Complaints & Grievances Policy

The Company 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.

The Company is required to keep an internal record of each complaint or grievance and the measures taken for the complaint’s resolution.

Clients’ complaints or grievances are initially handled by a member of the Compliance Team; however, the final settlement of complaints or grievances needs to be approved by Senior Management/Head of Compliance.


The procedure which shall be followed by the Company when handling client’s complaints or grievances is as follows:

Filing Complaints

Any client who wishes to submit a complaint or grievance is advised to complete a Complaint Form and to send it to the Company in one of the following ways:

  • By email to
  • By post to Yiannis Nicolaides Business Center, 33 Agiou Athanasiou Avenue, 4102, Agios Athanasios, Limassol, Cyprus.

Receiving Complaints

A complaint or grievance is initially handled by a Compliance Officer who shall immediately register the complaint in the Company’s internal register and give it a unique reference number.

The Compliance Officer shall then communicate receipt of the complaint along with the unique reference number to the complainant. He shall also inform the complainant that the said reference number will be used for future communication with the Company, the financial ombudsman or CySEC when discussing the specific complaint.

The Compliance Officer will ensure that this unique reference number and confirmation of receipt is sent within 5 working days of the complaint being made.

The Compliance Officer shall then take all necessary actions to ensure that the complaint or grievance is properly addressed by forwarding it to the head of the department the complaint is addressed to (within 3 working days). He 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 Employees, in addition to the above, shall make all best efforts to ensure that, in case the complaint or grievance is of such nature that it is not formal and can be resolved immediately, to do so that the client will not have to pursue the filing 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

Complaint Form

In order to ensure the correct details are obtained from the complainant, a copy of the ‘Complaints Form’ and Complaint Policy are provided on the Company’s website

Upon receiving a written complaint or grievance, the following details shall be obtained and recorded by the Compliance Officer:

  • The identification particulars of any client having made a complaint or grievance.
  • The service provided by the Company and related to the complaint or grievance.
  • The employee responsible for the provision of those services.
  • The department to which the employee belongs.
  • Date of receipt and registration of complaint or grievance.
  • Content of the complaint or grievance.
  • The capital and the value of the financial instruments which belong to the client.
  • The magnitude of the damage claimed by the client.
  • Reference to any correspondence exchanged between the Company and the client.

Handling Complaints

The events leading to the complaint or grievance shall be examined and assessed by the Compliance Officer based on the information provided by the client.

The facts as stated by the client shall be examined and verified with the relevant heads of department and any additional information needed shall be retrieved from the Company’s archives (electronic mail, recorded telephone calls, IT data, etc.).

During the investigation of the complaint, the Company shall inform the complainant of the handling process of his/her complaint.

Upon completion of the investigation, the Compliance Officer will prepare a report stating the facts and make recommendations which will be brought to management’s attention who will then conclude on the final decision to be made. The Head of Compliance will make a formal response to the client and carry out these actions.

The Company shall investigate the complaint and reply, within two months, to the complainant about the outcome/decision. In the event when the Company is unable to respond within two months, it shall inform the complainant of the reasons for the delay and the period of time within which it is expected to complete the investigation. This period of time cannot exceed three months from the submission of the complaint.

Record Keeping

The Company shall keep a record of every complaint or grievance received from clients, as well as of all the measures taken for the resolution of said complaint/grievance for a minimum period of five years.

The Compliance Officer shall be responsible for maintaining all complaints, relevant correspondence and documents related to the complaints. Management will ensure at the end of each month that the heads of departments have taken all the required actions so as to prevent repetition of the same complaints/grievances.

Submission of Information to CySEC

Every month, within five days after the reporting month, the Company will submit the form XX_yyyymmdd_T144-002-01 (the “Form”) to CySEC in order to inform them of the complaints the Company has received and how these complaints have been handled.

If no complaints or grievances have been received for the reporting month, the Company has no obligation to submit the Form.

In the event when the Company has resolved and/or revised a complaint which was reported in the previous month(s), the Company completes all the fields of the Form and selects ‘U’ from the column Record Type.

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