On the receipt of a complaint, the Compliance Officer of the Firm shall acknowledge the complaint in writing. The acknowledgement of the receipt of the complaint shall be sent by the Compliance Officer within 5 working days of the receipt of the complaint. Along with an acknowledgement the Compliance Officer shall:

• share the contact details of the relevant employee responsible for handling the complaint; and
• state that a copy of the complaint handling procedures is available free of charge upon request

After acknowledgement of the complaint, the Compliance Officer will consider the subject matter of the complaint and shall forward it to the Chief Financial Officer (who shall also discharge the function of the Complaints Officer) with a recommendation of an employee to handle the complaint resolution. In the event the CFO was involved in the provision of the service about which the complaint has been made, the Compliance Officer shall direct another employee to investigate the complaint. In all cases, the relevant employee shall: 

• handle the complaint in a fair and impartial manner;
• have sufficient authority to resolve the complaint; and 
• have access to individuals with the necessary authority

If the platform considers another Financial Institution to be entirely or partly responsible for the complaint, it will forward the complaint to the Financial Institution only after it receives approval from the complainant to do so. This shall only be done after the below procedures have been adhered to: 
 

• the complainant has been informed (in writing) that the Firm shall refer the complaint (either entirely or in part) to another Financial Institution; 
• the complainant has consented the Firm to refer the complaint to another Financial Institution; 
• the complainant has been provided with adequate details of any individual at the other Financial Institution responsible for handling the complaint; and 
• any part of the complaint not referred to, is dealt with by the relevant employee. 

If the relevant employee expects the resolution of the complaint to take longer than 7 days, he/she will update the complainant weekly on the progress of the complaint.

Upon conclusion of the investigation of the complaint, the platform will:

• advise the complainant in writing on the resolution;
• offer the complainant with terms of compensation (if any); and
• fulfil the terms of compensation, if accepted by the complainant

The platform will update its systems and controls in order to remedy any problems identified from the complaint. 

If the complainant is not satisfied with the terms of the compensation, the Compliance Officer shall inform the complainant of an alternate avenue (and their contact details) for resolution of the complaint.  

The platform will maintain records of all complaints made against it for a period of six years. The records will contain the name of the complainant, the substance of the complaint and the Firm’s response and/or action taken by the Firm.