3 Comma Capital hereby informs its clients and investors that it has formally adhered to the Protocol on Alternative Dispute Resolution Mechanisms (Management Companies), established between the Portuguese Securities Market Commission (CMVM) and the signatory institutions engaged in the management of collective investment undertakings.

This adherence reinforces our commitment to transparency, investor protection, and the availability of effective mechanisms for resolving disputes.

Scope and Purpose of the Protocol

The Protocol sets out the mutual understanding between the CMVM and the signatory management companies, ensuring that these institutions accept the use of Alternative Dispute Resolution (ADR) mechanisms whenever:

• The complainant is a consumer who qualifies as a non‑professional investor.
• A prior complaint submitted to the management company and to the CMVM has not been fully resolved.
• The dispute concerns activities related to the management of collective investment undertakings (UCITS or AIFs), including authorized ancillary or additional activities.
• The amount in dispute does not exceed €30,000.

ADR Centers Available to Investors

Under this Protocol, consumers who qualify as non‑professional investors may resort to the following Consumer Arbitration Centers, which form part of the national ADR network:

• CACRC – Consumer Conflict Arbitration Centre of the Coimbra Region
• CACCL – Consumer Conflict Arbitration Centre of Lisbon
• TRIAVE – Consumer Conflict Arbitration Centre of Ave, Tâmega and Sousa
• CICAP – Consumer Information and Arbitration Centre of Porto
• CIAB – Consumer Information, Mediation and Arbitration Centre (Consumer Arbitration Tribunal)
• CIMAAL – Consumer Information, Mediation and Arbitration Centre of the Algarve
• CNIACC – National Centre for Consumer Information and Arbitration

These centers are authorized to handle disputes relating to financial intermediation and asset management activities.

Other Dispute Resolution Options

The Protocol does not limit or exclude access to other legally available dispute resolution mechanisms, nor does it prevent the use of procedures contractually agreed between the parties. Investors remain free to choose the most appropriate means to safeguard their rights.

Commitment of 3 Comma Capital

By joining this Protocol, 3 Comma Capital reaffirms its dedication to:

• Protecting the interests of its clients and investors;
• Ensuring responsible and transparent market practices;
• Providing effective channels for complaints and dispute resolution;
• Continuously improving the quality of the services it provides.

For further information or clarification, clients and investors may contact us through the usual communication channels.