Instructions for the handling of customer complaints

1 Scope

The instruction covers the handling of all customer complaints in DNB Asset Management S.A. The customer complaint shall be understood as a customer who presents a specific complaint about the products managed by DNB Asset Management S.A. and/or the activity performed by DNB Asset Management S.A.


2 Purpose

All customer complaints shall be processed in a secure manner within DNB Asset Management S.A.


3 Handling

3.1 Registration

The customer can file a complaint by sending an email to the attention of the compliance officer of DNB Asset Management S.A. on funds@dnb.no or in writing at 13, rue Goethe, L-1637, Luxembourg.
In the complaint filed, the customer must state the grounds on which it is based and the results demanded. The complaint is handled by the compliance officer of DNB Asset Management S.A. For further details on DNB Asset Management S.A. complaints policy, please contact the compliance officer of DNB Asset Management S.A.

3.2 Handling of customer complaint

The compliance officer of DNB Asset Management S.A. shall ensure that all complaints are answered as soon as possible, with a written acknowledgment of receipt of a complaint being sent to the customer within 10 (ten) business days following a receipt of such complaint.
If a safe and good handling of the complaint presupposes is not possible to provide the customer with an answer within 14 (fourteen) business days after the complaint is received, the customer shall within this time be informed of the status of the procedure and, if possible, a delay before the customer receives a final response to the complaint.
In no case the customer shall be provided with an answer on the complaint filed, with a period longer than 1 (one) month after receipt of such complaint.

If the answer provided to the customer on the complaint filed is not to the customer’s satisfactory, the compliance officer of DNB Asset Management S.A. shall provide such customer with full details and argumentation behind such resolution of the complaint. Such customer shall be also informed in writing of the possibility to send a complaint to the Commission de Surveillance du Secteur Financier (“CSSF”) with a copy of CSSF Regulation N° 16-07 relating to the out-of-court resolution of complaints.

The customer shall at any time have a right to contact the management of DNB Asset Management S.A.  with regards to its complaint by sending email to funds@dnb.no or in writing at 13, rue Goethe, L-1637, Luxembourg. 

3.3 Resolution of Disputes


If the customer has demanded financial compensation and DNB Asset Management S.A. does not accept such demand, the customer shall be informed in writing with full details of such decision and that the dispute can be subject to judicial review.

4 References

CSSF regulation No 10-4 transposing Commission Directive 2010/43/EU of 1 July 2010 implementing Directive 2009/65/EC of the European Parliament and of the Council as regards organisational requirements, conflicts of interest, conduct of business, risk management and content of the agreement between a depositary and a management company.

CSSF regulation N° 16-07 relating to the out-of-court resolution of complaints.

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