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COMPLAINTS
POLICY

As per CySEC’s CASP Directive 269/2021 and Directive DI144-2007-01 of 2012, the Company is required to establish, implement and maintain effective and transparent procedures for the reasonable and prompt handling of complaints or grievances received from existing or potential clients as well as recording for the complaints/grievances received and the measures taken for its resolution.

The purpose of this of the Complaints Handling Policy (the “Policy”) is to set out the procedures to be followed and the appropriate actions to be taken by the Company in the cases where a complaint or grievance is received from any of the Company’s Counterparties.

The aim of the procedures established in the current Policy is to deliver a consistent, high-quality and accountable response to each official complaint, regardless of the subject matter.

 

Definitions & Requirements

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“Complainant” means any person, natural or legal, who is eligible for lodging a Complaint to the Company and who has already lodged a Complaint.

“Complaint” or “Grievance” means a statement of dissatisfaction addressed to the Company by a Complainant relating to the provision of investment services. 

The Company shall establish, implement and maintain effective and transparent procedures for the reasonable and prompt handling of Complaints or Grievances received from existing or potential counterparties, and keep a record of each Complaint or Grievance and the measures taken for the Complaints resolution. 

In addition, the Company is required to:

  • Apply a complaints management policy in order to ensure that its counterparties’ complaints are properly resolved.

  • Ensure that it has a complaints management function, which enables Complaints to be investigated fairly and possible conflicts of interest to be identified and mitigated.

 

How to file a complaint

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Counterparties’ complaints or grievances are initially handled by the Compliance Department. However, the final settlement of non-trivial complaints or grievances needs to be escalated and approved by Senior Management. 

A complainant shall complete the Complaint Form provided by the Company (available upon request). Once completed, it should be sent either:

- as 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 the Company’s head offices which are situated at 84 Spyrou Kyprianou, 4004 Limassol, Cyprus

- by e-mail to info@veliona.com

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Internal procedures for handling a complaint

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The procedure, that shall be followed by the Company when handling Counterparties’ complaints or grievances, is the following:

1) A complaint or grievance is initially handled by the Compliance Department to the addresses specified above. The Compliance Department shall register the complaint directly to an internal register, giving it a unique reference number. 

 

2) Upon receiving a written complaint or grievance, the following details should be obtained and recorded: 

  • The identification particulars of any counterparty who submits a complaint or grievance. 

  • The service provided by the Company and related to the complaint or grievance. 

  • The employee responsible for the provision of those services. 

  • The department where the employee belongs.

  • Date of receipt and registration of complaint or grievance. 

  • Content of the complaint or grievance. 

  • The capital and the value of the financial instruments which belong to the counterparty. 

  • The magnitude of the damage claimed by the Counterparty. 

  • A reference of any correspondence exchanged between the Company and the counterparty.

 

3) The Company shall confirm to the complainant via email, within five (5) business days from the receipt of the complaint or grievance, that the complaint or grievance is under investigation and shall provide the complainant with the unique reference number assigned to the specific complaint.

 

4) The complainant shall use the reference number provided to them in all future contacts with the Company and/or the Cyprus Securities and Exchange Commission regarding the specific complaint.

 

5) In the case that the complaint or grievance is in languages other than English or Greek, a true translation must be obtained.

 

6) The events leading to the complaint or grievance should be examined and assessed based on the information provided by the Counterparty. 

 

7) As a next step, the Compliance Department shall forward the complaint or grievance to the relevant department, involved in the case, with instructions to provide all information and evidence available, to allow investigation of the Counterparty’s claim. The department involved in the case shall provide all information and evidence collected to the Compliance Department.

 

8) Upon completion of the investigation a report shall be prepared stating the facts of the complaint. The report shall be brought to management’s attention, who shall then decide on the formal response to the Counterparty and the action to be taken.

 

9) The events leading to the complaint or grievance and all the information provided by the complainant and the relevant department of the Company involved in the case shall be examined and assessed in order to reach a fair outcome. 

 

10) The complainant shall be regularly updated on their complaint's development and handling process. Where further details on the Counterparty’s complaint are considered needed the Compliance Department shall call the specific Counterparty for a personal interview or discuss the matter over the phone, as appropriate to better identify the nature of the complaint.

 

11) The Company sets five (5) business days from the day of the receipt of the original complaint or grievance as a standard investigation period. However, if a complaint is not resolved within the standard investigation period, the Company shall inform the complainant in detail about the causes of the delay, the status of the investigation process and an expected date for completion of the investigation.

 

12) Upon investigation completion, a member of the Compliance Department shall inform the complainant in writing, using plain language, which is clearly understood, about the results of the investigation and actions taken to satisfy the complainant’s demand(s).

 

13) Where the case is not closed within the standard investigation period as specified in the above point, the Company shall deliver its final solution on the case no later than two (2) months from the receipt of the complaint. The findings and proposed solutions shall be clearly communicated to the Counterparty in a written form, explaining in detail the Company’s stand on the specific case.

 

14) If the Compliance Department is unable to provide a response to the Complainant within two (2) months, it will inform the complainant of the reasons for the delay, and it will indicate the period that it will take to complete the investigation. All complaints must be responded to within three (3) months of receiving the complaint initially.

 

15) A complaint is resolved where the complainant has indicated acceptance of a response from the respondent, with the response or acceptance having to be in writing.

 

16) The Company has the right to refrain from reviewing a complaint when: 

  • The information in the complaint prevents the Company from identifying the applicant’s identity. 

  • The complaint includes offensive language directed either to the Company or to an employee of the Company. 
     

Corrective measures triggered by Counterparty’s complaints

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In the case where a Counterparty complaint or grievance is valid, the Company’s Management shall take all necessary actions, together with the Head of the Department(s) to which the complaint or grievance is related, in order to identify and verify:

  • Reasons for failure of the procedure followed. 

  • Weaknesses of the internal controls. 

  • Implementation of internal controls that would prevent any complaint or grievance in the future.

All suggested procedures shall be approved by Senior Management at the meeting following the completion of the investigation. Procedural manuals should be updated to reflect the approved changes and shall be communicated to all involved staff members. 

At the end of each month, the Director shall inspect the “complaint/grievance file” and ensure that the Heads of the Departments have taken all the required actions to prevent a repetition of the same complaints/grievances. The Director shall inform at least once per year the Board of Directors of all complaints/grievances received.

The Compliance Officer shall ensure that procedure manuals are updated to address and prevent any drawbacks in the Company’s procedures that may cause malpractices and respectively Customers’ complaints.

 

Review of Complaints received on an ongoing basis

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The Company shall analyse, on an ongoing basis, complaints-handling data, to ensure that it identifies and addresses any recurring or systemic problems, and potential legal and operational risks by:

  • Analysing the causes of individual complaints to identify root causes common to types of complaints; 

  • Considering whether such root causes also affect other processes or financial means, including those not directly complained of; and 

  • Correcting, where reasonable to do so, such root causes. 

The Complaints Handling Policy shall be reviewed and/or amended annually or as when considered necessary by the Board of Directors or when changes or amendments to operating requirements are issued by the Cyprus Securities and Exchange Commission.

 

Record-keeping of Complaints or Grievances received

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The responsible department for the record-keeping of Complaints or Grievances received is the Back Office / Account Opening Department. In particular, the Head of Back-Office, or his designee, will keep a record of each Complaint and the measures taken for the Complaints resolution. 

The Complaint shall be registered once it is received on an internal archive and in an appropriate manner. The Head of Back Office, or his designee, shall maintain a central record of all Complaints that includes the following information:  

  • name, address and account number (if available) of the Complainant.  

  • date on which the Complaint was received.  

  • department(s) involved in the Complaint investigation along with the names of the responsible employees.

  • description of the nature of the Complaint. 

  • disposition of the Complaint.  

One copy of the complaint form is archived in the Counterparty’s file and another copy is kept in a separate file (“complaints/grievances file”). The Company shall maintain all Complaints or Grievances for a minimum period of five (5) years.

 

Financial Ombudsman

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If the Complainant is not fully satisfied with the Company’s final decision/response, then the Complainant may refer the complaint to the Financial Ombudsman of the Republic of Cyprus. 

Complainants must refer complaints to the Financial Ombudsman within four (4) months of the date of the final response from the Company. Please note if you do not refer your complaint in time, the Financial Ombudsman may not be able to deal with your complaint.

The Complainant may also address their 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 may not investigate individual complaints.

 

Contact Details of the Financial Ombudsman of the Republic of Cyprus:

 

Website: http://www.financialombudsman.gov.cy

Email: complaints@financialombudsman.gov.cy

Postal Address: 15 Kypranoros, 1061 Nicosia or P.O. Box. 26722, 1647 Nicosia

Telephone: +35722848900
 

Fax: +35722660584

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