Complaints Procedure

COMPLAINTS

A complaint can be made via any reasonable means, including letter, telephone, email, and in person.

PROCEDURES

It is the firm’s policy to treat all complaints, whether regulated or not, according to the Complaints Procedures.

Receiving a complaint

All complaints, whether oral or written and made by or on behalf of a customer, will be referred immediately to the person responsible for handling complaints. This is usually the Compliance Director

Any oral or written statement made by a client, which might be considered as a complaint will be referred to the Compliance Director so that it can be determined as to whether is a complaint or not.

Acknowledging a complaint

The Compliance Director will acknowledge the complaint promptly in writing.

In all cases, the written acknowledgement will set out (his/her) understanding of the complaint and will invite the complainant to contact (him/her) if their understanding is incorrect.

The acknowledgment letter will outline the result of the investigation if this has been completed.

If the investigation has not been completed, the acknowledgement letter will confirm that the firm will: -

• provide the complainant with regular updates on our progress if required.
• advise them that if our investigation has not been completed within 8 weeks of our receipt of the complaint, we will write to the complainant informing them why we are not yet in a position to resolve their complaint and provide details of their rights to refer the matter to the Financial Ombudsman Service.
• advise them that on completion of our review, we shall write to the complainant informing them of the outcome.

Investigating a complaint

Any investigation conducted will be fair, consistent, and will be dealt with promptly.

The Compliance Director will investigate all complaints and may, where appropriate, consult the adviser / member of staff whose actions or omissions gave rise to the complaint issue(s) raised.

If the Compliance Director is subject to the complaint, the investigation will then be conducted by The Managing Director.

The investigation will include:

• A review of the relevant client file
• All documents, emails and correspondence will be examined
• Any relevant 3rd parties contacted
• The investigation will take into account any information and/or documents submitted by the complainant

If remedial action and/or redress is to be offered, the type of remedial action and the level of redress will be fair and appropriate.

Resolving a complaint

Following the completion of the investigation, the Compliance Director will issue a written “Final Response Letter” to the complainant.

The Final Response letter will be fair, clear and not misleading and will provide the complainant with:

• Details of the investigation;
• The outcome of the investigation;
• If relevant, any offer of remedial action(s) or the appropriate level of redress (or both), and the basis of calculation;
• Details of their right to refer the matter onto the Financial Ombudsman Service (FOS) and advise that this must be done within 6 months from the date of this letter, or they may lose that right, and contact details of the FOS

A copy of the FOS’s standard explanatory leaflet will be issued with the Final Response letter, unless provided earlier.

If the firm receives confirmation from the complainant that they are satisfied with the findings and outcome of the investigation and/or the redress being offered, the complaint will be considered to be closed by the Compliance Director

Where no confirmation has been received from the complainant within 8 weeks of the firms Final Response, the complaint will also be considered closed. However, under the concept of “Treating Customers Fairly,” should the complainant contact the firm after 8 weeks, we will review any further correspondence accordingly.

Keeping a complainant informed

We will ensure that you are regularly kept informed of our progress with regards to the investigation into your complaint.

Any progress updates will include:

• The reasons for any delay
• What further information / documents we require to resolve their complaint
• When they may expect to receive a further update / our Final Response letter

We will work towards completing our investigation into a complaint within eight weeks of its receipt.

In the event that we have been unable to conclude our investigation within the eight week period, we will write to you, informing you of the reasons for the delay and that if he/she is not satisfied with our progress, he/she may refer the matter to the FOS. A copy of the FOS’s standard explanatory leaflet will have been issues with or before the week 8 response letter.

Financial Ombudsman Service

If a complaint is referred to the FOS, the firm will fully co-operate with them and comply promptly with any settlement and awards made by it.

The firm agrees to be bound by any awards made by the Ombudsman.
The firm undertakes to pay promptly the fees levied by the FOS.

Referring a complaint to another firm

If a complaint is received whereby the firm has reasonable grounds to be satisfied that another firm/provider/lender is solely or jointly responsible for the issue(s) raised, the case will be referred promptly, in a durable medium, to that firm.

The firm will also inform the complainant promptly of the referral and provide them with the other firms/providers/lenders contact details.

If the firm is responsible on a joint basis, we will investigate those issue(s) in line with our normal procedures.

Record Keeping

An entry of each complaint received will be made within the firms Complaints Register, which will be maintained at all times.

The firm will retain a record of each complaint received for at least 3 years from the date the
complaint is received.