Coverdeal Holdings Limited, hereafter the "Company", is a company registered in Cyprus (registration number HE 303127), acting as a Cypriot Investment Firm, licensed and regulated by the Cyprus Securities and Exchange Commission (License number 231/14). The purpose of this Policy is to set out the procedure to be followed and the appropriate action required to be taken by the Company in the case of a complaint by any client to ensure the Company's compliance with paragraph 13 of Directive DI 144-2007-01 of the Cyprus Securities and Exchange Commission for the Authorisation (hereafter "CySEC") and Operating Conditions of the Cyprus Investment Firms.
"Complainant" means any person, natural or legal, which is eligible for lodging a complaint to the Company and who has already lodged a complaint.
"Complaint" means a statement of dissatisfaction addressed to the Company by a complainant relating to the provision of investment services.
In accordance with Directive DI144-2007-01, the Company shall 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, and to keep a record of each complaint or grievance and the measures taken for the complaint's resolution.
In addition, the Company is required to:
Clients' complaints or grievances are initially handled by the Compliance Department. However, the final settlement of non-trivial complaints or grievances needs to be approved by Senior Management.
A complainant shall complete the Complaint Form developed by the Company. Once completed, it should be sent either in a hard copy along with a copy of the complainant's identification document and any additional documentation that would be relevant to the complaint to Kristelina Tower, 12 Arch. Makarios III Avenue, Office 201, 2nd Floor,, Mesa Geitonia, 4000, Limassol, Cyprus or by e-mail to the respective company: email@example.com or firstname.lastname@example.org
No Complaint shall be valid if submitted after six months of its alleged occurrence and should be deemed to be settled in full upon the expiry of the said 6 months period. The Client hereby waives any rights it may have inclusively the right to submit any complaint or claim or allegation outside the permitted timeframe of six months from the day that the said alleged occurred, irrespectively of the nature of the event (i.e. trade, refund, etc.) or the size of the Complaint.
The procedure which shall be followed by the Company, when handling with clients' complaints or grievances, is the following:
The unique reference number is communicated to the complainant.
The Company sets 10 business days from the day the original complaint is received as a standard investigation period. If the investigation is complete in less than 10 business days, the complainant will be informed about the results of the investigation immediately upon its completion. However, if a complaint is not resolved within the standard investigation period, the Company will inform the complainant in details about causes of delay, a status of the investigation process and an expected date of completion of the investigation.
1.1Procedure to be followed when a formal complaint or grievance is received:
If the provided investigation results does not fully satisfy the complainant's demands, the Company should provide to the complainant in writing a thorough explanation of its position on the complaint and set out the complainant's option to maintain the complaint e.g. through CySEC, the Financial Ombudsman, ADR Mechanism, or the relevant Courts.
In the case where a client complaint or grievance is valid, the management shall take such necessary action together with the Head of Department(s) to which the complaint or grievance is related in order to identify and verify:
All suggested procedures shall be approved by Senior Management at the meeting following the completion of the investigation.
The above mentioned procedure shall be disclosed in summarised form to the complainant through the agreement which is signed for the provision of investment services.
1.2 Complaints on an on-going basis
The Company undertakes to analyze, on an on-going basis, complaints-handling data, to ensure that they identify and address any recurring or systemic problems, and potential legal and operational risks, for example by:
1.3 Reporting of complaints
Every month, and within five days after the reporting month, Company is required to submit the form ΧΧ_yyyymmdd_T144-002-01 (the "Form") to the CySEC, in order to inform regarding the complaints it receives and how these are being handled.
1.4 Record-keeping of complaints or grievances received
The responsible department for the record keeping of complaints or grievances received is the Compliance Department. In particular, the Head of Back Office, or his/her designee, will keep a record of each complaint and the measures taken for the complaint's resolution.
The complaint shall be registered once it is receives on an internal archive and in an appropriate manner. The Head of Compliance Department, or his/her designee, shall maintain a central record of all complaints that includes the following information:
The Company shall maintain all complaints or grievances for a minimum period of five years.
V.Financial Ombudsman of the Republic of Cyprus
In case you are not satisfied with the company's final decision, you can use your unique reference number to contact the:
Financial Ombudsman of the Republic of Cyprus
If you are not satisfied with the Company's final decision you may check with the office of the Financial Ombudsman of the Republic of Cyprus and seek mediation for possible compensation. It is important that you contact the Financial Ombudsman of the Republic of Cyprus within four (4) months of receiving a final response from the Company otherwise the Financial Ombudsman of the Republic of Cyprus may not be able to deal with your complaint. If the Company was unable to provide you with a final response within the three (3) month time period specified above you may again contact the office of the Financial Ombudsman of the Republic of Cyprus no later than four (4) months after the date when the company ought to have provided you with its final decision.www.financialombudsman.gov.cy email@example.com P.O. BOX: 25735, 1311 Nicosia, Cyprus +357 2284 8900 +357 2266 0584 +357 2266 0118
You may also maintain your complaint with the Cyprus Securities and Exchange Commission. However please note that the Cyprus Securities and Exchange Commission does not have restitution powers and therefore does not investigate individual complaints.www.cysec.gov.cy firstname.lastname@example.org P.O. BOX 24996, 1306 Nicosia, Cyprus +357 2250 6600 +357 2250 6700