Complaints Policy

What information do you need to make a complaint?

Please have the following information available when you call, or include them in any email or letter that you send us:

• Your full name and address
• Order number/reference
• Details of your complaint
• Copies of any correspondence or documents relating to your complaint
• How you wish us to resolve the complaint

What happens once you have made a complaint?

If we are unable to resolve your complaint at first contact, or you or someone on your behalf, would prefer to submit your complaint in an alternative medium, your concerns will be fully investigated by our complaint handler.

Once your complaint is submitted, we shall send you an acknowledgment correspondence within 10 working days. A final response will be issued to you within eight weeks of the initial receipt of your complaint. It will explain our reasons for the conclusion or alternatively, why we are not able to issue a final response at this time.

During this time, our complaint handler may need to contact you to seek additional information or clarification to ascertain the facts surrounding your complaint.

If we uphold your complaint, we will take all appropriate steps to rectify the error promptly, offer an apology for the error and where appropriate, may offer redress or remedial action.

The Financial Ombudsman Service

If you are not satisfied with our final response you have the right to escalate the complaint to the Financial Ombudsman Service, their contact details can be found below. You must do this within six months of our final response. Conversely, you are unable to escalate a complaint until the full 8 weeks has lapsed.

When we send you our final response, we will also provide you with a copy of the Financial Ombudsman Service’s explanatory Leaflet. Alternatively, you can obtain a copy from:

Post: Financial Ombudsman Service, Exchange Tower, London E14 9SR

Online: www.financial-ombudsman.org.uk

By freephone: 0800 023 567 *

Or Standard Telephone: 0300 123 1 123 *

Outside of the UK: +44 20 7964 0500

* calls are charged at the same rates as 01/02 number on mobile tariffs.

Time Restrictions

The Financial Ombudsman Service will only consider complaints that have received a final response from the firm. The Financial Ombudsman Service is unable to accept complaints more than 6 months after the final response was issued or more than six years after the event complained or (if later) three years from the date on which the complainant became aware (or ought reasonably to have become aware) that he had cause for complaint; unless the complainant referred the complaint to the respondent or to the Ombudsman within that period and has a written acknowledgement or some other record of the complaint having been received.

Updates

We may change this policy from time to time by updating this page. This may occur due to change in regulatory framework or a change in contact information. Any changes to this policy will be made here.

When will the complaint be resolved?

We will consider a complaint resolved when we have received a confirmation from the complainant that explains they have accepted the findings in our final response. Should the complainant be unhappy with our final response, they may escalate their complaint to the Financial Ombudsman Service as detailed above.

The Complaint Investigation

The nominated complaint handler will always be responsible for the investigation of complaint. Input will be sought from other employees or external support, where the nominated complaint handler is in connection with the allegations made.

We will retain a log of all complaints received and the outcome. A complaint file will be created for each complaint, reference to the log, and which will contain all communication with complainants, the actions taken to investigate the complaint, the findings and a copy of the final response to the complainant.

Root Cause Analysis

Upon completing the investigation of a complaint, the nominated complaints handler shall conduct a root cause analysis of the complaint to ascertain the cause of the complaint and the risk of that cause reoccurring. Where the cause is compliance system or operational processes the nominated complaint handler shall submit a report to the senior management team.

Trend Analysis

Each month the nominated complaint handler shall compile MI in reflection of any complaints received into the firm; inclusive of the resolution or otherwise of those complaints, and sufficient analysis to enable the board to understand any causes of those complaints including any trends which may exist within those complaints and other current or historic complaints. This will enable the firm to assess whether there may be a systemic problem within the firm.

Complaints Register

We will maintain a complaint register which will be the subject of periodic review. A lack of complaints recorded may indicate that we do not recognise what a complaint is or have concerns that recording a complaint may reflect negatively upon themselves.

Storage

We shall store our complaint register within a secure server, accessible via restricted users. Any additional access is to be confirmed by the firms nominated complaint handler. There will be no access by any external persons, unless a lawful basis exists, and such a request is made in writing.

Retention

We will retain all complaint data for 6 years.