1 Purpose

In the course of a continuous index determination internal and external errors may occur. The aim of this policy is the correction of any identified error by applying a consistent and comprehensible approach within a reasonable period of time.

2 Scope

This document describes the procedure applied by Commerzbank Aktiengesellschaft (the “Administrator”) in the case errors occur in the determination or calculation of indices used as underlying for the issuance of factor certificates, ETNs or ETCs (the “Factor Indices”) by Commerzbank Aktiengesellschaft.

3 Procedure

As a general principle of error handling, the Administrator seeks to correct all errors that have been identified within a reasonable period of time. The Administrator applies different treatment of error correction depending on the time elapsed since the error has been identified.

A recalculation of all official index closing levels retrospectively (“Restatement”) of the affected Factor Index will only be applied as far as technically possible, economically reasonable andonly if errors have been detected within two trading days. Where a Restatement of an index level is performed, any uncorrected and erroneous intraday index values are declared invalid.

Errors identified later than two trading days of their occurrence but no longer than 20 trading days will not be restated but corrected. In this context, a “Correction” means that an affected Factor Index is revised only going forward by disposing the error source without adjusting past index values.

However, a deviation from the general principle is necessary for some error types as they differ considerably from each other. Table 1 “Error Treatment” illustrates the differences in detail.

The most common error types are:

• Errors occurring due to a required index adjustment because of a corporate action (including dividend adjustments and any connected tax provisions)
• Data errors due to incorrect calculation parameters, i.e. wrong levels, prices, rates or values of index constituents, costs or fees (including the roll-over of future underlyings).
• Errors due to a misinterpretation or misapplication of the index methodology

If an error event occurs, the following escalation process will be followed:

• The Index Committee will be informed immediately
• In case of a Restatement, the team responsible for the calculation of the affected Factor Index will immediately start with the correction and recalculation of the index without further involvement of the Index Committee.
• In case of a Correction, the Index Committee will in a timely manner instruct the corresponding team to start the correction and defines the date on which the correction shall become effective.
• Each Correction or Recalculation of a Factor Index will be carried out on the basis of a four-eyes-principle and will be duly documented.
• The documentation of each error incident will be stored in accordance with applicable law and internal procedures.
• Any Restatement or Correction shall be announced as soon as reasonably practicable simultaneously to all stakeholders.

4 List of Errors and Treatments – Table 1

Error Type	Restatement	Correction	Effective Date
Corporate Action
corporate actions / dividends / tax rates	Yes, if error occurred within the last 2 trading days	Yes, if error occurred after 2 trading days and no longer than 20 trading days ago	Restatement: immediately/ Correction: Defined by Index Committee
Calculation Parameters
management fee	Yes, if error occurred within the last 2 trading days	Yes, always	Restatement: immediately/ Correction: Defined by Index Committee
ICS / REPO rate	Yes, if error occurred within the last 2 trading days	Yes, if error occurred after 2 trading days and no longer than the last ICS / REPO Adjustment	Restatement: immediately/ Correction: Defined by Index Committee
constituents	Yes, if error occurred within the last 2 trading days	Yes, if error occurred after 2 trading days and no longer than 20 trading days ago	Restatement: immediately/ Correction: Defined by IndexCommittee
roll-over future contract	Yes, if error occurred within the last 2 trading days	Yes, if error occurred after 2 trading days and no longer than the last ordinary roll-over date ago	Restatement: immediately/ Correction: Defined by Index Committee
Index Methodology
Misapplication	Yes, if error occurred within the last 2 trading days	Yes, if error occurred after 2 trading days and no longer than 20 trading days ago	Restatement: immediately / Correction: Defined by Index Committee

5 Handling of Unpredictable Errors

Although table 1 should cover most error types, it cannot be ruled out that under certain circumstances errors of an unforeseen nature in the calculation of Factor Indices may arise. In such rare cases where table 1 provides no clear approach an individual treatment of the incident is unavoidable. In exceptional cases, the Index Committee may also decide even for standard error types to deviate from the error treatment in table 1 and to rather examine the error individually. In these cases, the following procedure applies:

• The Index Committee will be informed immediately.
• The Index Committee will investigate the actual situation based on all relevant information provided by the team members in charge.
• The Index Committee will make a decision in good faith and in an economically reasonable manner after careful consideration of all relevant facts and, to the extent practicable, reflecting the commercial objective of the relevant Factor Index as well as market practice, to what extent the error should be remedied.
• Any Restatement or Correction shall be announced as soon as reasonably practicable simultaneously to all stakeholders.

6 Policy Review

The policy shall be reviewed and updated accordingly on an annual basis.

Please note that Commerzbank has reached an agreement to sell its Equity Markets & Commodities business, which includes the issuance and trading of investment and leverage products as well as the administration of indices, to Société Générale S.A. As part of the transaction Commerzbank envisages the discontinuance of its administration role in respect of indices within the next few years.