How to make a complaint

We are committed to providing a high standard of service. If something has
gone wrong, please let us know as soon as possible so that we can put it
right. You can make a complaint in writing, by email, by telephone or in
person.

What we treat as a complaint

A complaint is any oral or written expression of dissatisfaction, whether
justified or not, about the provision of, or failure to provide, a financial
service which alleges that the complainant has suffered (or may suffer)
financial loss, material distress or material inconvenience. We take
complaints seriously. Our approach is underpinned by our desire to treat our
clients fairly, and complainants will be handled with courtesy at all times.

It may not always be clear that a complaint is being made; sometimes it may
appear simply to be a general expression of unhappiness with the standard of
service. Anything which could reasonably be construed as a complaint will be
brought to the attention of our Compliance Officer.

All complaints will be investigated free of charge, competently, diligently
and impartially, obtaining additional information as necessary.

What we will do when you complain

Resolution within 3 business days

When we receive your complaint we will log it immediately and consider
whether it is a matter we can resolve within 3 business days. If it is, we
will send you a Summary Resolution Communication confirming that we consider
the matter resolved.

More complex matters

Where the matter is of a more serious nature or cannot be resolved within
3 business days, we will promptly (within 5 business days at most) acknowledge
your complaint in writing, confirm who is handling it and enclose a copy of
this complaints procedure. We will then keep you informed of the progress we
are making to resolve the complaint.

Our final response — within 8 weeks

Within 8 weeks of receiving your complaint we will send you a final
response which either accepts the complaint and, where appropriate, offers
redress and/or remedial action, or rejects the complaint and provides reasons
for doing so.

Where it is found that redress is appropriate, we will aim to provide you
with fair compensation for any acts or omissions for which we were
responsible. If you accept our offer, we will promptly provide compensation
in a manner agreed with you.

If for any reason it is not possible to provide a final response within
8 weeks, we will write to you to explain why and tell you when you can expect
a final response. That letter will also inform you of your right to refer
the complaint to the Financial Ombudsman Service (see below).

Your right to refer to the Financial Ombudsman Service

If you are an eligible complainant and you remain dissatisfied with our
final response — or if 8 weeks have passed without our final response —
you may refer your complaint to the Financial Ombudsman Service (FOS), free
of charge.

Who is an eligible complainant?

Under FCA rules, eligible complainants include:

• a private individual (a consumer);
• a business which has a group annual turnover of less than £6.5 million, an annual balance sheet total of less than £5 million, or fewer than 50 employees;
• a charity with an annual income of less than £6.5 million; or
• a trustee of a trust with a net asset value of less than £5 million.

When we will close your complaint

We regard a complaint as closed when our final response is issued and no
further action is proposed by us, or when you accept our response in writing.
Where you decline our response and refer the matter to FOS, the complaint
remains open until FOS informs us in writing that the complaint has been
closed.

Records and root-cause analysis

We maintain a complaints register that captures all expressions of
dissatisfaction along with the measures taken to resolve them. Records are
retained for at least five years and are available for inspection by the
Financial Conduct Authority. Our Compliance Officer regularly reviews the
register to identify trends, the implications for other clients, and any
training or process changes needed.

How to request a copy of this procedure

A copy of this complaint-handling procedure is available on request from
our Compliance Officer at the address above, free of charge.