Procedure for Handling of Client Complaints

Legal basis and purpose

This procedure is determined by the Board of Directors of BTIG Norway AS (the “Company”) pursuant to section 9-20 of the Securities Trading Act, and Commission Delegated Regulation 2017/565 art. 26, cf. the Securities Trading Regulation section 2-2.

The purpose of the procedure is to establish guidelines for receiving and processing client complaints.

Responsibility

This procedure shall be adopted by the board of the Company.

The procedure must be made known to all employees.

The Company’s responsible person for handling client complaints is the Compliance Officer (“Complaints Handling Manager”).

Information about the company’s complaint procedures

The Company shall publish information on the company’s complaints handling procedures on its website. Such information shall contain information on how the Company processes client complaints and contact details to the Company’s Complaints Handling Manager, ref. section 2 above.

No fees shall be charged for filing a client complaint.

The Company shall, on request, provide the complainant with written information about the Company’s complaint handling procedures and in connection with the receipt of a complaint.

The complaints handling process

If a client files a complaint with the Company, regardless of whether the complaint concerns the Company in general or one or more named employees, the Company must ensure that the complaint is handled properly and quickly. The Company should communicate with complainants in a clear and understandable manner by using uncomplicated words and expressions.

All complaints must be in writing. The client will, without undue delay, be given written feedback which as a minimum indicates that the complaint has been received, that it will be processed, that the client will be given written feedback from the Company as soon as the complaint has been processed and that it will then be stated what the Company will do with regard to complaint.

The Complaint Handling Manager must, after receiving a complaint, discuss the complaint with the CEO. The Complaint Handling Manager and CEO decide jointly, and without undue delay, how the complaint is to be processed, including considering what steps and measures are necessary to investigate the cause of the complaint. If relevant, a meeting shall be held with any named employee to whom the complaint relates. It must be assessed whether it is necessary for the client to participate in such a meeting. The Complaints Handling Manager and CEO shall be present at such meetings. Minutes shall be kept of such meetings.

If a client complaint is not upheld by the Company, the Company shall justify the refusal in writing and provide information on the possibility for the complainant of bringing the case in for an appeals board.

Follow-up, record-keeping and register over CLIENT complaints

The Complaint Handling Manager shall continuously analyze the information received in the complaints to determine whether the complaints are due to systematic or fundamental issues within the company, as well as to addressing risks or issues that need to be corrected.

The entire chain of correspondence relating to a complaint (including the complaint, the company’s confirmation of receiving the complaint, internal assessments and decisions, etc., as well as final feedback to the client with the outcome of the complaints handling process and any follow-up correspondence) shall be recorded and stored in accordance with the Company’s routines for recording and storing documentation.

All complaints, including information on the measures taken to resolve the complaints, shall be registered in a separate internal register kept by the Complaints Handling Officer.

Reporting to the financial supervisory authority

The Company must report all complaints to the Financial Supervisory Authority annually.