Complaints Procedure

We recognise that we are a growing business in terms of size and complexity. One of our key differentiating factors is to provide high levels of personalised service to our customers. It is , therefore, important that we seek out and respond to feedback provided by our customers and other parties with whom we are involved.

A complaint  is defined by the Isle of Man Financial Supervision Commission as "a written expression of dissatisfaction, whether justified or not, from and on behalf of a customer about our provision of, or our failure to provide, a financial service, which alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience."

Procedures for Handling Written Complaints

  • The complaint should be immediately investigated, and resolved, where possible, by the close of business on the fifth working day following receipt.  The complainant should be notified, in writing, of the resolution of the complaint under the signature of the Head of Function or in their absence another member of the Management team.
  • The Compliance Officer should be advised so the main details can be included in the Complaints register.
  • As soon as it is clear that the complaint cannot be resolved within five working days following receipt, as it requires more detailed or fuller investigation, a written acknowledgement should be sent to the complainant, who should also be sent a copy of these internal procedures.
  • The complaint should then be further investigated and a full and final response issued to the complainant,  as soon as investigations are completed, but, in any event, no later than four weeks from the date of receipt of the complaint.
  • This final response should, where relevant, also inform the complainant that they may have the right to refer the complaint to the Financial Services Ombudsman Scheme in the Isle of Man, and include details of the Scheme.
  • Presently, only personal complainants will be considered by the Ombudsman.  Corporate complaints are not presently covered.  The scheme presently extends to banking and investment services but fiduciary services are currently not within the scope of the scheme arrangements.  Clearly, if the complainant is considering this course of action, it follows they remain dis-satisfied with our proposed resolution to their complaint.
  • Leaflets on the detail of the Scheme are available from the Office of Fair Trading, and further background information can be obtained from the Operations Manager. The website with further information is http://www.gov.im/oft/ombudsman/ .
  • In exceptional circumstances, if the investigation has not yet been completed after four weeks, a holding response should be sent to the complainant highlighting why the matter is still under investigation and advising that a full and final response will be issued within a further eight week period, or as soon as possible during that period.
  • If the investigation is still not fully completed after the further eight week period, then a further interim response should be issued to the complainant explaining why the company is not yet in a position to issue a final response, when the company would expect to be in a position to issue such a final response, and informing the complainant of their right to refer the complaint to the Ombudsman Scheme, as above.
  • If the complainant decides to refer the complaint to the Ombudsman Scheme, then the company should co-operate fully with the Scheme and comply promptly with any requests from the Scheme staff or an adjudicator for further information.