Complaints Handling Policy
Version 1, October 2025
This policy regulates effective, clear and fast handling of complaints and disputes submitted to The Company in relation to the performance and procedures of the Company.
The Company maintains Records of Complaints and a structured dispute resolution process. The Company must develop and put into practice an independent and objective complaints and dispute resolution system that includes:
-
A written Policy that sets out how complaints and disputes will be
handled, including:
- How to lodge a complaint or dispute regarding the company’s actions or decisions;
- Time frames for decisions regarding complaints;
- Information to be provided to complainants;
- Options available when a complaint or dispute is not resolved
- Effective communication of the company's Complaint Handling and Dispute Resolution Policy to clients
- A complaints register that records details of complaints and disputes and their progress;
- Referral arrangements to external dispute resolution resources for disputes that cannot be resolved through the internal resources of the company
Definitions
1. Complaint:
- Complaints are defined as specific requests or claims related to the performance, services or products of the Company, which objects the performance or expresses negligence of the Company and lodges a relevant, specific and clear demand.
- Asking an opinion or position about any specific case or requesting general information about the operation and services of the Company shall not constitute a complaint.
2. Complainant:
- The Complainant could be a natural or legal person, a company without legal entity or other organization that requires services of the Company or the addressee of information or offer related to the service.
- When the complaint is submitted by a representative or other duly authorized person, the Company will investigate the legal basis of the submission, which must be presented by the Complainant in a format required by law. If no authorization is available, the Company will approach the Complainant directly in order to accelerate the procedure.
3. Dispute
- Means an unresolved complaint. In other words, it is a matter that has been dealt with as a complaint under this Policy, but where the complainant is still not satisfied with the outcome.
4. Dispute Resolution
Dispute resolution refers to the processes by which disputes are brought to an end. This can occur through:
- A negotiated outcome, where the parties concerned sort out things themselves;
- A mediated outcome, where the parties use the services of an independent mediator to help them arrive at their own agreement;
- An arbitrated or adjudicated outcome, where an independent arbitrator or court determines how the dispute is to be resolved and makes a binding decision or order to this effect
Definitions
The Complainant, if possible, should report the event or the date of the occasion subject of the complaint to the Company as soon as possible. This is necessary to enable the Company to investigate the complaint as efficiently as possible.
The following opportunities are available for submitting a complaint to our Company: by e-mail in writing
Employees of the Customer Support shall receive and manage - first of all - complaints within the Company. Employees of the Customer Support shall help the Complainant in compiling and submitting the complaint. The Complainant must submit complaints related to services rendered on the basis of online trading agreement to the Customer Support of the Company. Contact of the Customer Support is available at the homepage of the Company all the time. If employees at Customer Support are unable to settle the complaint efficiently or within 48 hours, they forward the complaint to the Compliance officer of the Company
The telephone line of the Customer Support is available for submitting complaints by telephone. If the Complainant calls another telephone number of the Company to submit his/her complaint, he/she will be redirected to the Customer Support. The Company shall provide 24 hours direct telephone line to the Customer Support.
If you wish to submit your complaint in writing, please attach - if possible - copies of documents supporting your complaint to your application. The Company receives complaints submitted by e-mail on an ongoing basis
Registration of Complaints
The Company, shall register all complaints until they are dealt with. This register shall record at least the following information:
- description of the complaint,
- description of the event or fact subject of the complaint,
- date of submitting the complaint,
- measures implemented to settle or solve the complaint,
- in case of rejection, the reasoning of the rejection,
- deadline of managing the complaint,
- name of the person responsible for the execution,
- date of responding to the complaint.
The Company pays special attention to avoid collection of data about the complainant with the exception of recording data aimed to settle the complaint. All personal particulars obtained in relation of managing the complaint shall be deleted from records or made unsuitable for identification.
The Company manages complaints within a transparent system; they could be traced and administered in each and every stage of the procedure.
Unless settled on the spot, the Company records a written memorandum on all verbally submitted complaints. For this purpose, the Company is entitled to use a complaint format or to register the complaint electronically. The Company hands over or mails one copy of the complaint to the Complainant.
The Company records all telephone conversations between the Customer Support and the Complainant and keeps the voice record for the period of one year. The Complainant shall be informed about this at the beginning of the conversation. The Company shall make this record available for listening and shall make the certified memorandum registered about this voice record available to the Complainant
Managing Complaints
The Company manages all complaints and Complainants equally, without any discrimination, in harmony with the procedure regulated by this Policy.
Disputes with Customers and Participants
To maximize the chance of a successful resolution the Complaint Handling and Dispute Resolution will:
- Listen to what the complainant has to say
- Request documentary evidence if required to verify the facts;
- Negotiate in a calm and professional manner;
- Understand the company's legal obligations seeking advice from the relevant consumer organization depending on the nature of the dispute;
- Provide accurate information on the options available to the complainant for resolution of the issue.
Dispute Provisions in Contracts or Letters of Engagement
We will include clauses that address the joint problem of solving disputes provision in contracts/ letters of engagement:
- Early notification of issues and informal discussion to seek a resolution;
- A process for raising continuing issues with the other party more formally in writing, setting out grounds and preferred solutions, and requiring the party to make every effort to resolve disputes fairly;
- The use of an informal negotiator (such as an industry association, business adviser or employee representative) to assist in finding a solution;
- Provision for the use of alternative dispute resolution, such as mediation or conciliation.
External Dispute Resolution Options
The company will have the available options for external dispute resolution and the appropriate option for any particular dispute. Successful use of external dispute resolution will involve a number of steps, as set out below:
Step 1 - Understand the Dispute
Step 2 - Understand Dispute Resolution Options
Step 3 - Select the Appropriate Dispute Resolution Method
Step 4 - Access an Alternative Dispute Resolution Provider
Step 5 - Prepare for the Alternative Dispute Resolution
Process
Step 6 - Working Towards a Successful Resolution Outcome
1. Customer Support
If possible, all complaints must be settled without delay. If immediate settlement of a verbal complaint is not possible or the Complainants rejects the solution offered on the spot, an employee of the Company shall record the complaints and the Company's position in a memorandum and forward them to Customer Support, unless the complaint was submitted directly to Customer Support. Similarly, Company employees forward all complaints submitted in writing to Customer Support. Customer Support shall be responsible for settling complaints. The officers of the Customer Support Department will inform you of the appropriate process to follow.
If you are contacting us on behalf of another person, we may ask you to provide a proof of that person's consent to your handling of their Complaint. We aim to resolve the matter within five (5) business days depending on the nature of the complaint and ensure that the maximum time to respond to complaints do not exceed 60 days
2. Compliance Officer
If employees at Customer Support are unable to settle the complaint efficiently or within a short period of time (48 hours), they forward the complaint to the Compliance officer of the Company. The Complainant, if he/she does not accept the solution offered by Customer Support, is also entitled to approach the Compliance officer directly.
3. Directors of the Company
Within the organization of the Company, Directors of the Company represent the highest level of authority in deciding the settlement of complaints. Directors of the Company shall settle those complaints which cannot be managed within the above procedure; they shall take into account the opinion of the Compliance officer of the Company.
The employee of the Company who participated in the measure related to the complaint or made a decision subject of the complaint must not participate in making any decision related to the complaint. Such employee must provide every reasonable help to the Company in the procedure aimed to settle the complaint as soon as possible and in the interest of the Complainant.
Response to Complaints
The Company follows the outlined procedures to ensure that your Complaint is resolved within a period of sixty (60) business days. This response, including the reasoning, is always mailed to the Complainant. Some Complaints can be resolved more quickly depending on the facts and the nature of the Complaint. If the Complaint is more complex and takes longer than sixty (60) business days to resolve, we will communicate the reasons for the delay. Sometimes you are requested to supply additional information required for investigating the complaint. In this case please respond at your earliest convenience
When the complaint is submitted by another person or with a method unsuitable for establishing proper authorization of the submission, The Company may ask the person authorized to submit the complaint to confirm the complaint in question.
The Company adds a correct, clear and unanimous reasoning to every decision brought down in order to settle complaints, which are mailed to the Complainant in writing. If the decision refers to a legislation, not only the legislation, but its relevant regulations must also be included in the above reasoning. In parallel with informing the Complainant about the decision in question, the Company informs the Complainant about the opportunities of appeal and possible damage compensation.
Monitoring of Complaints
After settling the procedure, the Company shall preserve every written or electronic documents related to complaints for a period of 7 years. The Company shall be entitled to prepare statistics and reports about complaints, which will be aimed to improve the efficiency of administering complaints.
Settlement of Disputes
When disputes between the Company and the Complainant cannot be settled by the official procedure, regulations of chapter "Settlement of Disputes" of the Company Rules and Regulations shall be applicable. When the complaint is rejected, the Complainant may lodge an appeal at the Union of Comoros.
Contact for Complaints
Clients may submit complaints via :
