Client Complaints Handling Policy

Transcription

1 Client Complaints Handling Policy June 2016 TABLE OF CONTENTS: STATUTORY OBLIGATIONS... 2 DETAILED DESCRIPTION OF PROCEDURES... 2 Assignment of responsibility:... 2 General Principles:... 2 Submitting a Complaint:... 2 Acknowledging your Complaint:... 2 Handling your Complaint:... 2 Decision on a complaint:... 3 Resolutions of disputes with customers:

2 STATUTORY OBLIGATIONS We, Felicitas Management Investment Services Ltd (hereinafter, the Company ), are required to establish, implement and maintain effective and transparent procedures for the reasonable and prompt handling of complaints received from our clients or potential clients, and to keep a record of each client complaint and the measures taken for its resolution. DETAILED DESCRIPTION OF PROCEDURES Assignment of responsibility: The Company s Complaints Management Function (hereinafter, the CMF ) is responsible for handling client complaints, in co-operation with the affected units of the Company. General Principles: All units of the Company are required to report any client complaints to the CMF, which is required to handle client complaints honestly and with professional integrity. Withholding information about a complaint submitted by a client is an internal offence and may lead to disciplinary actions. Submitting a Complaint: All client complaints must be submitted in writing (see below), signed by the complainant or a person authorised to act on behalf of the client, and should be as descriptive as possible in respect of the events that led to the filing of the complaint. Complaints which are unsigned and do not contain the name and other details of the complainant will not be considered. If a client communicates a complaint verbally, or by any other means, he/she should kindly be asked to contact the CMF, who will then explain the procedure for handling complaints to the client. Clients are encouraged to use the Complaints Form attached herein and submit it in any of the following ways: 1. By sending by post to: P.O Box 59619, Limassol, 4011, Cyprus 2. By delivering in person at the following address: 13&15 Gregoris Afxentiou St, Ide Ioannou Court, Office 301, Mesa Geitonia, Limassol, 4003, Cyprus 3. Electronically, at the following address: fmis@fmgroupinternational.com 4. By Facsimile at: All complaints received are communicated to the respective manager of the affected business/operations unit. The relevant manager and the CMF should facilitate the investigation of client complaints to the highest possible degree. Acknowledging a Client Complaint: The CMF is required to acknowledge receipt of a client complaint and provide written information regarding the Company s complaints-handling process within five (5) working days from the receipt of a client complaint. A unique reference number of your complaint should be also provided to you, which should be used in all your future contact with the Company, the Financial Ombudsman and/or CySEC, regarding the specific complaint. Handling a Client Complaint: Once we acknowledge receipt of your complaint, we will review it carefully and will try to resolve it without undue delay. The CMF may contact you directly (including communication by or phone) in order to obtain further clarifications and information relating to the complaint. Your cooperation is needed in order to handle the complaint as reasonably and promptly as possible. 2

3 All complaints should be resolved promptly and within a maximum of Thirty (30) working days from the date you have submitted your complaint to us. During the investigation process we will keep you updated of the handling process of your complaint. In the event that your complaint requires further investigation and we cannot resolve it within the expected time limit mentioned above, we will issue a holding response in writing. When a holding response is sent, it will indicate the causes of the delay and when the Company s investigation is likely to be completed. In any event, we shall provide you with the outcome of our investigation no later than three (3) months from the date you have submitted your complaint to us. Decision on a complaint: Upon finalisation of the investigation, one of the following decisions may be taken: On full or partial satisfaction of the complainant On refusal of the complainant satisfaction We will inform the complainant of the outcome of our investigation, together with an explanation of our position and any remedy measures we intend to take. A. Contact Details of the Financial Ombudsman of the Republic of Cyprus: Website: complaints@financialombudsman.gov.cy Postal Address: P.O. BOX: 25735, 1311 Nicosia, Cyprus Telephone: Fax: , If you are not satisfied with our final decision, you may check with the office of the Financial Ombudsman of the Republic of Cyprus in case you are eligible to file a complaint with them and seek mediation for possible compensation. It is important that you contact the Financial Ombudsman of the Republic of Cyprus within four (4) months of receiving a final response from the Company, otherwise the Financial Ombudsman of the Republic of Cyprus may not be able to deal with your complaint. In the unlikely event that the Company was unable to provide you with a final response within the three (3) month time period, you may again contact the office of the Financial Ombudsman of the Republic of Cyprus no later than four (4) months after the date when we ought to have provided you with our final decision. B. Contact Details of the Cyprus Securities and Exchange Commission: Website: General info@cysec.gov.cy Postal Address: P.O. BOX 24996, 1306 Nicosia, Cyprus Telephone: Fax: You may maintain your complaint with the Cyprus Securities and Exchange Commission. However, please note that the Cyprus Securities and Exchange Commission does not have restitution powers and therefore does not investigate individual complaints. It is understood that your right to take legal action remains unaffected by the existence, or use of, any complaints procedures referred to above. 3

4 Resolutions of disputes with customers: In applying high ethical standards, the Company, when providing services to clients, acts honestly, fairly and professionally in the client s best interests, and fully complies with provisions for the protection of the investor, envisaged by the law and European Union Markets for Financial Institutions (Markets in financial instruments directive MiFID) Directives. The Company extends every effort to handle client complaints honestly, fairly and professionally in the clients best interests. In each and every case, the CMF, and other managers and staff members involved in the investigation of complaints, should strive to arrive at a mutually satisfying solution, should it occur that a complaint is founded on reasonable grounds and any compensation demanded is reasonable and fair. 4

5 COMPLAINTS FORM This is the form you may fill in if you wish to submit your complaint to Felicitas Management Investment Services Ltd (the Company ). Complete, up-to-date as well as accurate information is required to be provided to the Company for the proper investigation and evaluation of your complaint. Please note that the below Complaint Form is only indicative and not exhaustive. The Company may request further information and/or clarifications and/or evidence as regards to your complaint. DATE: CLIENT INFORMATION First Name: Surname: Legal Entity Name (in case the Client is a legal person): Account/Plan Number: CONTACT DETAILS OF THE CLIENT Postal Address: City/Province: Post Code: Country: Telephone Number: Please advise your most convenient method of communication: (tick the box) Post DETAILS OF THE COMPLAINT Date when the Complaint was created: Employee/representative who offered the services to the Client: 5

6 Description of the Complaint: (use a separate sheet if necessary) Client Declaration: I hereby certify and confirm that to the best of my knowledge, the information furnished above is true, accurate, correct and complete. Signed: FOR OFFICIAL USE ONLY Received on: Received by: Assigned to: To reply by: 6