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Complaints Handling Policy

Introduction

GWG (Cyprus) Ltd (hereafter the “Company”) is an Investment Firm incorporated and registered under the laws of the Republic of Cyprus, with registration number C342580. The Company is authorised and regulated by the Cyprus Securities and Exchange Commission (hereafter the “CySEC”) under the license number 291/16

The Investment Services and Activities and Regulated Markets Law of 2007 (Law 144(I)/2007), including all its amendments and the Directives issued by CySEC (the “Regulations”) are the regulatory framework that governs Trading in Financial Instruments.

In accordance with paragraph 13 of DI144-2007-01 of 2011 and CI144-2012-05, the Company maintains an effective and transparent procedure for handling complaints and grievances from clients. The Company keeps records of each complaint or grievance including all measures taken for its resolving. Additionally, the company has in place a committee to handle all submitted complaints. This Committee will be composed of the following persons:

  • Executive Director
  • Compliance Officer
  • Back Office Manager
  • The Head of the department involving the specific submitted complaint

The head of the ‘Complaints Handling Committee’ is the company’s Compliance Officer who will also be the person in charge of Complaints Handling. For the purpose of this policy a “complainant” is defined as any client, who has agreed with and accepted all the terms and conditions contained in the Client Agreement, and who proceeded to open an account with the Company and has submitted a written complaint.

Definition

The Company considers as a complaint a statement unsatisfactory of financial services provided, based on actual or supposed circumstances that have caused hardship or harm to the claimant, received in writing on a specified form provided by the Company.

Verbal Complaints

When the Company receives any verbal complaint, the handling will be the following:

A complaint or grievance is initially handled by a member of the Back Office / Customer Support Department. The employee receiving the complaint or grievance will take the necessary actions so that the complaint or grievance is properly addressed.

The complaint or grievance in the form that has been received immediately (within three working days), should be forwarded to the head of the department where the complaint is addressed. The member of the Back Office / Customer Support shall inform the client that the complaint or grievance has been forwarded to the relevant department / personnel, providing all details so that the client is aware who is dealing with his / her complaint or grievance.

The member of staff, in addition to the above, should make all best efforts to ensure that in the case of the complaint or grievance being of such nature that can be resolved immediately, to do so that the client will not have to pursue the filling of a formal complaint. The member of staff in such a case shall not:

  • Commit him / herself in any way to the client
  • Address any issues in relation to best execution
  • Address any issues relating to legal issues
  • Commit the Company in taking any action prior to examining the issues in a formal manner

Procedure For Written Complaints

The client contacts the Company to submit a complaint or grievance using the address and / or email and / or fax stated or online form on the Contact Page. The Compliance Officer shall deal with clients’ complaints unless in cases when a conflict of interest might occur. In such cases the other authorized personnel will deal with it. The Company acknowledges receiving of the submitted form noting the approximate time for resolving the case as follows, according to the relevant laws:

  • Initial Response will be given within the next 5 days from the receipt of the complaint.
  • A Final Resolution to be announced not later than 8 weeks of the date of initial complaint submitting.

Records and Reports

The Company shall keep detailed documentation of all complaints and grievances and maintain an internal register for this purpose:

  • Upon receiving the complaint, the company will register the complaint directly to its internal register, giving it a unique reference number. The unique reference number will consist of ten digits: the first two digits are the code of the company regarding the Transaction Reporting System - and the following four digits define the year, and the last four digits denote the number of each complaint serial number (e.g. for 2016 - NN20160001, NN20160002, for 2017 - NN20170001, NN20170002).
  • The unique reference number is communicated to the complainant.
  • The company will inform the complainant that he should use the said reference number in all future contact with the company, the Financial Ombudsman and/or the CySEC regarding the specific complaint.

The company will confirm, within five days, the receiving of the complaint to the complainant [as stated in paragraph 13(8)(a) of the Directive]. The client shall also receive a full copy of the complaint and all related records within five days. Another copy shall be kept in clients’ file with the Company. In cases when the complaint involves the General Manager, it shall be mentioned in the Annual Report.

The company will investigate the complaint [as stated in paragraph 13(9)(a) of the Directive] and reply, within two months, to the complainant about the outcome/decision [as stated in paragraph 13(9)(c) of the Directive]. It is provided that, during the investigation of the complaint, the CIF informs the complainant of the handling process of his/her complaint [as stated in paragraph 13(8)(d) of the Directive].

In the event that the company is unable to respond within two months, it will inform 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 [as stated in paragraph 13(9)(c) of the Directive].

Updates & Accessibility

The Company will perform an annual review of this Policy, in line with the Company’s operational model, and therefore in case of any changes in the operations, these will be properly reflected in this policy.

The complaints management policy will be available to all the Company’s personnel through email and an internal folder in the Shared Documents which can be accessed at any time without any restrictions.

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