Complaints Handling

We will ensure any complaint can be made free of charge and the contact number for making a complaint will not involve a premium rate number.

 

Once we are in receipt of a complaint it will be immediately recorded within our complaints register.

Following this, an initial assessment will be carried out to determine if an immediate resolution can be made. Where this is possible, you will receive a written summary of our findings and conclusion (summary resolution). Where this is accepted within three business days (by the close of the third full day) the case will be closed.

Where this is not possible, a written acknowledgement will be issued to you within five business days and will set out the basis, or understanding, of the complaint.

A copy of our ‘dealing with your complaint’ leaflet will be included within either of these communications.

We will ensure you are kept informed of the progress of the measures being taken for the complaint’s resolution.

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Appropriate Investigation of Complaints

We will ensure that all complaints are investigated by an individual with sufficient competence and experience who, where appropriate, was not directly involved in the matter giving rise to the complaint. 

We will aim to resolve any complaints as quickly as possible.

The person responsible for the investigation of the complaint (usually the Compliance Officer) will examine, in detail, all documentation in relation to the complaint and will interview, where appropriate, any staff with an involvement in the content of the complaint.  Communication with any connected parties will be fully recorded on the complaint file as will copies of all correspondence.

Additional information will be requested as necessary to investigate the complaint fully.

We will endeavour to resolve complaints at the earliest possible opportunity and within 8 weeks of its receipt.

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We will then issue a final response. If however we are not in a position to issue this within the above time period, a letter will be sent to you explaining:

1. the reason for the continued delay

2. when the firm anticipates being able to provide a final response

3. your right to refer the matter to the Financial Ombudsman Service and enclosing a copy of the Financial Ombudsman Service’s leaflet

  

 

Financial Ombudsman Service time limits

Our summary resolution communication and final response letters will make it clear to the complainant whether the firm is willing to waive the time limits for cases referred to the FOS.

Where the firm receives a complaint which is outside the time limits for referral to the FOS, the firm will contact the complainant to discuss and consider whether there are exceptional circumstances for missing the deadline and consider matters such as a period of serious ill health, or a bereavement at the relevant time in question.

The Final Response

Once all enquiries are complete, the Compliance Officer will draft a response for issue to you. 

Where redress is appropriate, we will provide you with fair compensation for any acts or omissions for which it was responsible. The Compliance Officer has the necessary authority to offer redress.

We will comply with redress offers accepted by you. Redress need not be financial and could include, for example; an apology. The final response letter will explain your right to refer the matter to the Financial Ombudsman Service. 

Following our response you have a six-month timescale to refer the matter to the Ombudsman, which commences on the date that the final response is issued by the firm.

The result of the investigation will be entered into the Complaints Register.

A complaint will be deemed closed:

• Once the investigation has been completed and a final decision letter has been issued to the complainant; or

• Where we receive confirmation that the complainant is satisfied with the outcome of the investigation and a summary resolution communication has been issued (resolved within three business days from receipt); or 

• Where the complainant has indicated in writing acceptance of the firm’s earlier response, where appropriate

 

Co-operation with the Ombudsman

We will co-operate at all times with the requirements of the Financial Ombudsman Service and comply promptly with any settlements or awards made by it.

If the case is referred to the Ombudsman, the Compliance Officer will submit a report along with any supporting documentation.

Record Keeping

We will keep a record of each complaint received and the measures taken for its resolution, and retain that record for a minimum period of:

1. At least 5 years where the complaint relates to MiFID business; and

2. Three years for all other complaints.

 

Complaints about other firms

 

Where a complaint is received in respect of advice provided by another firm, it is important that the customer is treated fairly.  In such circumstances, the complaint should be acknowledged promptly. Once we are satisfied that the other firm is responsible, the customer should be provided with the contact details of the firm concerned in the form of a final response letter.

Additionally, a copy of the complaint should be forwarded to the firm concerned requesting that they make contact with the complainant.

Where there may be a joint liability in relation to a complaint, the procedure discussed above should be followed as well as the firm responding to part of the complaint that is relevant to it in accordance with the complaints procedures.   

 Such complaints should be recorded within the complaints register.

Where we receive a referred complaint, it should deal with the complaint in accordance with our standard complaints procedure with time limits applying from the date on which we receive the complaint referral.