Please find a summary of your investor rights in the EU/EEA countries, where the Funds are registered for distribution, related to the Regulation (EU) 2019/1156 on facilitating cross-border distribution of collective investment undertakings.
Luxembourg Domiciled Vehicles
1 - Entitlement to make an individual complaint
a) Liaising with Energy Infrastructure Partners (EIP) Luxembourg SARL
As an Investor in the Fund(s) managed by EIP Luxembourg SARL as an Alternative Investment Fund Manager (AIFM), you are entitled to make a complaint free of charge in your language. Any such complaint must be handled by the AIFM promptly and effectively.
You will be able to provide us with your detailed complaint either:
– in paper form at Energy Infrastructure Partners Luxembourg SARL, 7, avenue du Swing, L-4361 Esch-sur-Alzette, Grand Duchy of Luxembourg
– per email at [email protected]
b) Out-of court complaint resolution with the Commission de Surveillance du Secteur Financier (“CSSF”)
If after discussing with us, you still wish to proceed with an out of court complaint resolution, you may file your complaint with the CSSF only when it relates to a Luxembourg supervised entity, meaning Energy Infrastructure Partners Luxembourg SARL authorised as an AIFM in Luxembourg under the Luxembourg Law of 12 July 2013 on alternative investment fund managers.
c) Out-of court complaint resolution related to a financial service provider in your country
If your complaint relates to a financial service provider in your country of residence, such as a bank, an insurance company, an investment firm (e.g. a portfolio manager, an investment adviser), you must first address your complaint to this financial service provider.
If after discussing with this entity, you still wish to proceed with an out of court complaint resolution, you may file a complaint directly to the appropriate Ombudsman of your country for the specific type of intermediary.
Please find the main Ombudsman (or equivalent) in your country (not exhaustive list). Please verify that the entity for which you have a complaint is a member of this Ombudsman.
|Country||Name||Types of intermediaries||Contact||Website||Languages|
|Austria||Conciliation Board of the Austrian Banking Industry||Mortgage banks, payment institutions, investment providers, most banks, most credit unions
|Arbitration board for consumer businesses||Mortgage intermediaries, Insurance companies, insurance intermediaries, investment intermediaries, pension intermediaries, some banks, some mortgage banks, some credit unions, some investment providers, some pension providers
|Belgium||Ombudsfin||Banks, mortgage banks, credit unions, investment providers, investment intermediaries, securities intermediaries
|ombudsfin.be||Dutch, French, English, German|
|Insurance Ombudsman||Insurance companies, some mortgage intermediaries, some pension intermediaries
|ombudsman.as||Dutch, French, English, German
|Denmark||Ankenævnet for Fondsmæglerselskaber (Complaint Board of Danish Securities and Brokering Companies)
|Most investment intermediaries||fanke.dk||Danish, English, Swedish, Norwegian|
|Det finansielle ankenævn
Danish financial complaint board
|Banks, mortgage institutions and investment funds||fanke.dk||Danish, English, Swedish, Norwegian|
|Ankenævnet for Forsikring
Danish Insurance Complaints Board
|Insurance companies, most pension providers||ankeforsikring.dk||Danish, English|
Investments Complaints Board
|Banks, mortgage banks, mortgage intermediaries, securities intermediaries, most investment providers, most investment intermediaries||fine.fi||Finnish, Swedish, English|
Consumer Disputes Board
|Banks, mortgage banks, mortgage intermediaries, credit unions, insurance companies, insurance intermediaries, some investment providers, some investment intermediaries, some pension providers, some pension intermediaries||kuluttajariita.fi||Finnish, Swedish, English|
Finnish Banking Complaints Board
|Banks, mortgage banks, mortgage intermediaries, credit unions||fine.fi||Finnish, Swedish, English|
Finnish Insurance Complaints Board
|Insurance companies, most insurance intermediaries, most pension providers, most pension intermediaries||fine.fi||Finnish, Swedish, English|
|France||AMF Ombudsman||Investment providers, most investment intermediaries, most securities intermediaries, some pension providers||On AMF website, go to Ombudsman / Médiateur, Access Form||amf-france.org||French, English|
|Mediator of the French Association of Specialised Finance Companies||Most credit unions, some banks, some mortgage banks||lemediateur.asf-france.com||French, English|
|Insurance Mediator||Insurance companies, some credit unions, some insurance intermediaries, some pension providers||mediation-assurance.org||French, English|
|Germany||Real Asset Investment Arbitration Board||Alternative investment fund managers (AIFM), providers of closed-end funds, trust companies, alternative investment funds, closed-end funds
|Ombudsman of German Cooperative Banks||Most banks, some mortgage banks||bvr.de||German, English|
|German Savings Banks Association||Only German savings banks||dsgv.de||German, English
|Ombudsman of German Public Sector Banks||Some banks||voeb.de||German, English, French
|Ombudsman Scheme of the Private Commercial Banks||Most banks, most mortgage banks||bankenombudsmann.de||German, any other language agreed on by the customer and bank
|Ombudsman Private Health and Long-term Care Insurance||Some insurance companies||Complaints can be sent via internet by filling in a specific form||pkv-ombudsmann.de||German|
|Ombudsman Scheme for Investment Funds||Some investment providers, some banks and some depositaries||ombudsstelle-investmentfonds.de||German, English|
|Arbitration Board at the Deutsche Bundesbank||Mortgage intermediaries, investment providers, investment intermediaries, securities intermediaries, some banks, some mortgage banks, some credit unions
|Arbitration Board at BaFin||All institutions under supervision of BaFin||bafin.de||German|
|Insurance Ombudsman||Insurance companies, insurance intermediaries||versicherungsombudsmann.de||German, English, French
|Iceland||Úrskurðarnefnd um viðskipti við fjármálafyrirtæki
Complaints Committee on Transactions with Financial Firms
|Banks, investment providers, investment intermediaries, securities intermediaries, payment services providers||en.fme.is||Icelandic, English|
|Úrskurðarnefnd í vátryggingamálum
Insurance Complaints Committee
|Insurance companies||en.fme.is||Icelandic, English|
|Ireland||Financial Services and Pensions Ombudsman
An tOmbudsman Sheirbhísí Airgeadais agus Pinsean
|Banks, mortgage banks, mortgage intermediaries, credit unions, insurance companies, insurance intermediaries, investment providers, investment intermediaries, securities intermediaries, some pension providers, some pension intermediaries||fspo.ie||English, Irish|
|Italy||ACF – Securities and Financial Ombudsman||Banks, credit unions, some insurance companies, some investment providers, most investment intermediaries, most securities intermediaries, depositaries
|Banking Ombudsman||Banks, investment providers, investment intermediaries||conciliatorebancario.it||Italian, French, English, Spanish
|IVASS – Insurance Supervisory Authority||Insurance companies, insurance intermediaries||E-mail
|ABF – Banking and Financial Ombudsman||Banks, mortgage banks, mortgage intermediaries, credit unions, payment institutions, electronic money institutions, Poste Italiane S.p.A.||E-mail
|The Netherlands||Financial Services Complaints Institute||Banks, insurance companies, insurance intermediaries, most mortgage banks, most mortgage intermediaries, most credit unions, some investment providers, some investment intermediaries, some pension intermediaries, some securities intermediaries
|Norway||Norwegian Financial Services Complaints Board||Banks, mortgage banks, insurance companies, most pension providers, some investment providers||cnmv.es||Norwegian, English|
|Portugal||CMVM – Comissão do Mercado dos Valores Mobiliários
Portuguese Securities Market Commission (CMVM)
|Banks, credit unions, investment providers, investment intermediaries, securities intermediaries, most insurance companies.||cnmv.pt||Portuguese|
|Spain||Oficina de Atención al Inversor – Dirección de Inversores de la CNMV
Investor Assistance Office – Investors Division of the CNMV
|Banks, investment providers, investment intermediaries, securities intermediaries||cnmv.es||Spanish, English|
|Servicio de Reclamaciones de la Dirección General de Seguros y Fondos de Pensiones (DGSFP)
Complaints Service of the Directorate-General of Insurance and Pension Funds (DGSFP)
|Insurance companies, insurance intermediaries, pension providers, pension intermediaries||dgsfp.mineco.es||Spanish|
|Departamento de Conducta de Entidades (Banco de España)
Institutions’ Conduct Department (Banco de España)
|Banks, savings banks, credit co-operatives, payment institutions and some others||bde.es||Spanish, English|
|Sweden||Allmänna reklamationsnämnden (ARN)
National Board for Consumer Disputes
|Banks, mortgage banks, mortgage intermediaries, credit unions, insurance companies, insurance intermediaries, investment providers, investment intermediaries, pension providers, pension intermediaries, securities intermediaries||arn.se||Swedish, Danish, Norwegian and, in principle, English|
d) Liaising with FIN-NET
If you have a cross-border complaint related to financial service provider, such as a bank, an insurance company, an investment firm located in another EU/EEA country than yours, you may either:
- Contact the local Ombudsman at that country (please refer to the table above) or
- Place your complaint via FIN-NET, which is an EU network of national organisations, responsible for settling consumers complaints in the area of financial services out-of-court and complying with the principles set out in Directive 2013/11/EU on alternative dispute resolution (ADR).
Summary of the information with FIN-NET:
– FIN_NET website for more details: https://ec.europa.eu/info/business-economy-euro/banking-and-finance/consumer-finance-and-payments/retail-financial-services/financial-dispute-resolution-network-fin-net/fin-net-network/about-fin-net_en
– FIN-NET Form for cross-border complaints (available in your language):
The FIN-NET member will tell you whether they are able to resolve your problem or may refer you to another organisation that can help you. You may be asked for additional information to assess your case properly. Most FIN-NET members can help you free of charge or at a low cost. They usually reach an outcome within 90 days.
2 – Collective Redress Mechanism
a. For collective litigation – at EU level
The applicable rules for collective action for litigation at European level are detailed in the Directive (EU) 2020/1828 (dated 25 November 2020).
Please find a short summary of your rights foreseen:
- Domestic or cross border representative actions to defend the collective interests of consumer in cases of mass harm can be taken by non-profit based qualified entities (e.g. consumer organizations or independent public bodies);
- Qualified entities can seek at least 2 types of measures for investor protection: injunctive and redress;
- Penalties under the form of fines, for non-compliance with decisions issued within the representative action will be set out by each Member State;
- Depending on the circumstances of the cases (e.g. interim or definitive measures to stop and prohibit a trader’s practice or to eliminate the continuing effects of the infringement), the qualified entities may be able to bring representative actions seeking different types of measures as appropriate.
b. For collective litigation – at country level
A collective redress mechanism, as required under Directive (EU) 2020/1828 on representative actions for the protection of the collective interests of consumers, must be implemented in Luxembourg as well as in your EU/EEA country of residency in 2022. More information will be provided for your country once available.
In the meantime, and in the absence of any specific legal or regulatory mechanisms, you may refer to the website of the CSSF by following this link: www.cssf.lu
It should be noted that this summary addresses rights conferred on Investors under the applicable legislation governing the operation of the Fund(s) in which you are invested.
You may also be afforded rights under other legislation or regulatory frameworks which are not addressed above.
Energy Infrastructure Partners Luxembourg S.à r.l. Sustainability disclosures
Energy Infrastructure Partners Luxembourg S.à r.l. (“EIP Luxembourg”) is authorized to act as an alternative investment fund manager (“AIFM”) within the meaning of Chapter II of the Luxembourg Law of 12 July 2013 on alternative investment fund managers.
Transparency is important to us
In accordance with Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (the “SFDR”), EIP Luxembourg qualifies as a financial market participant in accordance with the SFDR and is therefore required to provide transparency with respect to the following at entity level:
- Article 3 SFDR – Sustainability risk policies
- Article 4 SFDR – Adverse sustainability impacts at entity level
- Article 5 SFDR – Remuneration policies in relation to the integration of sustainability risks
Further transparency requirements apply to the managed investment funds and are included below.
Regardless of the transparency requirements, sustainability considerations are key to EIP Luxembourg and, hence, integrated in its operations. It is EIP Luxembourg’s conviction that investors, as long-term stakeholders, benefit when investments operate their businesses responsibly. Sustainability risks or adverse sustainability impacts can not only harm the investment and its stakeholders, but also expose investments to material risks that can materialize in different ways affecting the activities and the value of the investment.
On the other hand, robust sustainability and ESG practices can be important value drivers.
As per SFDR, sustainability risks are defined as environmental, social and governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment.
EIP Luxembourg established a Sustainability Risk Policy to integrate sustainability factors and risks into its investment decision-making process. This policy also defines the management and monitoring principles of such risks to establish the necessary risk control.
EIP Luxembourg has delegated the portfolio management function to Energy Infrastructure Partners AG which has robust in-house ESG and sustainability expertise. The delegated portfolio manager shall be responsible for the investment decision-making process and the consideration of sustainability risks. Sustainability risks deemed relevant shall be integrated within the due diligence and investment decision-making process and, subsequently, during the asset management phase in accordance with EIP Luxembourg’s Sustainability Risk Policy, which, inter alia, refers to SFDR requirements.
EIP Luxembourg will monitor the integration of sustainability risks in the investment decision-making process as part of the due diligence and ongoing monitoring of the delegated portfolio manager and managed funds.
Transparency of adverse sustainability impacts - No consideration of adverse impacts of investment decisions on sustainability factors at entity level (Art. 4 SFDR)
This statement describes Energy Infrastructure Partners Luxembourg S.à r.l. decision with respect to the requirements of article 4 (1) SFDR regarding the consideration of principal adverse impacts (hereinafter “PAIs”) of investment decisions on sustainability factors.
Transparency of remuneration policies in relation to the integration of sustainability risks (Art. 5 SFDR)
EIP Luxembourg ensures that it adopts remuneration policies and procedures which are consistent with the integration of sustainability risks, to the extent sustainability risks are integrated into the investment decision-making process.
EIP Luxembourg remuneration structures do not encourage excessive risk-taking with respect to sustainability risks and remuneration is limited to risk adjusted performance.
Transparency of the promotion of environmental or social characteristics for EIP Luxembourg managed funds (Art. 10 SFDR)
SFDR article 8 funds managed by EIP Luxembourg promote environmental characteristics as they intend to positively contribute to energy transition, mitigate climate change and/or related environmental challenges. These funds invest in technologies and assets that support the transition to a more decarbonized future and contribute to energy security of supply.
Please find here the full sustainability-related disclosures required for Article 8 financial products: