Complaints Policy

1. A complaint or issue of dissatisfaction should be addressed to the Firm in the following ways:

In writing to: Director of Operations at 15 Old Bailey, London EC4M 7EF.
By phone: 020 3700 7391
By email: david.pickles@squaremileresearch.com

2. On receipt of your communication we will undertake an assessment as to whether this is a complaint and should be handled in line with our internal complaints policy.

If the communication is a complaint and you are an eligible complainant we will endeavour to provide you with a resolution within three business days. We will provide you with a written summary resolution which will contain details as to how you can escalate your complaint to the Financial Ombudsman Service (“FOS”), should you be unsatisfied with our resolution. Within our written resolution we will provide details as to any findings we have made as a result of our investigation into your complaint and whether any remedial action will be taken by ourselves. We will ask you to confirm if you are satisfied with our conclusion.

If you are not satisfied with our conclusion we will not close your complaint and will continue to seek resolution. You may raise your complaint to the FOS if you feel dissatisfied with our resolution.

3. If we feel your complaint requires further review and we cannot respond to you with a resolution within three business days we will inform you of this. We will provide you with details of who is responsible for handling your complaint at the Firm as they will provide you with updates.

We will provide you with a written Final Response Letter within eight weeks of the date of your original complaint. Within this letter we will provide details as to any findings we have made as a result of our investigation into your complaint and whether any remedial action will be taken by ourselves. We will ask you to confirm if you are satisfied with our conclusion.

If you should wish and you are an eligible complainant, you may refer your complaint to the FOS at:

The Financial Ombudsman Service

Exchange Tower

London
E14 9SR

Email complaint.info@financial-ombudsman.org.uk

Telephone
0800 023 4 567 or 0300 123 9 123

4. Processes and Procedure

The Firm has adopted the following procedures in respect of any complaints received:

(i) All complaints received must be notified immediately to the Compliance Officer.

(ii) The Compliance Officer will notify Senior Management of any serious complaints or complaints that indicate the possibility of a material loss or a material deficiency in the Firm’s systems and controls.

(iii) A written acknowledgement will be provided to the client of the complaint together with a note that it is being taken into consideration and the anticipated maximum response time.

(iv) The Compliance Officer is responsible for ensuring that appropriate investigation and internal reporting of complaints is undertaken and that all stakeholders required for the investigation and resolution of the complaint are informed

(v) Any responses to complaints must be reviewed and approved by the Compliance Officer. It is important to ensure that clients are kept informed of progress in the processing of their complaint.

(vi) The Compliance Officer must oversee the appropriate investigation and internal reporting of complaints.

(vii) The Compliance Officer maintains a file of complaints with all the supporting correspondence.

(viii) A Complaints Register is also maintained and, where appropriate copies of documentation will be placed on customer files.

(ix) Records of complaints are retained for a minimum period of five years from the date of receipt of the complaint.

Staff are required to confirm that all complaints have been reported as part of the Annual Compliance Declaration.

5. Examples of A Complaint

Set out below are examples of the types of complaints that would be dealt with under these procedures:

• Breach of investment restrictions
• Breach of contractual arrangements
• Transaction costs (too high or undisclosed)
• Incorrect calculation of fees
• Interest claims from late/wrong settlement
• Reporting (Wrong/too late)
• Poor administration
• Inconsistency between marketing material and the service sold

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