Complaints
Complaints Handling Procedure
Definition of Complaint
For the purposes of the submission of this form and for our own internal complaints handling procedures, a complaint is defined as any expression of dissatisfaction, whether oral or written, regarding Nine Blocks' products, services, employees, or any other aspect of its operations, from institutional investors and qualified high-net-worth individuals.
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Framework
All complaints by current, prospective or past clients and investors in any Fund should be notified to the management and the Chief Compliance Officers immediately. All complaints must be handled in a timely and appropriate manner, and effective remedial action must be taken. The Chief Compliance Officer should log complaints and ensure the senior management is aware of them. All complaints should be acknowledged within 7 days.
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Procedure
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Step 1: Recording the complaint
Employees who receive a complaint, either in writing or verbally, must promptly record the complaint by completing the Client Complaint Record and forwarding it to the Compliance Officer immediately. Any related correspondence must be attached to the Client Complaint Record. In the event a complaint is made verbally, Employees should request the complainant to submit the complaint in writing. Notwithstanding, the written complaint should not delay Employees from notifying the Compliance Officer. Employees are prohibited from privately negotiating the settlement of any complaint. To ensure a complaint is handled in a fair and impartial manner, Employees involved in the conduct of the financial service for which the complaint is made must not handle the complaints resolution.
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Step 2: Notification of receipt of complaint
The Compliance Officer will notify the Chief Executive Officer of the complaint and together, depending on the severity of the complaint:
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(a) seek to resolve the complaint on the same day of receipt. If resolution is possible on the same day, the resolution will be communicated in writing by either the Compliance Officer or the Chief Executive Officer, as appropriate on that day;
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(b) in the event the complaint cannot be resolved the same day, the Compliance Officer will acknowledge receipt of the complaint in writing to the client as soon as possible and at the very least within 10 days of receipt, provide an overview of the Firm’s complaint procedures, and provide a timeframe for resolution, which should be as soon as possible and at the very least within 60 days from receipt.
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Step 3: Investigation of complaint
The Compliance Officer and the Chief Executive Officer will together take the necessary steps to investigate and resolve the complaint fairly, consistently and promptly within the anticipated timeframe communicated to the client.
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Step 4: Communicate resolution
Upon conclusion of the investigation the client must be informed of the resolution in writing by either the Compliance Officer or the Chief Executive Officer, as appropriate, as soon as possible and at the very least within the timeframe communicated to the client. The Firm must comply with the resolution communicated with the client. If the complainant is not satisfied with the resolution, the Firm will inform the complainant of other avenues, if any, for the resolution of the complaint, such as an external dispute resolution arrangement, arbitration or the UAE Court and provide him with the appropriate contact details upon request.
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Step 5: Record outcome
The Compliance Officer will summarize the details of the complaint and its resolution in the Register of Client Complaints and place any relevant information relating to the complaint on file.
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Step 6: Review and mitigate
The Compliance Officer will review the Firm’s systems and controls, where relevant in light of the complaint, and make the necessary enhancements to prevent any recurring or systemic problems identified.
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Step 7: Report to Board
The Compliance Officer reports any complaints and their status to the Board as part of its quarterly compliance report.
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Record Keeping
All complaints received, along with their resolutions and any other related documentation, will be appropriately recorded and maintained by Nine Blocks. These records will be retained in accordance with applicable laws and regulations.
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