Saltgate S.A. Complaint Handling Policy and Procedure
1. Introduction
1.1 Scope
The Complaint Handling Policy and Procedure (the Policy) applies to Saltgate S.A. (Saltgate).
1.2 Definitions
Saltgate defines a complaint as “Any expression of dissatisfaction, whether oral or written, and whether justified or not, from or on behalf of an eligible complainant about the firm's provision of, or failure to provide, a service”. Whilst Luxembourg regulations refer to “a complaint filed with a professional to recognise a right or redress a harm”, the intention of the definition is considered to be the same.
In this Policy, "third party" means any individual or organisation and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents and advisers.
Circular Commission de Surveillance du Secteur Financier (the “CSSF”) 17/671, as amended by Circular CSSF 18/698, that clarifies the rules applicable to customer complaints in the financial sector as provided by CSSF Regulation N° 16-07 of 26 October 2016 relating to out-of-court complaint resolution.
Saltgate is committed to acting in the best interests of its customers and will deal with any complaints received from customers, investors or other eligible third parties in a professional, efficient, transparent and equitable manner.
To assist Saltgate in upholding this commitment, Saltgate has designed and implemented the Policy.
Saltgate will provide information to its customers on:
- how to complain;
- how a complaint will be handled, including acknowledgement and indicative timeframe for providing a full response; and
- the out of court resolution process with the CSSF.
Saltgate will maintain a register of all complaints received.
Saltgate will appoint an Authorised Manager to be responsible for the oversight of client / customer complaints.
Compliance with this Policy is subject to periodic review by the compliance function and internal audit.
Complaints may be submitted verbally or in writing and will be escalated to the Compliance Officer and Authorised Manager responsible for the oversight of complaints.
Contact details are available via Saltgate’s website:
The submission should provide full details of the circumstances of the complaint.
Saltgate will appoint an Authorised Manager to be responsible for the oversight of client / customer complaints.
4.2 Acknowledgement of a complaint
All complaints received must be acknowledged in writing by Saltgate within five working days of receipt unless the complaint is satisfactorily resolved within this period. The acknowledgement will include the following:
- The name and contact details of the person who will be handling the complaint; and
- An anticipated date when the complaint will be fully responded to. This date must be no later than one month from the original date of receipt of the complaint. Where an answer cannot be provided within this period, a reason for the delay must be provided and a date indicated when the response will be provided.
The complainant must be kept informed of any progress made with their complaint, including details of actions being taken to resolve the matter. The complainant must then be informed when the complaint has been considered closed, and if not upheld, full and clear reasons given for the decision.
4.4 Failure to resolve a complaint
Where the response to the complaint has not satisfactorily resolved the matter, the complainant must be given the opportunity to escalate the complaint to the board and contact details provided where necessary.
In the event that an internal escalation proves unsuccessful in resolving the complaint, the complainant has recourse to the CSSF out of court resolution procedure, details of which are in the link below:
https://www.cssf.lu/wp-content/uploads/RCSSF_No16-07eng.pdf
In the event of a complainant reporting a matter to the CSSF in accordance with the out of court resolution procedure, Saltgate will co-operate fully in providing comprehensive information on the matter, as required.
The complainant must also be advised in writing how they may contact the CSSF to file a request. The request must be filed with the CSSF within one year after the complaint was filed with Saltgate.
