Complaints Procedure

1. Purpose

You expect a first-class service from us and that is what we aim to provide. However, on occasion you may not be happy with our service or a financial product. This may be because of the nature of the service or product or there may be more to it.  If there is a problem, or you are not happy with something, please tell us and we will try to put things right. If you don’t understand something, please ask us for an explanation. If we understand the problem or any concerns you may have, we can often explain it in a clearer way or resolve it quickly and easily.

If you are not happy with the answers we give you, you may need to make a complaint.

These notes have been written to explain to you how we deal with complaints. If you have any questions about the content please contact our Compliance Partner, Julian Ellis.

2. What is a complaint?

As far as we are concerned a complaint is any expression of dissatisfaction by, or on behalf of, a client, whether oral or written and whether justified or not.  Some complaints can be handled relatively informally and quickly, however, if it involves allegations of financial loss, material inconvenience or distress it will have to go through our “regulated” complaints process.

3. Who can complain?

You or someone else can complain on your behalf.  If someone does complain on your behalf we will require your written permission to allow us to deal with them.

4. What do we do if we receive a complaint?

All regulated complaints are referred to our Compliance Partner for independent investigation. We will try to resolve the matter in a timely manner and, where possible, within three business days.  If we cannot, we will keep you informed of progress.

We aim to:

  1. Establish whether you are what is called “an eligible complainant”. This means whether you have the right to refer your case to the Financial Ombudsman Service.  We will tell you if we believe that you are an eligible complainant.  However, even if we think you are not, it is for the Ombudsman to decide who is and is not an eligible complainant;
  2. Investigate your complaint competently, diligently and impartially;
  3. Assess your concerns fairly, consistently and promptly;
  4. Respond as quickly as possible;
  5. Inform you of your rights.

If the complaint relates to another company, we will pass your complaint on to that company and tell you what we have done. If it involves us and another company, we will liaise with the other company to resolve the problem and keep you informed of what we are doing.

5. Acknowledging your complaint

We will acknowledge your complaint in writing within five business days. We will explain our understanding of your complaint and invite you to confirm (if our understanding is incorrect) the nature of your complaint.

The acknowledgement letter will outline the results of the investigation if it has been completed by then. If it has not been completed, we will:-

  1. Highlight that if the investigation is not completed within a reasonable time following receipt of your complaint, you will be informed of the reasons for the delay; and
  2. Highlight that if the investigation is not completed within eight weeks following the initial receipt of your complaint, you will be informed of what further action you may take; and
  3. Point out that on completion of the investigation you will be informed of the outcome and the options available to you.

6. Progress of our investigation

If we have not completed our investigation within eight weeks, we will write to you informing you of the reasons for further delay. If you are an eligible complainant and are not satisfied with progress, you may refer the complaint to the Financial Ombudsman Service. The letter will include the name, address, website and telephone number of the Ombudsman and a leaflet about the Ombudsman’s arrangements.

7. Conclusion of our investigation

On completion of the investigation we will write you a “conclusion” letter advising you of the outcome of the investigation and the nature and terms of any proposed settlement.  If you remain dissatisfied with the outcome you may refer the matter to the Financial Ombudsman Service or the Pensions Ombudsman.  Both are free of charge.  If the complaint is about a MiFID instrument we will tell you about your right to take court action through the civil courts.  We will tell you if you have rights to complain under more than one system.

8. What if you are still not happy with what we have done?

If you are unhappy with anything and we have not been able to resolve it through our complaints procedure, one of the following organisations may be able to help.

If you are an eligible complainant and intend to refer the matter to the Financial Ombudsman Service, you must do this within six months of our conclusion letter we send you or you may lose that right to do so. If you do not refer your complaint in time, the Ombudsman will not have our permission to consider your complaint and so will only be able to do so in very limited circumstances; for example, if the Ombudsman believes that the delay was because of exceptional circumstances. Our letter will point this out to you. But, it is the Ombudsman who decides what exceptional circumstances are.

If the matter is about pension administration you may have the right to refer your complaint to the Pensions Ombudsman.

Organisations that may be able to help you

Financial Ombudsman Service The Pensions Ombudsman
Exchange Tower 11 Belgrave Road
London London
E14 9SR SW1V 1RB
08000234567 08009174487
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