The Complaint handling of S.O. Spotoption Limited (the “Company”) would be performed from the Back Office/Account Opening Department in order for the contact with the client to be performed and the complaint to be resolved. However, the final approval shall be provided by the Compliance Officer and the ultimate responsibility lies with the Senior Management.
The procedure which is followed by the Company, when handling with clients’ complaints, is the following:
The Complaint would be received from a member of staff of the Back Office/Account Opening Department. The employee receiving the complaint shall take the necessary actions so that the complaint is properly addressed.
The complaint in the form that has been received immediately (within the same working day), should be forwarded to the head of the department, where the complaint is addressed.
The member of the Back Office/Account Opening Department shall inform the client that he/she is not responsible to deal with the complaint and that the complaint has been forwarded to the relevant department/personnel, providing all details so that the client is aware who is dealing with his/her complaint.
The member of staff, in addition to the above, should make all best efforts to ensure that in the case of the complaint 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:
i. Commit him/her self in any way to the client.
ii. Address any issues in relation to best execution.
iii. Address any issues relating to legal issues.
iv. Commit the Company in taking any action prior to examining the issues in a formal manner.
Procedure to be followed when a formal (Appendix 1: Complaint Form) complaint is received:
a. When a written complaint is received, this shall be forwarded to the relevant department which is the most appropriate for dealing with the complaint.
b. The head of the relevant department shall contact the client to inform him/her that the complaint has been received and it is under investigation.
c. Upon receiving a written complaint, the following details should be obtained and recorded:
• The identification particulars of any client having made a complaint.
• The service provided by the Company and related to the complaint.
• The employee responsible for the provision of those services.
• The department where the employee belongs.
• Date of receipt and registration of complaint.
• Content of the complaint.
• The capital and the value of the financial instruments which belong to the client.
• The magnitude of the damage claimed by the client.
• Reference of any correspondent exchanged between the Company and the client.
d. The events leading to the complaint should be examined and assessed based on the information provided by the client.
e. The facts as stated by the client have been examined and verified whether any additional information, need to be retrieved from the Company’s archive (electronic mail, recorded telephone calls, IT data, etc).
f. All complaints shall be brought to the attention of Senior Management.
g. All complaints should be handled within 3 working days from the date of the receipt of the complaint.
h. Upon completion, a complaint registration form report shall be prepared stating the facts and brought to management’s attention (Appendix 2), which will decide on the formal response to the client and the action to be taken.
In the case where a client complaint is valid, the management shall take such necessary action together with the Head of Department(s) to which the complaint is related in order to identify and verify:
• Reasons for failure of procedure followed.
• Weaknesses of the internal controls.
• Implementation of internal controls that would prevent any complaint in the future.
All suggested procedures shall be approved by the Board of Directors at the meeting following the completion of the investigation.