COMPLAINT HANDLING POLICY
Centralspot Trading Ltd (hereinafter the “Company) is an investment firm that is established in the Republic of Cyprus and is authorized by the Cyprus Securities and Exchange Commission (the “CySEC”) pursuant to the Law L. 87(Ι)/2017 (hereinafter the ‘Law’), to provide one or more investment services to third parties and/or perform one or more investment activities in accordance with its Cyprus Investment Firm (“CIF”) authorization.
The Company classifies a complaint as any grievance/dissatisfaction involving the activities of those persons under the control of the Company (Employees), in connection with the provision by the Company of the investment and/or ancillary services it provides.
The target of the Company is to deliver a consistent, high-quality and accountable response to the complainant.
- Legal Framework
In accordance with provisions of the Law and Circular C338 , a CIF is required to establish, implement and maintain effective and transparent procedures for the reasonable and prompt handling of complaints or grievances received from retail or potential retail clients, and to keep a record of each complaint or grievance and the measures taken for the complaint’s resolution.
A “Complaint” is a statement of dissatisfaction formally addressed by the Client to the Company regarding the provision of investment and/or ancillary services provided by the Company
A “Complainant” is any client which is eligible for lodging a complaint.
The procedure sets out the method for the submission of complaints with the Company when dealing with complaints received by the clients. The purpose of the Complaint Handling Policy (hereafter “CHP) outlines the procedures that are implemented when handling client complaints.
- Procedure for Handling Client Complaints
3.1 How to file a Complaint:
The Complainant/Client are able to file a complaint to the Company by sending a written complaint to the Company’s email firstname.lastname@example.org. All complaints must be in writing and shall be addressed, in the first instance, to the Customer Support Department. Where the Client receives a response, which does not satisfy him, he has the right to ask Support to escalate the complaint to the Compliance Department. The Clients shall provide the following details when submitting their complaints via email:
- E-mail to email@example.com.
- The Client’s name and surname.
- The Clients Trading Account Number.
- The identification numbers of the relevant Orders and Positions (if applicable).
- The date that the issue arose and the description of the issue.
- The capital and the value of the Financial Instruments which belongs to the Client (if applicable).
- Reference of any correspondent exchanged between the Company and the Client (if applicable).
- Any other relevant information.
3.2 Handling Complaints:
- Upon receipt of the complaint the Client shall receive a formal written acknowledgement within five (5) business days by the Support Department. The client will receive an email advising that the complaint has been received and it is under investigation.
- The complaint will be investigated and if deemed necessary it will be escalated to the Compliance department where the complaint is addressed to be further verified and investigated and you will be provided with a unique reference number of your complaint. The unique reference number should be used in all your future contact with the Company, the Financial Ombudsman and/or CySEC regarding the specific complaint.
- The events leading to the complaint or grievance and all the information provided by the client, will be examined and assessed in order to reach a fair outcome.
- The client will be informed at all the times by the CIF in regards to the handling process of his/her complaint. In particular, the findings and proposed solutions that shall be clearly explained in written form to the client within the agreed time frame.
- If an issue cannot be resolved within the specified period due to the complicated nature of the complaint or further clarification of circumstances is required, the complainant shall be notified of the new timeframes of response for the complaint. Which shall not exceed the two months.
- In the event that the Company is unable to respond within two months, it informs the complainant of the reasons for the delay and indicates the period of time within it is possible to complete the investigation. This period of time cannot exceed three months from the submission of the complaint.
- The Complainant/Client, if not satisfied with the resolution of the Complaint, may approach the Financial Ombudsman of the Republic of Cyprus and/or the CySEC, using the assigned unique reference number provided by the Company and/or the relevant Courts.
- Final Decision
When we reach an outcome we will inform you of it together with an explanation of our position and any remedy measures we intend to take (if applicable).
If you are not satisfied with the Company’s final decision you may submit your complaint to the Financial Ombudsman of the Republic of Cyprus and seek mediation for possible compensation. It is important that you contact the Financial Ombudsman of the Republic of Cyprus within four (4) months of receiving a final response from the Company otherwise the Financial Ombudsman of the Republic of Cyprus may not be able to deal with your complaint.
In the unlikely event that the Company was unable to provide you with a final response within the three (3) month time period specified above you may again contact the office of the Financial Ombudsman of the Republic of Cyprus no later than four (4) months after the date when we ought to have provided you with our final decision.
- Contact Details of the Financial Ombudsman of the Republic of Cyprus:
Postal Address: P.O. BOX: 25735, 1311 Nicosia, Cyprus
Fax: +35722660584, +3572266011
- Contact Details of the Cyprus Securities and Exchange Commission:
General email: firstname.lastname@example.org
Postal Address: P.O. BOX 24996, 1306 Nicosia, Cyprus
You may maintain your complaint with the Cyprus Securities and Exchange Commission, however please note that the Cyprus Securities and Exchange Commission does not have restitution powers and therefore does not investigate individual complaints.
Further information as to the procedure you need to follow can be found on https://www.cysec.gov.cy/enGB/complaints/how-to-complain/
It is understood that your right to take legal action remains unaffected by the existence or use of any complaint procedures referred to above.
- Record Keeping
The Company shall maintain all complaints for a minimum period of five years, by the Compliance Department.
- Review of the CHP
This Policy will be reviewed and/or amended at annually or as when considered necessary by the board or when changes or amendments to operating requirements are issued by the Commission.
V 2.0 28.04.20