companies. (2) It is considered that the Company has delivered the compensation plan under Articles 7, 11 and 18 of this Rulebook at the moment when the documentation was recorded on the server for sending such documentation. (3) In justified cases of technical impossibility of delivery or delivery that was not correctly executed (e.g., system failure, inability to read received documentation, etc.) in the manner prescribed by paragraph 1 of this Article, the Company is obliged to deliver the documentation in written form, directly or by mail for the purpose of timely reporting. The Company is obliged to deliver the documentation in the manner prescribed by paragraph 1 of this Article as soon as the reasons for the impossibility of such delivery cease, and no later than within eight days from the cessation of circumstances that caused the technical impossibility of such delivery. (4) HANFA may, if necessary, request the Company to deliver certain documentation prescribed by this Rulebook in the original or certified copy, regardless of the electronic delivery performed.

VII. FINAL PROVISIONS
Article 22.
(1) The Company is obliged to deliver documentation under Articles 7, 11 and 18 of this Rulebook in the manner and in accordance with the Technical Instruction for the Use of the System for Electronic Data Delivery of the Croatian Financial Services Supervisory Agency reports.hanfa.hr and the Instruction for Filling Out WEB Forms for Management Companies. (2) It is considered that the Company has delivered the compensation plan under Articles 7, 11 and 18 of this Rulebook at the moment when the documentation was recorded on the server for sending such documentation. (3) In justified cases of technical impossibility of delivery or delivery that was not correctly executed (e.g., system failure, inability to read received documentation, etc.) in the manner prescribed by paragraph 1 of this Article, the Company is obliged to deliver the documentation in written form, directly or by mail for the purpose of timely reporting. The Company is obliged to deliver the documentation in the manner prescribed by paragraph 1 of this Article as soon as the reasons for the impossibility of such delivery cease, and no later than within 8 days from the cessation of circumstances that caused the technical impossibility of such delivery. (4) HANFA may, if necessary, request the Company to deliver certain documentation prescribed by this Rulebook in the original or certified copy, regardless of the electronic delivery performed.

Article 23.
(1) With the entry into force of this Rulebook, the Rulebook on the Procedure for Compensation of UCITS Fund Investors and/or UCITS Fund for Damage ("Official Gazette" 41/17) ceases to be valid.
(2) Compensation procedures initiated under the provisions of the Rulebook on the Procedure for Compensation of UCITS Fund Investors and/or UCITS Fund for Damage ("Official Gazette" 41/17) shall be completed in accordance with the provisions of that Rulebook.
(3) This Rulebook shall be published in the "Official Gazette" and shall enter into force on the eighth day from the date of publication.

FINAL PROVISION
The Rulebook on Amendments and Supplements to the Rulebook on Compensation of UCITS Fund Investors and/or UCITS Fund for Damage (NN 150/22) entered into force on 1 January 2023.
Article 6.
This Rulebook shall be published in the "Official Gazette" and shall enter into force on 1 January 2023.

FINAL PROVISION
The Rulebook on Amendments and Supplements to the Rulebook on Compensation of UCITS Fund Investors and/or UCITS Fund for Damage (NN 66/26) entered into force on 2 July 2026.
Article 6.
This Rulebook shall enter into force on the eighth day from the date of publication in the "Official Gazette".