Complaint Handling Procedure

Exchange4free Complaints Handling Policy

This document sets out the Exchange4free Ltd complaints procedure. It has been prepared in accordance with the requirements set out in the Dispute Resolution Complaints Sourcebook issued by the Financial Conduct Authority and demonstrates our aim to treat customers fairly at all times. We believe it meets those requirements.

1. The Nature of a Complaint

These procedures cover any expression of dissatisfaction, whether oral or written, and whether initially justifiable or not, made by or on behalf of a complainant about the provision of, or failure to provide, a financial services activity by our firm. In the course of our investigations we will identify whether or not any complaint made meets the definition set out by the Financial Conduct Authority.

2. Eligible Complainant

In order to be eligible to make a complaint about our firm under the Dispute Resolution: Complaints Sourcebook you have to meet certain criteria. These criteria are that the complainant must be:
  • a private individual consumer, or
  • a business which has an annual turnover or balance sheet of less than 2,000,000 EUR at the time of the complaint, or
  • a charity which has an annual income of less than £1,000,000 at the time of the complaint, or
  • a trust which has net assets of less than £1,000,000 at the time of the complaint
In addition to meeting one of the above criteria you must have been a customer of the firm at the time the complaint arose and the complaint must arise out of matters relevant to your having been a customer of our firm.

One of the first steps we will take when receiving a complaint is to identify whether a complainant is eligible. If we decide that the complainant is not eligible then we will write to that complainant accordingly and state our reason for coming to that decision. We will review any response by that complainant to see whether or not the correct decision has been made. Upon receiving further information we will write to the complainant again saying whether or not they are now eligible.

3. Availability of our Complaints Procedure

It is our duty to make sure that you are aware of our complaints procedure. You will be made aware of the basic principles at the point of sale, and then issued with a full procedure document should you actually wish to make a complaint.

In addition to making the procedure known to you we have posted a copy and made notice on our website indicating that we are covered by the Financial Ombudsman Service.

4. The Procedure

Your complaint will be investigated by our compliance officer who has sufficient competence to deal with the complaint and who preferably has not been involved in the matter, which is the subject of the complaint. We will also ensure that the person dealing with the complaint either has the authority to settle your complaint or can have ready access to somebody who can make a decision on your complaint.

5. Time Limits

We will respond to your complaint within 7 business days of its receipt and give you the name or job title of the person handling the complaint and let you have a copy of this procedure if you have not already received a copy.
We will deal with your complaint by the end of 15 business days after the day on which it was received but if this is not possible, due to exceptional circumstances outside of our control, then by the end of 35 business days after the day on which it was received.
By the end of this period we hope to have resolved your complaint. If it has not been resolved by then we will provide you with more information about the Financial Ombudsman Service and you can refer your complaint to that service should you wish to do so.

6. Final Response

When we give you our final response we will explain to you all the reasons why we have come to our conclusion. If we feel that redress is appropriate we will show how we have calculated this based on what we believe is fair and appropriate to your complaint.

At the same time we will confirm that you have a copy of the Financial Ombudsman Service’s explanatory leaflet. This will enable you to refer the matter to the Ombudsman should you be dissatisfied with our decision.

You will have a window of 6 months from receipt of our final decision in which to refer the case to the Financial Ombudsman Service after which it will be concluded that you are satisfied with our investigation and findings.

7. Third Party Representation

We are happy to deal with nominated third party representations throughout the whole of this procedure subject to your (The complainants) letter of authorisation.

Director of Compliance

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