COMPLAINTS HANDLING POLICY AND PROCEDURE NORDIC FUND SERVICES S.A.

Similar documents
COMMISSION de SURVEILLANCE du SECTEUR FINANCIER

CSSF Regulation N relating to out-of-court complaint resolution

COMPLAINTS HANDLING POLICY

COMPLAINTS HANDLING POLICY

SWITCHING BANK ACCOUNTS IN LUXEMBOURG A GUIDE

SWITCHING BANK ACCOUNTS IN LUXEMBOURG A GUIDE

First-tier complaints handling: section 112 requirements and section 162 guidance for approved regulators

Best Execution Policy of IPConcept (Luxemburg) S.A.

Terms and Conditions for Payment Services

CASH MIFID II DISCLOSURES EFFECTIVE AS OF 3 JANUARY, 2018

MEDIOBANCA MANAGEMENT COMPANY S.A. BEST EXECUTION POLICY

DEFENCE OF THE POLICYHOLDER S RIGHTS REGULATION CAJA DE SEGUROS REUNIDS COMPAÑÍA DE SEGUROS Y REASEGUROS, S.A. CASER

INFORMATION SHEET DEPOSIT ACCOUNT INFORMATION ON THE BANK

Conflict of Interest Policy

J.P. Morgan Structured Products B.V. (incorporated with limited liability in The Netherlands)

SWEDBANK MANAGEMENT COMPANY S.A. s POLICY ON THE EXERCISE OF VOTING RIGHTS

KJK Management S.A. Summary of Conflict of Interest Policy

Luxembourg implements Directive 2013/50/EU on transparency requirements

Dispute Resolution: Complaints

Payment Services Nordea Bank S.A. 1. Our Payment Services. October 2015

Voting Rights Policy

CSSF Circular 04/146

A GUIDE TO INVESTING WITH Columbia Threadneedle Investments (SICAV)

ALFI comments. European Securities and Market Authority (ESMA)

LEGAL ALERT 30 OCTOBER 2012

KBL European Private Bankers S.A. Due Diligence

1.2 These General Terms and Conditions are applicable between the Broker and the Customer.

Policy for communication and contacts with shareholders, institutional investors and proxy advisors

CS Investment Funds 13

COMMISSION FOR THE SUPERVISION

Code of Banking Practice

ESFB Customer Grievance Redressal Policy P age 1 9

Information to the Shareholders of

Code for Underwriting Agents: UK Personal Lines Claims & Complaints Handling

1.1 The complaint concerns the manner of payment of a disability benefit.

Best Execution Policy

Investors grow with us

J.P. Morgan Structured Products B.V. (incorporated with limited liability in The Netherlands)

EQUITY LOANS COMPLAINTS

Financial Supervision Authority advisory guidelines. Tallinn 23 November 2011

DOCUMENT FOR EXTERNAL PUBLICATION. Remuneration Policy. FundPartner Solutions (Europe) S.A. Luxembourg March 2016

Information to the Unitholders

Inducements under MiFID

Luxembourg Takeover Law apects. Latest Update: March 2015

C WorldWide Biotechnology Appendix 1. C WorldWide Medical Appendix 2. C WorldWide Nordic Appendix 3. C WorldWide Sweden Appendix 4

Complaints Money/Debt Advice

EXTRAORDINARY GENERAL MEETING 2017 NOTICE

INTERFUND SOCIETE D INVESTISSEMENT A CAPITAL VARIABLE UNDER LUXEMBOURG LAW WITH MULTIPLE SUB-FUNDS AND FULL INCOME CAPITALIZATION

edreams ODIGEO and Subsidiaries

LETTER TO UNITHOLDERS OF THE AMUNDI ETF MSCI BRAZIL UCITS ETF FCP

SecureSign Set Up a Mobile Device

Internal Dispute Resolution Procedure Firefighter Pensions

REMUNERATION AND INCENTIVE POLICY

J.P. Morgan Structured Products B.V. (incorporated with limited liability in The Netherlands)

HSBC GLOBAL INVESTMENT FUNDS European Equity High Dividend

CREDIT SUISSE (LUXEMBOURG) S.A. ZWEIGNIEDERLASSUNG ÖSTERREICH

VOTING POLICY. Strategy for exercising rights relative to financial instruments of managed UCI s

MDO may either delegate or perform directly the portfolio management function of a given UCITS or AIF depending on the targeted asset class(es).

Luxembourg regulator issues rules applicable to the distribution of foreign AIFs to Luxembourg-based retail investors

I N F O R M A T I O N F O R I N S I G H T F U L D E C I S I O N M A K I N G. N o r t h e r n T r u s t P a s s p o r t

PRIVATE PLACEMENT MEMORANDUM SEVEN LUX SICAV-SIF

GRIEVANCE REDRESSAL POLICY INDEX NO 1 INTRODUCTION 1

PRODUCT HIGHLIGHTS SHEET

NN (L) EURO HIGH DIVIDEND (the Sub-Fund )

CONFLICT OF INTEREST POLICY

MIFID. Client Pre-Contractual Info Pack

DOCUMENT GRIEVANCE REDRESSAL POLICY

Coöperatieve Centrale Raiffeisen-Boerenleenbank B.A. GRIEVANCE REDRESSAL POLICY & PROCEDURE

Luxembourg Real Estate Investment Vehicles

ASHMORE SICAV ( The Fund )

EXTRAORDINARY GENERAL MEETING Notice

Luxembourg Real Estate Investment Vehicles

Corporate Governance

We are pleased to count you as a unitholder in the AMUNDI INDEX EQUITY GLOBAL MULTI SMART ALLOCATION SCIENTIFIC BETA FCP.

CP is licenced and supervised by the Commission de Surveillance du Secteur Financier (hereinafter CSSF ).

FINAL NOTICE Ms Moran was Catalyst s compliance officer (CF 10) from 3 August 2006 to 7 October 2011.

Code for Underwriting Agents: UK Personal Lines Claims & Complaints Handling Update (July 2018)

The shareholders are hereby invited to attend the ORDINARY ANNUAL GENERAL MEETING

Internal Market Scoreboard. EEA EFTA States. EFTA Surveillance Authority

GPB International S.A. Annual accounts. as at 31 December 2014 (with the Report of the Réviseur d'entreprises agréé thereon) GPB International S.A.

SMBC Nikko Bank (Luxembourg) S.A. Disclosure Report 1

(LF) Special Purpose Equity Formula Index I fund, a sub-fund of (LF) Fund Eurobank Class, ISIN: LU , Currency: EUR

Resolving a dispute with USS

Non-Distributing Shares: No dividends will be declared or paid A2, C2, D2

Audit Reform in Luxembourg what role will the Audit Committee play?

PROSPECTUS SUPPLEMENT

Conflict of Interest Policy

Non-Distributing Shares: No dividends will be declared or paid A2, C2, D2

ABN AMRO MULTI- MANAGER FUNDS - FUND OF MANDATES ASIA-PACIFIC EQUITIES

Entry into force of amendments to capital markets transparency legislation

Perks & Associates Financial Services Guide

CAPITAL MARKETS. Listing of bonds on the Luxembourg Stock Exchange

GRG Helpdesk Appeals FAQs

JPMC Office of the Ombudsman

Private Mandate Your Goals, Our Global Investment Expertise

INDUSIND BANK LTD. GRIEVANCE REDRESSAL POLICY

SEB Asset Management S.A. Société anonyme. Notice to unitholders of SEB Fund 1 SEB Europe Fund

April CEIOPS-DOC-02/06 Rev 1 Oct 2008

NOTICE TO SHAREHOLDERS. This document is important and requires your immediate attention. If in doubt, contact your professional adviser.

Q&A. CSSF Circular 11/512. Issue 01. Luxembourg, 14 th November 2011

Transcription:

COMPLAINTS HANDLING POLICY AND PROCEDURE NORDIC FUND SERVICES S.A. Approved by: The Board of Directors Date of Approval: February 2, 2017 Date of last Approval: n/a 1

1 Glossary BoD - Board of Directors CSSF - Commission de Surveillance du Secteur Financier Company - Nordic Fund Services S.A. 2 Legal Framework CSSF Regulation No. 10-4 CSSF Circular 12/546 CSSF Regulation No. 13-02 3 Objective Every management company must implement and maintain effective and transparent procedures for the reasonable and prompt handling of complaints received from investors. The objective of this Policy is to ensure that complaints received for the attention of the Company or the funds it manages are dealt with professionally, efficiently, consistently and in compliance with the laws, regulations and circulars. 4 General principles The Company handles investors complaints according to the following general principles: An effective and transparent procedure for investors A prompt handling To ensure each complaint and the measures taken for its resolution are recorded. A free of charge complaints filing for investors 5 Responsible Person The Company has designated from amongst its staff a Conducting Officer as the responsible person for the handling, centralisation and follow-up of complaints. The responses provided to investors will be made under his authority. The Conducting Officer is responsible for that the other employees of the Company are aware of these internal complaint handling procedures. 6 Procedure 6.1 Eligibility A physical or legal person is eligible to complain if he is or has been an investor of the funds managed by the Company and 2

the complaint is relevant to the investor being or having been an investor of one of these funds. A complaint can be brought on behalf of an eligible complainant, or a deceased person who would have been an eligible complainant, by the person authorized by the eligible complainant or by law. Furthermore, the Company will deal with complaints that have been forwarded to it by the delegates or the CSSF. 6.2 Form of a Complaint A complaint may be made by phone, mail or email to Nordic Fund Services S.A. To the attention of the Complaints Handling Officer 34A, rue Philippe II L-2340 Luxembourg Tel: +352 621 817 913 mw@nordicfs.lu 6.3 Acknowledgement of Receipt and Update When an investor submits a complaint the Company will send him a written acknowledgement of receipt of the complaint and/or bring an answer within five business days. Each complainant must be informed of the name and contact details of the person in charge of his/her file. At the latest ten days weeks after the acknowledgement letter an update or response must be provided to the complainant. 6.4 Investigation Each complaint must be analysed in order to identify the reason for the complaint and to ascertain responsibilities. The Company will seek to gather all relevant evidence and information. The investigation must be handled without delay. 6.5 Answer and Resolution An answer and possible resolution must be presented in writing to the complainant. The answer must always be made in writing and be signed by the Conducting Officer. The answer must be provided without undue delay and in any case, within a period which cannot exceed one month between the date of receipt of the complaint and the date at which the answer to the complainant was sent. Where an answer cannot be provided within this period, the Company must inform the complainant of the causes of the delay and indicate the date at which the examination is likely to be achieved. 3

Where the complaint handling does not result in a satisfactory answer for the complainant a full explanation on the position of the Company regarding the complaint must be given in writing. Furthermore the complainant must be informed in writing of the existence of the out-of-court complaint resolution procedure at the CSSF and a copy of the relevant CSSF regulation must be sent to him or a reference to the CSSF website, as well as the different means to contact the CSSF to file a request. 6.6 Closure of Complaints A complaint can be closed if the Conducting Officer has sent a final response or the complainant has positively indicated acceptance of the Companies earlier response or the complainant has failed to revert to the Company within 8 weeks of the most recent letter from the Company, which letter must advise that the Company has not received a response to earlier letters sent by the Company and the case has been closed or the complainant has contacted the Company to confirm that the complaint is dropped, in which case a letter will be sent by the Company confirming that the complaint has been closed on the instructions of the complainant. 6.7 Records All measures taken for the resolution of a complaint and how it was resolved shall be recorded in the complaints folder. 6.8 Complaints Register All complaints received must be registered in the Complaints Register. 7 Analysis of Complaints The Conducting Officer shall analyse the data relating to the complaint handling, on a permanent basis, in order to enable the identification and treatment of any recurring or systemic problem, as well as any potential legal and operational risks, for example: by analysing the causes of the individual complaints in order to identify the root causes common to certain types of complaints; by considering whether these root causes may also affect other processes or products, including those to which the complaints do not relate directly; and by correcting these root causes, when it is reasonable to do so. 7.1 Quarterly Report to the Board On a quarterly basis, the Conducting Officer informs the Board of Directors of the Company about complaints received and ongoing actions to solve them. 7.2 Yearly Report to the CSSF The Conducting Officer is CSSF responsible for sending an annual report to the CSSF in accordance with circular 12/546 indicating the number of complaints filed by the investors, the reason for these 4

complaints as well as the progress made in handling them. This report will be sent at the latest one month after the ordinary general meeting that approves the annual accounts of the Company. 5