Complaints & Dispute Policy

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Complaints & Dispute Policy

Clients’ Complaints

HOW DO WE PROCEED WITH COMPlAINTS?

Complaints resolution is a priority matter for Translativa Group s.r.o. (Clients’ complaints and policy). If you have a complaint with the financial products and services that we are providing you with, you can contact us and explain your concerns, and if possible we will attempt to resolve your problem straight away subject to provisions mentioned hereunder in The Company’s Complaints Policy.

Phone: (+420-228880697 or +420-228880702)
Email: [email protected]

If the complaint cannot be resolved at first contact, please write to us at the following address:
The Complaints Officer
Brno – Veveří, Lidická 700/19, PSČ 602 00

We will proceed with your request immediately and let you know that we have received your complaint. Rest assured that every effort will be made to resolve the complaint within 45 days of receipt. While most matters can be resolved quickly, more complex issues may take longer and in these cases we will keep you advised at
regular intervals and specify a date when a decision can reasonably be expected. Each complaint is addressed in an equitable, objective and unbiased manner through
the complaint handling process.

COMPLAINTS POLICY
(13.04.2018)

1. PURPOSE

The purpose of this policy is to provide the staff of Translativa Group s.r.o. (herein referred to as ‘The Company’) with the correct procedures in relation to handling, recording and monitoring complaints received from clients.

The Company staff must always be conscious that the issue raised in complaints may well have an impact on such a party and must be handled accordingly with attention to details and care.

Complaints should be dealt with at the earliest possible stage as doing so:
1. preserves customer relationships; and
2. is often the most efficient and cost-effective way of dealing with complaints.

This policy constitutes The Company’s Internal Dispute Resolution.

What is a “complaint”?

A complaint is any expression of dissatisfaction with a product or service offered or provided, which is often difficult to determine. Where there is any doubt as to whether a communication received (either verbally or in writing or electronically) constitutes a formal complaint, it should be reported to the Compliance Officer, who will make further investigations.

2. DEALING WITH COMPLAINTS

Initial Response
All complaints, whether they are written or verbal are to be communicated to the Compliance Officer immediately, or as soon as practicable, on receipt of the complaint.

Within 48 hours of receipt of the complaint:
 The Compliance Officer is to respond to the complainant in writing, advising
that their expression of dissatisfaction has been received and will be
responded to in line with our Complaints policy;
 The Compliance Officer will raise a complaint outlining details and any actions
taken to date;
 The Compliance Officer assigns the responsibility of managing the complaint to
the appropriate persons;
 The Compliance Officer maintains a register of all complaints, and reports
quarterly to the Board on all complaints received during the preceding quarter.

3. PROCESS & ADMINISTRATION
Where a complaint constitutes or indicates a breach, the matter must be reported immediately to the Compliance Officer, and handled accordingly.

3.1. Complaints Process
The Compliance Officer:
(a) Will review the complaint immediately upon receipt and will reassign it to the appropriate staff member for action;
(b) Will register the complaint and include the following information:

(i) Date the complaint was received;
(ii) Product;
(iii) Client’s name;
(iv) Complaint detail;
(v) Any actions taken to date; and
(vi) Root cause.

(c) May provide assistance in resolving the complaint to the executive from whose fund the complaint emanated. At first instance, this could include a meeting with the complainant to discuss issues relevant to the complaint, and explore possibilities for resolution;
(d) Monitors all complaints until they are resolved;
(e) Evaluates the complaints handling procedure, at least annually.

3.2. Ownership
It is the responsibility of the Compliance Officer, with assistance from the relevant executive, or, if applicable, of an external service provider, to ensure complaints are satisfactorily resolved.

The Compliance Officer and the relevant executives must use their best endeavours to resolve the complaints as soon as is practicable by:

(a) communicating with the client in a positive and conciliatory manner;
(b) addressing all issues that were raised in the complaint;
(c) ensuring that all answers are accurate and understood;
(d) giving clear and concise reasons for the decision reached;
(e) keeping comprehensive notes on the progress of the complaint, including file notes on conversations; and
(f) liaising with external and internal personnel where appropriate.

Decisions should be communicated in writing and should refer to applicable provisions in legislation, codes, standards or procedures. The decisions should be clear, concise and effective, and avoid the use of legal or industry jargon which may confuse the client.

3.3 File Records
A copy of all correspondence and other relevant documentation is to be retained by the Compliance Officer.

3.4. Reporting
All complaints must be recorded in the Complaints Register by the Compliance Officer. The Compliance Officer will monitor all complaints and their status.

3.5. Timeliness
The Compliance Officer must investigate all complaints, assist with reaching a decision on the course of action, and ensure that the decision is communicated to the client within 45 days of the complaint being made.

If a longer period is required, the client must be notified by The Company, within the initial 45-day period, of the reason why a decision cannot be made within that period.

3.6. Resolution
If the action taken/decision made is believed to have satisfied/resolved the complaint, the Compliance Officer should attempt to have the complainant sign a Deed of Release, which acknowledges that the dispute has been resolved, and releases The Company from any liability in connection with the dispute/complaint.