I. Provision of Information
In the case of submission of complaint to the Company, you may do so either by telephone or in writing, but it is recommended to complete the Online Complaint Form, so as to ensure that all relevant information of the complaint is provided to the Company. The relevant form should be submitted via email to firstname.lastname@example.org.
In either case, the recipient of the complaint shall inform the Client Services Function of the Company, which is responsible for the reception and concentration of complaints and who shall provide all the relevant information required for the analysis and resolution of the complaint to the Compliance Officer and the Internal Auditor of the Company.
II. Unique Reference Number and Complaint Acknowledgment
Upon receiving the complaint, the Client Services Function assigns to the complaint a unique reference number (“URN”) and then registers the complaint directly into an internal register, which is maintained by the Company.
Within 5 days from the receipt of the complaint, the Client Services Function informs you, via Acknowledgement email, that the complaint has been received and is under investigation by also providing the URN. The said URN should be used in your communication with the Company, the Financial Ombudsman and/or CySEC regarding the specific complaint.
The Company reserves the right not to begin a full investigation until you provide all the information required to effectively investigate the complaint. In such cases, you will be informed for the reasons of the delay in resolving the complaint, and we will indicate the time required to complete the investigation, subject to receiving all the information required.
III. Escalation of Complaints
In the following cases, the Compliance Officer and the Internal Auditor shall escalate the complaint to the CEO in order to take all necessary measures for prompt resolution of the issue and prevent any recurrence in the future:
- In case the complaint is due to a deficiency in one of the functions of the Company, or an established wrong practice;
- In case that following an answer, the complaint resubmitted and deemed that the answer is unsatisfactory. If, in continuance of the above case, the reply and handling of the complaint is deemed unsatisfactory, the CEO shall submit the case to the Board.
Any complaint or grievance to the Company that has legal complications is forwarded to the Legal Advisor of the Company, who collaborates with the Compliance Officer, the Internal Auditor and the Board of the Company.
IV. Responding to Complaints
When responding to a complaints, the Company shall ensure that it:
- Communicates in plain language, which is clearly understood;
- Provides a response without any unnecessary delay. When an answer cannot be provided within the expected time limits, you will be informed about the causes of the delay and indicate when the investigation is likely to be completed.
The timeframes set by the Company which are followed when handling complaints are listed below:
- An acknowledgement response is provided within 5 days.
- Resolution is sent as soon as the investigation has been completed and an outcome/decision has been concluded and within 2 months from the submission of the complaint (whichever is the earliest).
- If the complaint is not resolved within 2 months from receipt, explanation should be provided along with the reasons for the delay investigation and an indicative timeframe of completion. This period of time cannot exceed 3 months from the period of submission of the complaint.
If you are not fully satisfied by the final decision of the Company’s position on the complaint , you may refer the complaint to an alternative dispute resolution entity such as the Financial Ombudsman (www.financialombudsman.gov.cy). Furthermore, you may inform the Cyprus Securities and Exchange Commission (www.cysec.gov.cy).
V. Internal Complaints Register and Record Keeping
A Complaints Register is maintained by the Client Services Function of the Company and contains all relevant and latest updated information for all open and resolved complaints received by the Company.
All above records are maintained for a period of 5 years.