POLICY & PROCEDURE COMPLAINTS HANDLING

Transcription

1 POLICY & PROCEDURE COMPLAINTS HANDLING DATE: OCTOBER 2018 The art and science of investing TM

2 CONTENTS 1 Introduction How to Complain The Investigation Process Taking Your Complaint Further UK-Domiciled s Irish-Domiciled s Data Protection Appendix One DST Citibank Europe plc State Street Appendix Two Appendix Three... 9 Version Control... 9

3 1 INTRODUCTION The purpose of this policy is to outline Merian Global Investors (UK) Limited s ( MGI ) procedure for handling complaints from clients. We recognise that, regrettably, from time to time clients may have cause to complain about the service we provide to them. Where a complaint is received from a client we want to ensure that it is properly investigated and that wherever possible the complaint is resolved and a response provided to you at the earliest opportunity. 2 HOW TO COMPLAIN Before making a complaint you should ensure you are addressing this to the correct party. The best party to address a complaint to, is the one who you receive the majority of your communication from in relation to your investment. Appendix One provides contact details for raising a complaint with the appropriate party. Appendix Two provides a list of MGI s funds and the appropriate party to contact regarding a complaint. However, if a complaint is referred to MGI we will ensure it is redirected to the correct party who will respond in accordance with their own Complaints Procedure. If you wish to make a complaint direct to MGI you can do so: By Post: Complaints Manager, Merian Global Investors, Millennium Bridge House, 2 Lambeth Hill, London, EC4P 4WR By Telephone: Dial and asking to speak to a member of the Client Services Team You should include as much information as possible to enable the recipient to identify you, for example full name, address, fund(s) invested in, and any client account numbers. It is also advisable to inform us of how you can be contacted in case we need to obtain further information. Where MGI has identified you, your family members or your close associates as a Politically Exposed Person ("PEP"), the Money Laundering, Terrorist Financing and Transfer of s (Information on Payer) Regulations 2017 provide that you are eligible to complain to the Financial Ombudsman Service about complaints arising out of their identification as such, or any acts or omissions by the firm as a result of that identification. Such complaints should be made directly to MGI. 3 THE INVESTIGATION PROCESS Upon receipt of a complaint this will be referred to our Compliance department, who will ensure someone with sufficient seniority and knowledge can investigate the complaint fully. Where the complaint is a MiFID complaint, for example a complaint about investment services provided by ourselves, we will categorise the complaint as a MiFID complaint and investigate it in line with our MiFID regulatory obligations. All client categorisations are entitled to be categorised as a MiFID complaint. Where the complaint is not a MiFID complaint but is made by an eligible complainant, we will continue to investigate the complaint in line with our regulatory obligations. If a complaint cannot be resolved swiftly an acknowledgement letter will be sent to you within five business days from the date of receipt of the complaint. The acknowledgement will advise you who will be responsible for the investigation and in instances where you have complained verbally, it will record our understanding of your complaint.

4 We aim to respond to any complaint as quickly as possible but invariably some complaints take longer to resolve due to their complexity or the need to obtain further information. We would normally hope to send a final response to you within four weeks of receiving a complaint. In the event that we are unable to send a final response within this timescale, we will write to you detailing why we are not yet in a position to resolve the complaint together with an indication of when we will make further contact. In the unlikely event that we are unable to resolve your complaint within eight weeks after receipt we will advise you in writing providing an explanation for the further delay and when we expect to be able to provide a final response. We will also inform you of your right to refer the complaint to the relevant Ombudsman Service should you be dissatisfied with the delay. On conclusion of our investigation we will write to you with our final response. In the event you remain dissatisfied you have the right to refer the matter to the relevant Ombudsman Service (see section below on Taking Your Complaint Further) within six months from the date of the final response letter. Details of the relevant Ombudsman will be contained within the Final Response. 4 TAKING YOUR COMPLAINT FURTHER 4.1 UK-DOMICILED FUNDS If your complaint relates to a UK-domiciled fund (see Appendix 2 for clarification) and we do not resolve your complaint within eight weeks from the date of receipt of your initial letter, or after conclusion of our investigation you remain dissatisfied, then you have the right to refer your complaint to the Financial Ombudsman Service at no additional cost. The Financial Ombudsman Service is an impartial body that will review your complaint, obtaining relevant details from you and the company you are complaining about. A copy of the Financial Ombudsman Service's explanatory leaflet will be enclosed within our Final Response letter for your reference. Complaints can be referred to the Financial Ombudsman Service in the following ways: By Post: The Financial Ombudsman Service, Exchange Tower,, Harbour Exchange, London, E14 9SR By Telephone: Dial By complaint.info@financial-ombudsman.org.uk Through Their Website: IRISH-DOMICILED FUNDS If your complaint relates to an Irish domiciled fund (see Appendix 2 for clarification) and we do not resolve your complaint after 40 working days have expired (from the date we were notified of the complaint), or after conclusion of our investigation you remain dissatisfied, then you have the right to refer your complaint to the Financial Services Ombudsman. The Financial Services Ombudsman is a statutory officer who deals independently with unresolved complaints from consumers about their individual dealings with all financial service providers. It is a free service to the complainant. The Financial Services Ombudsman provides information on their website regarding submitting a complaint and also provides a complaint form to be completed. Complaints can be referred to the Financial Services Ombudsman in the following ways: By Post: The Financial Services Ombudsman Bureau, 3rd Floor, Lincoln House, Lincoln Place, Dublin 2, Ireland By Telephone: Dial +353 (1) By enquiries@financialombudsman.ie Through Their Website:

5 5 DATA PROTECTION Under Data Protection Legislation, MGI is required to only retain Personal Data for as long as is necessary for the purpose for which it has been collected or for legal or regulatory reasons. Where Personal Data is no longer required this will be disposed of securely in accordance with MGI s policies. MGI s Privacy Notice is available from our website for further information.

6 6 APPENDIX ONE 6.1 DST For funds where the administration is managed by DST Systems, please contact their dedicated customer service team to investigate complaints: The correct address is: Complaints Team, DST Systems, Paragon House, Coval Wells, Parkway, Chelmsford, Essex, CM1 1WB 6.2 CITIBANK EUROPE PLC For funds where the administration is managed by Citibank Europe Plc, please contact their dedicated customer service team to investigate complaints: Complaints can be made through the following methods: By Post: Citibank Europe Plc, Transfer Agency 3 rd Floor, 1 North Wall Quay, Dublin 1, Ireland By Telephone: Dial By MGITA@citi.com 6.3 STATE STREET For funds where the administration is managed by State Street complaints should be referred to: By Post: International Financial Data Services, Transfer Agency Department, 78 Sir John Rogerson s Quay, Dublin 2, Ireland

7 7 APPENDIX TWO Below is a list of Merian Global Investors funds which provides details of the relevant party to contact regarding your complaint. Once received your complaint will be investigated in line with the relevant party's Complaints Policy which will be available to you on request. Name Name of Umbrella Country of Domicile Address Complaint to MGI Arbea Merian Arbea Limited Cayman Citibank Europe Plc Merian Asian Equity Income Merian Asia Pacific Merian Investment s Series II UK DST Merian China Equity Merian Corporate Bond Merian Investment s Series I UK DST Merian Emerging Market Debt Merian Europe (ex UK) Smaller Companies Merian European Equity (ex UK) Merian Investment Series II UK DST Merian European Equity Merian Financials Contingent Capital Merian Global Emerging Markets Merian Global Equity Absolute Return Merian Global Equity Merian Investment s Series II UK DST Merian Global Equity Income (IRL) Merian Global Strategic Bond DST Merian Investment s Series II UK Merian Global Strategic Bond (IRL) Merian Gold & Silver Merian Investment Grade Corporate Bond Merian Local Currency Emerging Market Debt Merian Monthly Income Bond DST Merian Investment s Series I UK Merian North American Equity Merian North American Equity Merian Pacific Equity Merian Strategic Absolute Return Bond Merian Style Premia Absolute Return Merian Systematic Positive Skew Merian Global Investors Series III Plc Ireland State Street Merian Total Return USD Bond Merian UK Alpha Merian Investment Series I UK DST

8 Name Name of Umbrella Country of Domicile Address Complaint to Merian UK Alpha (IRL) Merian UK Dynamic Equity Merian UK Equity Merian Investment s Series II UK DST Merian UK Equity Income Merian Investment s Series I UK DST Merian UK Mid Cap Merian Investment s Series I UK DST Merian UK Opportunities Merian Investment s Series I UK DST Merian UK Smaller Companies Focus Merian UK Smaller Companies Merian Investment s Series I UK DST Merian UK Specialist Equity Merian US Equity Income Merian World Equity Merian US Equity Income

9 8 APPENDIX THREE VERSION CONTROL Date Version Comments Author January 2018 v.1.0 MiFID II text additions Compliance September 2018 v.1.1 Amended for change of name Compliance This communication is issued by Merian Global Investors (UK) Limited ( Merian Global Investors ). Merian Global Investors is registered in England and Wales (number: ) and is authorised and regulated by the Financial Conduct Authority (FRN: ). Its registered office is at 2 Lambeth Hill, London, United Kingdom, EC4P 4WR.