Complaints Handling Policy

As a regulated entity, the Company is required to establish, implement and maintain effective and transparent procedures for the reasonable and prompt handling of complaints received from Customers or Potential Customers both with respect to complaints addressed against the Company as well as in respect of complaints addressed against a  counterparty entity which is not the Company. 

  1. In both instances, the Company is responsible for the resolution of the complaint submitted. 
  2. A complaint is an expression of dissatisfaction or displeasure made by a Customer, whether verbally or written, regarding a product and/or service. All verbalised complaints must be formalized and therefore put in writing. This does not mean that one must not look into verbal complaints. Verbal complaints must also be actioned, however one must explain to the Customer that although action will be taken on the basis of a conversation, because of the nature of his/her complaint, it would be in the best interests of both parties, to put the complaint down in writing [Annex 1 – Complaints Handling Form].
  3. All complaints should be directed to the Compliance Officer. Complaints may be submitted by email or by post. The Compliance Officer will subsequently delegate the investigation of the complaints to an employee shall be responsible for dealing with the Customer’s query/complaint and seeing that this is resolved. In this respect, the delegated employee will be responsible to ensure that the Customer’s issue is dealt with as quickly as possible and to the satisfaction of the client.
  4. The submission of a complaint shall not be tied to any fee or consideration.
  5. From the initial discussions with the client and/or information obtained from the delegated employee, the Compliance Officer will immediately be in a position to assess whether the complaint is of a minor nature or whether the complaint is more serious and therefore must be channeled for further investigation in terms of relevant legislation.
  6. The Board of Directors shall ensure that any complaint is investigated thoroughly by an individual who is not involved in the provision of the service subject to the complaint. Furthermore, the individual investigating the complaint must be of sufficient seniority to have access to all information to reconstruct the business transaction.
  7. On receipt of a complaint, the Compliance Officer  shall ensure that an acknowledgement letter is sent out within one week of the complaint being made. This letter shall confirm that:

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  1. The Company will investigate the complaint and;
  2. On completion of the investigation, the Company will write to the Customer concerning the outcome.
  1. The Company shall strive to resolve all complaints within four (4) weeks of the complaint being made.
  2. In extraordinary circumstances where adherence to the four-week timeframe is not possible, the Company must provide the Customer with an update on the status of the complaint, and explain the extraordinary circumstances delaying its resolution within four weeks of the complaint being made. Nonetheless, the Company shall resolve the complaint by not later than eight (8) weeks from when the complaint was made.
  3. In communicating its final decision to the client, the Compliance Officer  shall:
    1. Include a very short description of the complaint, and of the outcome of the Company’s investigation;
  1. Set out the Company’s final view on the issues raised in the complaint; and
  2. Include details of any redress that is being offered, if considered appropriate.
  1. The Compliance officer shall keep a record of:
  1. All complaints received from their clients
  2. All measures taken in response to the complaints
  3. The resolution of all complaint