COMPLAINTS HANDLING POLICY

1.1. PURPOSE

Anneau Ltd (“Anneau”) is fully committed to promoting customer satisfaction by encouraging feedback from customers, including complaints. Anneau views complaints as a useful tool for receiving feedback about a product or service. A complaint gives Anneau the opportunity to improve and maintain confidence in its products and services.

Anneau is committed to resolving complaints received and recognizes the rights of complainants to have their complaint dealt with fairly, effectively and efficiently. Anneau’s complaints handling procedures recognize the need to be equitable, objective and unbiased to both the complainant and the organization or personnel against whom the complaint is made. Anneau ensures that all persons who may be the first point of receipt of complaints are made aware of Anneau’s complaints-handling procedures, and of their roles, responsibilities and authority in respect of complaints.

This policy should achieve the following objectives:

1. Provide effective, efficient, equitable and accessible complaints handling procedures;
2. Set forth the guidelines for the client to file a complaint and by be informed as to the prescribed timeframe for Anneau to handle the complaint;
3. Provide Anneau with a clear framework for handling complaints in accordance with its legal obligations.
4. Recognise, enhance and protect the interests of Anneau’s customers, as well as managing their needs and expectations.
5. Identify, through analysis, evaluation and review of complaints, opportunities to improve on the quality of Anneau’s products and services, as well as the complaints-handling process.
6. Increase the level of customer satisfaction with the delivery of products and services and enhance Anneau’s relationship with its customers.
7. Provide any such other information to customers and Anneau employees on Anneau’s complaints handling procedures.

1.2. REGULATORY FRAMEWORK

Anneau recognises that the complaints-handling system should address the aspects of complaints handling outlined in the Financial Services Commission (“FSC”) Guidelines on Complaints Handling, issued under Section 7(1)(a) of the Financial Services Development Act 2001.

1.3. POLICY APPLICATION

Anneau will apply this policy and related procedures when dealing with all complaints made by its Clients regarding any advice provided by Anneau in respect of a Anneau financial product or any securities it invests in. This further includes any advice or opinions contained in flyers, brochures and other promotional material prepared by Anneau.

1.4. PROCEDURES

MAKING A COMPLAINT

A customer (‘Complainant”) who has a complaint and wishes to bring this to the attention of Anneau’s attention shall do so in writing (via an official signed letter and/or email, which may further be supported by a telephone call and/or face-to-face meeting) to:

The Chief Legal & Compliance Officer,

ANNEAU LTD
Victoria House, St Louis St, Port Louis, Mauritius
Phone: +2302141717
Emails: [email protected], Cc: [email protected]

Where requested, the Compliance officer shall provide assistance to complainants in the formulation and lodgement of complaints. A copy of this policy is available free of charge on request from the Compliance Officer. Information on the availability of complaints-handling procedures and contact details for complaints are outlined to customers at the reception of the company’s offices.

WRITTEN COMPLAINTS

1. An Anneau employee who receives a written complaint from a Retail Client must refer it to the Compliance officer, together with any other relevant information/documentation relating to the complaint, as soon as possible.

VERBAL COMPLAINTS

2. Where a verbal conversation with a Retail client leads to the client wishing to make a complaint, the Anneau employee dealing with the client should make a case note of the issue (including details such as name of the client, contact details, nature of the complaint, etc.), and explain to the client that his/her complaint will be investigated, and a response provided in writing. All this information is recorded in a Complaint Registration Summary Form, which is then provided to the Compliance officer without further delay. Where the matter is complex, the client should be encouraged to put their complaint in writing.

RECORDING A COMPLAINT

3. All complaints received by the Compliance officer are recorded by filling in a Complaint Registration Summary Form, which is filed in the Complaints Register.

INITIAL ACKNOWLEDGEMENT

4. Receipt of a complaint must be acknowledged as soon as possible and, in any event, within two (2 ) business days of it being received by Anneau.

5. If a complaint is already resolved by this time, an acknowledgement is not required. Advising the complainant of a decision in writing within this timeframe is deemed to be acknowledgement.

RESOLVING A COMPLAINT

6. The Compliance officer has the capacity to resolve complaints and to implement appropriate remedies when resolving complaints.

7. The Compliance officer may obtain assistance from any staffs in order to resolve a complaint and this shall be promptly given. Where appropriate, a draft complaint response may be prepared by another staff member with the agreement of the Compliance officer. The Compliance officer must approve the response to the complaint before it is issued.

8. When resolving a complaint, the Compliance officer must make every reasonable effort to investigate all relevant circumstances and information surrounding the complaint.

9. When a final response to a complaint is provided, the Compliance officer must advise the complainant of the decision as soon as practicable after deciding on the outcome. In practice the final response must be sent to the complainant within thirty (30) days from the date the complaint was received. It should be sent no later than five (5) business days after the Compliance officer approves the outcome.

10. The Compliance officer must record the decision and the reasons for the decision on the Complaint Registration Summary Form.

UNRESOLVED COMPLAINTS

11. A final response requires the complainant to be advised of the outcome of their complaint (including reasons for the decision where not in their favour), their right to take their complaint to the FSC and/or alternatively to a dispute resolution body or the court.

12. Anneau will have the obligation to report to the FSC any unresolved complaints after three (3) months of being received.

1.5. REFERRAL TO THE FSC

A complaint may be referred to the Commission by the complainant where no settlement has been reached within thirty (30) working days as prescribed in the FSC Complaints Handling Guidelines.

The Commission will entertain complaints only to the extent that all attempts to settle the complaint have failed and the consumer is not satisfied with the outcome.

The Commission may require Anneau to address a complaint and propose means of redress to the extent that the complaint deals with regulatory breaches, malpractice or unfair treatment. In discharging its functions under these Guidelines, the Commission may request the Investment Adviser to provide copies of the complaint letter and the final response letter.

1.6. TIMEFRAME FOR COMPLAINTS RESOLUTION

A complaint shall normally be settled within thirty (30) working days from the date of the filing of the complaint. A complainant shall be informed in writing of the company’s final response to the complaint within this time limit. Where possible, the final response letter shall indicate the reasons or circumstances which have been considered for the settlement or non-settlement, as the case may be, of the claim.

The final response letter shall propose, as appropriate, any offer or other means of settlement made to the complainant.

1.7. CHARGES

Complaints are handled free of charge to the complainant, subject to any statutory requirements.

1.8. LITIGATION

Anneau’s Chief Legal & Compliance Officer is to be informed in writing of all legal proceedings. Anneau’s Chief Legal & Compliance is to notify Anneau’s liability insurer (“insurer”) of the claim and ensure that the litigation is conducted in accordance with any legitimate requirements of the insurer. Anneau’s Legal & Compliance Department, in conjunction with our external legal counsel,  shall be responsible for the conduct of the legal proceedings and will liaise with any other parties to the litigation.

1.9. THE COMPLAINTS REGISTER

The Complaints Register is maintained at the premises. In respect of each complaint, the Complaints Register must contain a completed Complaint Registration Summary Form, copies of all correspondence between Anneau and the complainant, and of the correspondence/(s) between Anneau and the regulator, if needed, in relation to the complaint and any relevant file notes and supporting documentation.

1.10. RECORD KEEPING

The Compliance officer must keep the records of a complaint for a minimum period of three (3) years after the date of last correspondence on the complaint and/or for the duration of the client’s contractual agreement with the company.

1.11. ANALYSIS AND REPORTING

Analysis and evaluation of data gathered in the complaints process will help Anneau determine the causes of complaints (e.g. any systemic and recurring problems) and whether remedial action is necessary.

The Compliance officer must provide a written summary of the Complaints Register via a Complaints Report to the Board of Directors of Anneau and the Audit & Risk Committee of Anneau at the end of each semester and shall not be less than twice a year.

A complaint report may contain the following information:

1. the total number of complaints received within a period of time;
2. a breakdown by type of complaint received;
3. the number of complaints settled, and the type of settlement reached; and
4. the number of complaints not resolved, out of which the number of complaints referred to the Financial Services Commission.

This summary should highlight any areas of concern and matters of a repetitive nature. This summary shall serve as a monitoring tool, which enables management to monitor the effectiveness of Anneau’s complaints-handling procedures and identify trends (if any), which would indicate that improvements are required.

1.12. CONFIDENTIALITY

Personal information is handled in a manner consistent with the group’s Privacy Policy. This refers to maintaining confidentiality of personal information of the complainant. Generally, the complaint and any information related to it are kept confidential except with the consent of the complainant and/or in accordance with applicable regulatory disclosures.