OVERVIEW
Providing clients with the best service and dealing with them in a fair, timely, and consistent manner is of paramount importance. If a client expresses dissatisfaction with the Firm or its employees and the matter cannot be resolved by the employee involved, the matter must be escalated to the Legal Counsel for action. The Firm will endeavour to investigate all complaints promptly and resolve complaints within a reasonable period of time. The CEO is ultimately responsible for ensuring that all client complaints are handled in a fair and transparent manner.
INDEPENDENCE
To ensure that clients receive proper handling and investigation of their complaints, no member of staff who was directly or indirectly involved in the subject matter of the complaint will be involved in the investigation and resolution of the complaint. All complaints will be investigated by the Legal Counsel; unless in instances the Legal Counsel is directly or indirectly involved in the subject matter of the complaint. In which case, the complaint will be handled and investigated by the Compliance Officer (CO).
PROCEDURE
We have adopted the following procedures for the quick and fair resolution of client complaints:
- A Client may make a complaint to the Firm in respect of any of the Firm’s activities, or the provision of services relating to the Firm’s activities, or notices, and/or employees through the complaint form available on the Firm’s website, an email sent to [email protected], by raising a support ticket through any of the Firm’s platforms, or via a telephone call to the Customer Service Team.
- When we receive a complaint via our platform including through the complaint form, email, ticket or telephone call, a member of the Customer Service Team will attempt to resolve the complaint as soon as reasonably practical and within one business day of receiving the complaint.
- If a complaint is received via telephone call, the Customer Service Team member is required to accurately document details of the complaint in writing and retain all written records including handwritten notes for such complaints in the client file;
- If a complaint is received from a Client regarding services provided by the Firm that involve third-party Entities (e.g., service providing partners), the Firm shall facilitate the handling of such complaints between the Client and third-party Entities. The Firm will remain responsible for the successful resolution of the complaint.
- If the complaint is resolved to the satisfaction of the client within one (1) business day, the Customer Service Team member who addressed the complaint must provide in writing to the Legal Counsel and CO, details of the complaint and the steps taken to resolve it;
- A complaint is deemed resolved only after a confirmation is obtained from the client (either in writing or via a telephone call which is thereafter documented) that they are satisfied with the resolution of the complaint;
- If the complaint is not resolved to the satisfaction of the client after one (1) business day, the Customer Service Team must escalate the matter to the Legal Counsel and notify the CO;
- The Legal Counsel will notify the client in writing within five (5) business days that his complaint has been received and is being reviewed. The acknowledgement will include the contact details of the individual responsible for handling the complaint; key particulars of the firm’s complaints handling procedures; and a statement that a copy of the procedures is available free of charge.
- The Legal Counsel will investigate the complaint along with any individual Legal Counsel deems appropriate and relevant for a fair and independent enquiry.
- The Legal Counsel will, within 20 business days of receiving the complaint, provide the client with the final response detailing the proposed resolution of the complaint. If the complaint cannot be resolved within 20 business days, the Legal Counsel will notify the client with an update on the status of the complaint, explain any circumstances that is delaying the resolution of the complaint, and indicate the additional time needed to resolve the complaint which must not extend beyond 50 days from the date the complaint was made;
- The Legal Counsel will provide the client with a response that will include measures taken to resolve the complaint (including the redress and its terms), any remedial action taken, and seek a formal acknowledgement of the acceptance or non-acceptance of the proposed resolution by the client. The response will also provide details by which the client can refer the complaint to VARA if the client is not satisfied with the Firm’s proposed resolution of the complaint.
- The Legal Counsel will keep the CO notified throughout the complaint handling and resolution. CO will keep a record of all complaints in the Complaints Register and will report them to the Board on a quarterly basis;
- The Complaints Register will include all records of:
- complaints received from clients;
- all measures taken in response to complaints;
- resolution of complaints
- whether the nature of complaints received is indicative of internal control or process failures or arising from a common root.
- any changes made to address a common root or source of complaint, inadequate or inefficient internal controls and/or processes.
RECORD KEEPING
The Legal Counsel will maintain electronic records of all complaint notifications, investigation papers and other related documents. Electronic copies of these documents will be saved in the Share Point drive. Records will be retained for a period of at least eight (8) year years from the time the complaint was resolved.
ESCALATION If the client is not satisfied with the outcome of the internal complaint handling procedure, the Legal Counsel will provide the contact and email details of relevant persons within VARA to whom the client may refer the complaint.