Complaints Handling Policy
Complaints Handling Policy Note: The English version of this Agreement is the governing version and shall prevail whenever there is any discrepancy between the English version and the other versions. 1. Introduction GS Sharestocks Ltd (the “Company”) strives to implement and maintain effective and transparent procedures for the reasonable and prompt handling of complaints or grievances received from its retail or potential retail clients. 2. Complaint or grievance handling
The Company shall take all necessary measures required for the effective and prompt resolution of complaints or grievances. To that effect, the Company hereby sets out important information for its clients regarding the Complaints-handling process, as well as the actual procedure that needs to be followed by the client ensuring effective and prompt resolution of complaints. For this purpose, ‘Complaint’ shall be defined as an expression of dissatisfaction addressed to the Company by the complainant in relation to the provision of investment services. Procedure on how to lodge a complaint and the complaints-handling process:
If you wish for any reason to lodge a complaint, then the procedure outlined below shall be followed by both the client and the Company for effective and prompt resolution of complaints. You may submit a complaint to us by telephone, or by email to [email protected]. In case of submission of complaints via telephone depending on the nature and seriousness of the complaint, a member of the Company may advise you to submit your complaint in other form (i.e. via email) if
required, so that it can be addressed in a formal and appropriate manner to the relevant department for formal investigation. We will send you a written acknowledgement of your complaint within 5 days following receipt, enclosing details of our complaints procedures (as outlined below), including when and how you may be able to refer your complaint to the Cyprus Securities Exchange Commission ("CySEC") which is the relevant regulatory body. For Trivial Complaints (defined below), taking into consideration the nature of the Complaint, the Company strives to resolve matters immediately, if possible. In such cases, where the complaint is considered to be of trivial nature and can be resolved immediately and effectively in an appropriate manner, you do not need to submit a formal/written complaint. ‘Trivial Complaints’ include but are not limited to matters such as clients training, communication issues, platform/system access issues and any other matters that can be resolved immediately within a short period of time and effectively without the need of extensive investigation In any other case, the complaint should be dealt with in a formal manner in line with the Company’s policies and procedures as outlined below: (i) How to lodge a Formal Complaint:
a. You may submit your complaint via email to the following address: [email protected] b. You shall provide the following details when you submit your complaint via email: i. Identification particulars (Full name, ID or passport number, contact detailsemail and telephone no., country of residence) ii. Service provided to you by the Company related to the complaint, i.e. portfolio management. iii. Name of Company’s employee that you had contact with and/or the relevant
department. iv. Date on which an event (if applicable) has occurred. v. Cause and details of the complaint to be expressed clearly in plain English language. (Please express clearly the facts, comments and the reasons leading to the complaint). vi. Capital and value of the financial instruments that belong to you and are relevant to the complaint. vii. Disputed Amount (if applicable). viii. Any other detail relevant to the complaint (i.e. correspondence etc.). c. The above information is required in order for the relevant department to process effectively the complaint for prompt handling and resolution. d. Once you provide the above information through the email you are about to submit, please use as subject of the email your full name and your Account ID Number. e. Then please submit via sending an email at: [email protected] f. You will be contacted via email for more information relating to the handling procedure of your complaint. (ii) The Complaint-handling process is as follows:
a. Please note that you shall receive an acknowledgement of receipt confirmation email, including all of the aforementioned information within 5 (five) working days from the date of submission of the complaint. b. Upon safe receipt of the formal complaint following the above process, the complaint will be recorded in an internal register, giving it a unique reference number. c. The complaint is initially handled by a member of our Back Office Department. d. The complaint or grievance is then forwarded to the head of the department where the complaint is addressed (within 3 (three) working days).
e. Upon acknowledgement of receipt of the complaint you shall be contacted by a member of the Back Office Department to inform you that the complaint or grievance has been received and forwarded to the relevant department/personnel for investigation. f. You will be given a unique reference number for the specific complaint as referred to above, which you shall use in all future contact with the Company, the Financial Ombudsman and/or the CySEC regarding the specific complaint. This reference number will be communicated to you via email, per point (e) above. g. You will also be informed about the complaint-handling process as published here from our website for your ease of reference. h. The Company, depending on the nature, importance and complexity of a complaint may investigate a complaint and respond with the outcome/decision within 2 (two) months from the day the original complaint is received. However, if a complaint is not resolved within the period of 2 (two) months, the Company will inform you in detail about causes of delay, a status of the investigation process and an expected date of completion of the investigation. i. Please note that the total investigation period will not exceed 3 (three) months from the date of submission of the complaint. j. During the investigation period, the Company shall keep you informed about further handling of the complaint. k. You may be contacted during the investigation period in order for us to obtain further information regarding the complaint if required. (iii) Completion of investigation and the final outcome/decision:
a. Upon completion of the investigation, you shall be informed about the outcome/decision of the Company relating to your complaint by receiving a formal response including any action that needs to be taken. b. If the Company decides that the complaint is not valid, you shall be informed about the reasons behind the Company’s decision/outcome.
c. If the Company’s final decision does not fully satisfy your demands, you will be formally notified in writing by the Company, with a thorough and clear explanation about the Company’s position on the relevant complaint. d. Please note that if you are not fully satisfied with the Company’s final decision and wish to pursue the matter further, you have the option and right to maintain the specific complaint through CySEC, the Financial Ombudsman, ADR Mechanism, or the relevant Courts. (You shall be informed accordingly upon receipt of Company’s final decision). 3. Important Information to Clients
It should be noted that the Company makes all best efforts to ensure that in the case of the complaint or grievance being of such nature that can be resolved immediately, to do so, in order to avoid unnecessary delays and procedures for the prompt and effective resolution of complaints.
The Company shall take all necessary measures required for the effective and prompt resolution of complaints or grievances. To that effect, the Company hereby sets out important information for its clients regarding the Complaints-handling process, as well as the actual procedure that needs to be followed by the client ensuring effective and prompt resolution of complaints. For this purpose, ‘Complaint’ shall be defined as an expression of dissatisfaction addressed to the Company by the complainant in relation to the provision of investment services. Procedure on how to lodge a complaint and the complaints-handling process:
If you wish for any reason to lodge a complaint, then the procedure outlined below shall be followed by both the client and the Company for effective and prompt resolution of complaints. You may submit a complaint to us by telephone, or by email to [email protected]. In case of submission of complaints via telephone depending on the nature and seriousness of the complaint, a member of the Company may advise you to submit your complaint in other form (i.e. via email) if
required, so that it can be addressed in a formal and appropriate manner to the relevant department for formal investigation. We will send you a written acknowledgement of your complaint within 5 days following receipt, enclosing details of our complaints procedures (as outlined below), including when and how you may be able to refer your complaint to the Cyprus Securities Exchange Commission ("CySEC") which is the relevant regulatory body. For Trivial Complaints (defined below), taking into consideration the nature of the Complaint, the Company strives to resolve matters immediately, if possible. In such cases, where the complaint is considered to be of trivial nature and can be resolved immediately and effectively in an appropriate manner, you do not need to submit a formal/written complaint. ‘Trivial Complaints’ include but are not limited to matters such as clients training, communication issues, platform/system access issues and any other matters that can be resolved immediately within a short period of time and effectively without the need of extensive investigation In any other case, the complaint should be dealt with in a formal manner in line with the Company’s policies and procedures as outlined below: (i) How to lodge a Formal Complaint:
a. You may submit your complaint via email to the following address: [email protected] b. You shall provide the following details when you submit your complaint via email: i. Identification particulars (Full name, ID or passport number, contact detailsemail and telephone no., country of residence) ii. Service provided to you by the Company related to the complaint, i.e. portfolio management. iii. Name of Company’s employee that you had contact with and/or the relevant
department. iv. Date on which an event (if applicable) has occurred. v. Cause and details of the complaint to be expressed clearly in plain English language. (Please express clearly the facts, comments and the reasons leading to the complaint). vi. Capital and value of the financial instruments that belong to you and are relevant to the complaint. vii. Disputed Amount (if applicable). viii. Any other detail relevant to the complaint (i.e. correspondence etc.). c. The above information is required in order for the relevant department to process effectively the complaint for prompt handling and resolution. d. Once you provide the above information through the email you are about to submit, please use as subject of the email your full name and your Account ID Number. e. Then please submit via sending an email at: [email protected] f. You will be contacted via email for more information relating to the handling procedure of your complaint. (ii) The Complaint-handling process is as follows:
a. Please note that you shall receive an acknowledgement of receipt confirmation email, including all of the aforementioned information within 5 (five) working days from the date of submission of the complaint. b. Upon safe receipt of the formal complaint following the above process, the complaint will be recorded in an internal register, giving it a unique reference number. c. The complaint is initially handled by a member of our Back Office Department. d. The complaint or grievance is then forwarded to the head of the department where the complaint is addressed (within 3 (three) working days).
e. Upon acknowledgement of receipt of the complaint you shall be contacted by a member of the Back Office Department to inform you that the complaint or grievance has been received and forwarded to the relevant department/personnel for investigation. f. You will be given a unique reference number for the specific complaint as referred to above, which you shall use in all future contact with the Company, the Financial Ombudsman and/or the CySEC regarding the specific complaint. This reference number will be communicated to you via email, per point (e) above. g. You will also be informed about the complaint-handling process as published here from our website for your ease of reference. h. The Company, depending on the nature, importance and complexity of a complaint may investigate a complaint and respond with the outcome/decision within 2 (two) months from the day the original complaint is received. However, if a complaint is not resolved within the period of 2 (two) months, the Company will inform you in detail about causes of delay, a status of the investigation process and an expected date of completion of the investigation. i. Please note that the total investigation period will not exceed 3 (three) months from the date of submission of the complaint. j. During the investigation period, the Company shall keep you informed about further handling of the complaint. k. You may be contacted during the investigation period in order for us to obtain further information regarding the complaint if required. (iii) Completion of investigation and the final outcome/decision:
a. Upon completion of the investigation, you shall be informed about the outcome/decision of the Company relating to your complaint by receiving a formal response including any action that needs to be taken. b. If the Company decides that the complaint is not valid, you shall be informed about the reasons behind the Company’s decision/outcome.
c. If the Company’s final decision does not fully satisfy your demands, you will be formally notified in writing by the Company, with a thorough and clear explanation about the Company’s position on the relevant complaint. d. Please note that if you are not fully satisfied with the Company’s final decision and wish to pursue the matter further, you have the option and right to maintain the specific complaint through CySEC, the Financial Ombudsman, ADR Mechanism, or the relevant Courts. (You shall be informed accordingly upon receipt of Company’s final decision). 3. Important Information to Clients
It should be noted that the Company makes all best efforts to ensure that in the case of the complaint or grievance being of such nature that can be resolved immediately, to do so, in order to avoid unnecessary delays and procedures for the prompt and effective resolution of complaints.
