Disclosure notice

Contents

Introduction

1. Risk Warnings Related to Shares (Equities)
   1.1. General risk warnings
   1.2. Dividend Payment Not Guaranteed
   1.3. Dealing/Administrative Costs
   1.4. Market Gapping
   1.5. Non-readily Realisable Investments
   1.6. Past Performance
   1.7. Dealing in Securities which may be Subject to Stabilisation
   1.8. Liquidity Risk in Shares
   1.9. Information on Overseas Investments
   1.10. Price Volatility
   1.11. Settlement
2. Risk Warnings Related to Fractional Shares
3. Risk Warnings Related to Share Lending
   3.1. General Structure
   3.2. Dividend taxation
   3.3. Corporate actions
   3.4. Counterparty credit risk
   3.5. Intraday price volatility
   3.6. Short selling
4. Risks associated with Extended Hours Trading
   4.1. Lower Liquidity
   4.2. Higher Price Volatility
   4.3. Wider Spreads
   4.4. News Announcements
   4.5. Changing Prices
5. Risk Warnings Applicable to Both CFDs and Equities
   5.1. Execution Only - You trade entirely at your own risk
   5.2. Market Risk
   5.3. Volatility Risk
   5.4. Currency Risk
   5.5. Interest Rate Fluctuation Risk
   5.6. Regulatory and Taxation Changes Risk
   5.7. Liquidity Risk
   5.8. Risk of Disruption orInterruption of Access to Exinity’s Electronic Systems and Services
   5.9. Segregated Account
   5.10. Uninvested Money Risks

1. What is a conflict of interest?
2. Managing and monitoring conflicts
   2.1. Policies and procedure
   2.2. Supervision
   2.3. Remuneration
   2.4. Gifts & inducements
   2.5. Outside business interests
   2.6. Personal account dealing
   2.7. Dealing & allocation
   2.8. Policy of independence
   2.9. Confidentiality
3. Summary on Conflicts of Interest

1. Introduction
2. What is a complaint?
3. How to make a complaint?
4. Investigation
5. Timeframes & External Dispute Resolution

Introduction

NEMO is the trading name of Exinity UK Ltd. (“the Company”, “Exinity”, “the firm”,“we”, “our” or  us”). 

The Company is registered in England and Wales (Register number 10599136) and is authorised and regulated by the Financial Conduct Authority (Register number 777911). 

TheCompany is committed to:

• providing a high standard of client service; and
• maintaining its reputation for credibility and accountability.

We welcome feedback on our service at any time. If you are dissatisfied with our services, please give us the opportunity to fix the problem. We will investigate, answer your questions and work hard so you enjoy trading with us. Should you feel dissatisfied with any aspect of our service, your first action should be to contact our CustomerService Team at hi@nemo.money  

The following disclosures provide you with information about the nature and risks of certain investment types, how we identify, monitor, manage and, where applicable, disclose conflicts of interest that may arise from time to time and how you can submit complaints and our processes for dealing with such complaints. 

All words and phrases highlighted and not defined in this Disclosure Notice, shall have the same meaning as defined in our Invest Terms and CFD Terms (as applicable).

A. Risk Disclosure

1. Risk Warnings Related to Shares (Equities)

1.1. General risk warnings
‍Shares represent a part of ownership in a company. As such, the owner of a share participates in the fortune of the company. If the company does well, the shares are likely to rise in price, but if the company does poorly, the share price is likely to fall. 

Holders of ordinary shares are the last to be paid in the event of a company becoming insolvent. However, ordinary shareholders also have the potential for returns in the form of dividends or share price appreciation, provided the company does well and is perceived to be continuing to do well. In extreme cases, a company can become insolvent, and you may lose all the value of your investment. 

Share prices are based on supply and demand forces which in many cases depend on perceptions of the companies’ future prospects by the market. If in general, market sentiment is pessimistic about a company and its future prospects, the share price will likely fall, and therefore, if you sell at that point or if the price does not recover, you get back less than you put in. 

The value of your investments and the level of any income from them can go down as well as up. You may not get back the full amount you have invested. You should also remember that past performance of shares is not an indication of how those Investments might perform in the future. 

Certain investments may not be readily realisable. You may have difficulty selling these investments at a reasonable price, and in some circumstances, it may be difficult to sell them at any price. 

The potential for profit or loss from transactions on foreign markets or in foreign-denominated contracts will also be affected by fluctuations in foreign exchange rates.

1.2. Dividend Payment Not Guaranteed‍
Some shares pay a dividend, either semi-annually or quarterly. A dividend is an amount of money determined by the company’s Board of Directors, which is a distribution of the company’s profits. Established, profitable companies tend to pay dividends and have a good record of providing a steady stream of dividend payments.Periods of economic difficulty may, however, interrupt such dividend payment for even the most established shares. Younger, less established companies that are building a business tend to retain their profits for re-investment. These are called “growth” companies as their business strategy is to grow their business rapidly.

1.3. Dealing/Administrative Costs
‍Costs and charges levied by ourselves or third parties will reduce potential profit you can make or increase the level of loss. Before you begin to trade, you should understand all charges for which you will be liable.

1.4. Market Gapping
This is a sudden shift in the price of an instrument or its underlying from one level to another. It can happen at any time but occurs most frequently when the market closes at one level but reopens at another. This can cause unexpected losses.

1.5. Non-readily Realisable Investments
Stocks can become non-readily realisable investments. These are investments in which the market is limited or could become so. You may have difficulty selling such an investment at a reasonable price and, in some circumstances, it may be difficult to sell it at any price. Do not invest in such investments unless you have carefully thought about whether they are suitable for you.

1.6. Past Performance
You should be aware that the price of the financial instruments that you are dealing with depends on fluctuations in the financial markets, company fundamentals and data points that are outside of our control and that past performance is no indicator of future performance.

1.7. Dealing in Securities which may be Subject to Stabilisation
We, and/or our representatives, may from time to time carry out transactions on your behalf in securities subject to stabilisation. Stabilisation enables the market price of a security to be maintained artificially during the period when a new issue of securities is sold to the public. Stabilisation may affect not only the price of the new issue but also the price of other securities relating to it.

1.8. Liquidity Risk in Shares
Shares are available in companies of different sizes, industrial sectors, geographical locations, and on different stock markets. Liquidity is an important risk factor when investing in individual equities and is generally driven by the market capitalisation (total value of issued shares) of the company and current market conditions. Liquidity levels can change rapidly and lack of liquidity often restricts trading in equities with smaller market capitalisations (known as mid-cap and small-cap).

1.9. Information on Overseas Investments
Information on overseas investments is not as readily available to the UK public as for UK companies and the financial pages of the national press give little coverage of the subject. Different time zones also mean that you will not always be able to get a real-time price for overseas stocks during the UK trading day. When investing in overseas markets, currency fluctuations need to be taken into account. A gain or loss made on the performance of a stock can easily be offset by a movement in the currency exchange rate. Alternatively, a gain or loss on a stock could be compounded to make an even larger one. Liquidity considerations are similar to UK shares.

1.10. Price Volatility
The price of individual shares can fluctuate considerably and can appreciate or decline rapidly. Shares can also remain in decline over long time periods. Share prices rise and fall according to the health of the company and general economic and market conditions. Individual share price rises and falls can be significant.Stock market investments tend to be more volatile than investments in most bonds.

1.11. Settlement
With respect to Shares, in many marketplaces (for example shares traded on the LondonStock Exchange) settlement takes place by the counterparties simultaneously matching shares traded with cash being given.

2. Risk Warnings Related to Fractional Shares

‍Fractional shares cannot be traded on public exchanges and are illiquid and unrecognised outside our trading platform. You can only liquidate them when they are sold through us and they cannot be transferred to another broker unless they are sold. 

We will comply in all respects with “best execution” on all orders executed through Exinity in line with its regulatory requirements.This means that execution will be based on a price no worse than the prevailing bid/offer on the reference exchange as of the time of your order for all full share and fractional share components of a transaction. Any Order greater than one share that includes a fractional share component will be executed in a mixed capacity. Exinity, and /or our partners, will act in a matched principal capacity with respect to the fractional share components of the transaction. If you enter an order solely for a fractional share, Exinity and /or our partners, will execute your trade over-the-counter, matching it internally based on a price no worse than the prevailing bid/offer on the reference exchange as of the time of your order. Orders entered outside of regular trading hours cannot be executed. 

Exinity and /or our partners, rounds all fractional holdings to eight decimal places. For all notional-based orders, your transaction will never exceed the order amount. Rounding may also affect your ability to be credited for cash dividends, stock dividends and stock splits. For example, if you own 0.00000001 shares of stock that pays a one-cent dividend per share, we will not credit your cash balance a fraction of a cent. In carrying out rounding, we will use reasonable endeavours to get as close as possible to your order. However, we shall not be liable for any loss or damage suffered or incurred by you arising out of or in connection with such rounding, save to the extent directly attributable to our negligence, fraud, wilful default, breach of contract or breach of the FCA Rules.

On a best-effort basis your voting rights will be facilitated on a pro-rata basis. However, this right  cannot be guaranteed. We do not restrict in any way any rights you would otherwise have over the securities and funds in your Exinity account, including any fractional shareholdings. 

There are potential conflicts of interest in connection with fractional transactions and you have consented to this transaction by agreeing to the Invest Terms. You may revoke your consent to such a transaction at any time by written notice to us.  

Fractional shares are not transferable. If you close your Account or transfer your Account to another firm, the fractional shares held in your Account shall be liquidated.Similarly, Fractional shares cannot be put into certificate form and mailed. Liquidations of fractional shares may result in additional charges.

3. Risk Warnings Related to Share Lending

3.1. General Structure
When we, and/or our representatives, borrow your shares, we act as your counterparty and are obliged to redeliver those shares to you. We, and/or our representatives, may on-lend the shares we borrowed from you to a reputable third party (the “Borrower”) through a back-to-back lending arrangement. The Borrower will have an obligation to redeliver theshares to us..

3.2. Dividend taxation
Shares lent to the Borrower are generally recalled from the Borrower before the ex-dividend date to capture the dividend. Where there call does not happen, we, and/or our representatives, receive a payment from the Borrower, and you will be entitled to a payment from us in the form of a manufactured payment in lieu of a dividend, equivalent to the dividend you would otherwise have received. Please note that this payment may have different tax implications, and you are responsible forany associated tax obligations.

3.3. Corporate actions
For shares lent, voting rights will be held by the Borrower, and you lose those voting rights. However, other Corporate Actions such as rights or bonus issues will be processed as usual. This means that you will receive any other rights and distributions made on loaned shares.

3.4. Counterparty credit risk
There is a potential counterparty credit risk where we or the Borrower become insolvent and do not return your shares. We, and/or our representatives, mitigate this risk by providing you with collateral, equal to at least 102% of the value of shares lent. The collateral will be in the form of US Treasury Bonds and will be held in line with FCA’s Client Asset Rules in a segregated account with a reputable third party.

3.5. Intraday price volatility
Due to market volatility, the value of the lent shares can increase or the value of the collateral can decrease, potentially leaving you insufficiently collateralised. We, and/or our representatives, mitigate this risk by monitoring the collateral on a daily basis, to ensure that its value is equal to or more than 102% value of the shares lent. 

In the unlikely event of Exinity, and/or our representatives, and the Borrower going bankrupt prior to the collateral being adjusted, your assets are protected up to £85,000 by the Financial Services Compensation Scheme. Further details can be found on www.fscs.org.uk

3.6. Short selling
Lent shares are typically used for shorting, which could affect the value of the stock. Short selling could put downward pressure on the price of the lent shares and affect their long-term value.

4. Risks associated with Extended Hours Trading

4.1. Lower Liquidity
‍Exinity allows users to place “market-on-open"orders whereby your market order – which can be placed at any time – will execute when the market opens. When the underlying market opens the amount of orders on the market are usually lower in comparison to Regular Market Hours, because fewer traders are buying and selling stocks. As a result, your orders may take more time to fill, may get filled partially, or in some cases not get filled at all.

4.2. Higher Price Volatility
‍Due to the lower volume of trades, prices when markets first open may be significantly more volatile in comparison to Regular MarketHours. As a result, your orders may get filled at a less favourable price compared to the price you would get during the regular trading session.

4.3. Wider Spreads
‍A spread is the difference between a stock’s buy and sell price. In an environment of lower liquidity and higher volatility, as in when markets first open, spreads may become wider than usual and thus lead to less favourable conditions for buying and selling stocks.

4.4. News Announcements
‍Often companies and other institutions release important information outside the Regular Market Hours, such as earnings, buyback of shares, etc. Combined with higher volatility and lower liquidity, this may cause significant price spikes in some stocks outside of Regular Market hours and increase these risk.

4.5. Changing Prices
‍The prices of stocks traded during when markets first open may not reflect the prices either at the end of Regular Market Hours, or the regular session opening on the following day. As a result, you may receive less favourable pricing.

5. Risk Warnings Applicable to Both CFDs and Equities

5.1. Execution Only - You trade entirely at your own risk
‍Our service is "execution only", meaning we will only carry out your trading instructions. We shall not offer you any advice or recommendation regarding the suitability of any investments with us, and nothing we send or tell you should be interpreted as such. We do not provide investment, tax or trading advice. Our service is "execution-only", meaning we will not advise you on any transaction, nor will we monitor your trading decisions to determine if they are appropriate for you or to help you avoid losses. You should obtain your own financial, legal, taxation and other professional advice as to whether CFDs or Shares are an appropriate investment for you. We may provide you with factual information in relation to our products, their potential risks, or about the financial markets in general; in doing so we shall not have assessed your individual circumstances.

5.2. Market Risk
‍Trading with Shares and CFDs carries the risk of sudden market fluctuation. Prices can go up as well as down. CFD trading in particular relies on the price movement of underlying financial products. You are therefore exposed to similar but magnified risks to holding the underlying assets.

5.3. Volatility Risk
‍Markets for CFDs and Shares can be highly volatile. The prices of CFDs and their UnderlyingProducts (shares or indices) may fluctuate rapidly and over wide ranges. The prices of CFDs will be influenced by, among other things, the market price of the underlying product of the CFD, the earnings and performance of the company or companies, whose shares comprise the underlying product or a related index, the performance of the economy as a whole, the changing supply and demand relationships for the underlying product or related instruments and indices, governmental, commercial and trade programs and policies, interest rates, national and international political and economic events and the prevailing psychological characteristics of the relevant marketplace.
‍
Furthermore, sharp, sudden and unexpected movements in the underlying product’s price may result in a substantial and magnified profit or loss to you. Markets may not move in a smooth fashion, and price ‘gaps’ may occur with consecutive quotations far apart. There may not always be an opportunity for you to place an order or forour platform to execute an order at the price level which you have selected. One of the effects of this may be that stop-loss orders are executed at unfavourable prices, either higher or lower than you may have anticipated, depending on the direction of your trade.

5.4. Currency Risk
‍Where you are trading a product denominated in a currency different from that in which you hold your account, fluctuations in the exchange rate affect your profit and loss. 

When you deal in a CFD or in Shares that are denominated in a currency other than the base currency or currency in which you have deposited in your account, all margins, profits, losses and financing credits and debits in relation to that CFD are calculated using the currency in which the CFD is denominated. Thus, your profits or losses will be further affected by fluctuations in the exchange rates between the account currency and the currency in which the CFD is denominated. We apply a margin "haircut"to reflect this risk, and so the Margin Requirement on the CFD will effectively increase.

5.5. Interest Rate Fluctuation Risk
‍Interest rates fluctuate, which will affect the financing charges (or rebates) you will pay (or may receive) on your long (or short, in the case of CFDs) positions. This will also affect your total profits or losses.

5.6. Regulatory and Taxation Changes Risk
‍Changes in taxation and other laws, government, fiscal, monetary and regulatory policies may have an adverse effect on the value of your CFDs or Shares, the tax you pay on your CFDs or Shares, and the total return on the products.

5.7. Regulatory and Taxation Changes Risk
‍Under certain circumstances, it may not be possible to close a part of or a whole position at the current price or at all. We are not obligated to provide quotes for any CFD at any time, and we do not guarantee the continuous availability of quotations or trading for any CFD. We may in our sole discretion cease quoting CFDs and/or cease entering new CFD or Shares transactions at any time based on lack of market data, halts or suspensions or errors or illiquidity or volatility in the market for the Underlying product, or our own risk or profit parameters, technical errors, communication problems, market or political or economic or governmental events, force majeure, or for other reasons.

5.8. Risk of Disruption orInterruption of Access to Exinity’s Electronic Systems and Services
‍We rely on computer software, hardware and telecommunications infrastructure and networking to provide its services to Clients, and without these systems, we cannot provide the services. These computer-based systems and services such as those used by us are inherently vulnerable to disruption, delay or failure, which may cause you to lose access to our trading platform or may mean we are unable to provide CFD or Shares quotations or trading, or may negatively affect any or all aspects of our services. Under our Invest and CFD Terms, you accept our systems and services and our liability to you is limited.

5.9. Segregated Accounts
‍In accordance with the FCA (Exinity UK Ltd.) regulations, all our client funds are held in segregated accounts. While we monitor the creditworthiness of our banks closely and select them on the basis of robustness and solidity, using only major international banks, this does not mean that they are risk-free. We can provide you with details of which banks we use, on request.

5.10. Uninvested Money Risks
‍When you hold Uninvested Money with Exinity, we may deposit your Uninvested Money with banks on your behalf and you may be eligible to receive interest from Exinity on Uninvested Money, as per the applicable Invest Terms. While your UninvestedMoney will continue to receive protections as client money (as per section 7.9above), that can still expose you to certain risks:

5.10.1 Inflation: Inflation risk occurs when the rate of inflation exceeds the interest rate earned, which can result in your money losing value over time. In case of inflation, the interest you may be eligible to receive from Exinity may not follow the pace of rising costs.

5.10.2 Credit risk: If the bank in which your Uninvested Money is deposited becomes insolvent, you may lose (a part of) your money. To manage this risk, as per section 7.9 above Exinity carefully selects banks and regularly monitors their creditworthiness. Additionally, you may be eligible to recover (a part of) your money from a protection scheme.

B. Conflicts of Interest

We have put in place a range of procedures in order to identify, monitor, manage and where applicable disclose conflicts of interest that may arise from time to time. The effectiveness of all these controls is monitored on an ongoing basis and forms part of our ComplianceMonitoring Programme. 

We place a great emphasis on maintaining a strong compliance culture. This culture is continually reinforced with all staff, and the need always to act in clients' best interest is the cornerstone of our philosophy.

1. What is a conflict of interest?

Conflicts of Interest may arise in any area of our business in the course of providing any investment and ancillary services, which may result in benefiting our interests. 

Conflicts of Interest can arise between various parties, including:

• Exinity and one or more of its clients;
• A director or an employee and one or more of the firm’s clients;
• A director or an employee and Exinity;
• Two or more of Exinity’s clients;
• A third-party service provider and Exinity;
• A third-party service provider and Exinity’s client(s); and,
• Two or more employees.

It is not desirable to enumerate a definitive list of circumstances in which conflicts could arise; part of staff training in this area is to recognise and remediate or escalate potential conflicts in the course of business. However, to help identify potential conflicts of interest, we have considered a number of areas, including:

• circumstances where we could make a financial gain, or avoid a financial loss, at the expense of a client;
• where financial or other incentives to favour the interest of one client or group of clients over the interests of another client or group of clients might arise;
• where our employees conduct personal account dealing and their positions oppose to clients’ positions, particularly in relation to less liquid stocks;
• where we mayor will receive an inducement from a third party in relation to a service provided to the client or us, in the form of monies, goods or services, other than the standard commission or fee for that service;
• where we have information about or have obtained information from one customer that is of relevance to transactions for another customer (for example information which shows one customer may be selling a specific stock and another buying; and
• where our employees accept benefits or gifts that could be construed as conflicting with our duties to the client.

Hereby, we have provided a summary of the most prevalent conflicts of interest that may arise and what we are doing to identify and mitigate them.

2. Managing and monitoring conflicts

We have a number of mechanisms in place to manage potential and actual conflicts, which are summarised below.

2.1. Policies and procedures
‍In order to identify, analyze and mitigate any possible conflicts of interest, we have embedded policies and procedures throughout our business to ensure conflicts are identified, considered and mitigated. We also run a robustCompliance Monitoring Plan, which includes ongoing monitoring of Conflicts of Interest. 

Our employees undergo regular training and receive guidance where conflict situations arise. The management teams are responsible for ensuring that their teams have robust controls in place to identify and manage risks which arise. We conduct a Risk Framework and have a register, where we record actual and potential conflicts of interests, as well as details of the controls which were put in place to mitigate potential issues.

2.2. Supervision
‍Where the interests of one team and its clients may conflict with the interests of another team and its clients, the management structure has been separated. We have in place measures designed to prevent or limit any person exercising inappropriate influence over the way in which services or activities are carried out.

2.3. Remuneration
‍In order to mitigate any conflicts of interest related to remuneration dissatisfaction, we have a remuneration policy which is updated annually. Our staff is remunerated by a combination of:

• Basic salary and related benefits; and
• Discretionary annual bonus.

These take into account individual, team and company performance. No employee will directly benefit from any single trade a client may make.

2.4. Gifts & inducements
In order to dissuade the possibility of gift receiving or inducements from our employees, we have procedures in place about the giving and receiving of gifts or hospitality.Employees must neither solicit nor accept any inducements which may conflict with our obligations to clients, nor offer inducements which could conflict with the recipient’s obligations to its own clients.

2.5. Outside business interests
We manage any possible conflicts of interest arising from employees’ outside-of-work activities that may arise by requiring all employees to disclose their outside business interests and directorships. We undertake pre-employment screening exercises in order to ensure that Staff is fit and proper and appropriately qualified.

2.6. Personal account dealing
In order to ensure our employees invest by complying with the relevant regulations and without using any insider information, we have in place restrictions regarding employees’ own, personal-account, dealing. All dealing or investment accounts must be approved by the management and copies of contract notes are automatically sent to the Compliance Department.

2.7. Dealing & allocation
In order to ensure that deals cannot be allocated in favour of one group of clients or staff, we operate dealing and allocation procedures which cover dealing fairly and in due turn.

2.8. Policy of independence
Our staff procedures require employees to disregard any material interest or conflict of interest when acting on clients’ behalf.

2.9. Confidentiality
Our strict client confidentiality policy ensures that all information relating to clients is retained with the firm and treated as confidential information.Confidential information is only disclosed to those entitled to receive it.Staff is prohibited from using any such confidential information for their own interests.

3. Summary on Conflicts of Interest

In practice, the conflict of interest arrangements summarised above have been designed to reduce the risk of a conflict of interest being detrimental to a client and inmost situations we consider that these will be sufficient to ensure clients’ interests are protected. However, there may be rare occasions where we consider these arrangements are insufficient. In such circumstances it may be possible to disclose the conflict of interest to the client(s) in writing directly or, in the event of a severe conflict of interest, we may need to cease or decline to act on a client’s behalf.

C. Complaints Procedures

1.  Introduction

Should you feel dissatisfied with any aspect of our service, your first action should be to contact our Customer Service Team at hi@nemo.money. The complaints handling section sets out the method for the submission of complaints by clients and our processes for dealing with such complaints.

2.  What is a complaint?

We define a complaint as “any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, or failure to provide, a financial service or a redress determination, which:

• alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience; and
• relates to an activity of that respondent, or of any other respondent with whom that respondent has some connection in marketing or providing financial services or products, which comes under the jurisdiction of the Financial OmbudsmanService.”

3.  How to make a complaint?

Any member of the Company staff can receive a customer complaint and has the responsibility to do everything within their authority to resolve the issue at the first point of contact. 

Complaints shall be submitted in writing through the normal Customer Support communication channels, namely by sending an email to our Customer Service Team at hi@nemo.money. 

To help us respond as quickly as possible, a complaint sent by the client shall include:

• the client’s name and surname;
• the client’s username;
• the client’s account number;
• the date on which the issue arose;
• the affected transaction numbers, if applicable; and
• a clear and logical description of the issue.

Complaints shall not include offensive language directed to either the Company or any Company employee. 

OurCustomer Support team may contact the complainant directly in order to obtain further clarifications and/or information. The complainant’s cooperation is required for the handling of the complaint in question. 

While our Customer Support team will be able to resolve the majority of queries, you may also refer the query as a complaint to our Compliance Department. We prefer to receive complaints in writing, as there is less potential for misunderstanding. 

In order to contact the Company’s Compliance Department, you should write to Complaints@Nemo.Money, or: 
‍
Compliance Department
Exinity UK Ltd.
1 St Katharine’s Way
London E1W 1UN 

‍setting out the details of your complaint as clearly as possible. 

TheCompliance Department operates independently and will carry out an impartial review of your case, contacting you for more information if necessary. They will endeavour to determine what happened or failed to happen and assess whether we have acted properly and in accordance with these terms and conditions and regulatory obligations. They may also determine whether any compensation is due.

4.  Investigation

On receipt of your complaint our staff will acknowledge your complaint and, where required, will commence an investigation. 

Whilst our internal procedures allow us up to eight weeks to deal with a complaint, every effort will be made to resolve complaints as quickly as possible.

5.  Timeframes & External Dispute Resolution

If after a period of eight (8) weeks, the Company has not completed its investigation and provided a final response, we must either:

A. provide a final response in writing, which:

• accepts the complaint, and where appropriate, offers redress or
• remedial action; or
• offers redress or remedial action without accepting the complaint; or
• rejects the complaint and gives our reasons for doing so, and, which
  i. encloses a copy of the Financial Ombudsman Services (FOS) standard explanatory leaflet or provide a link to;
  ii. provides the website address of the FOS;
  iii. informs the complainant that he or she may refer the complaint to the FOS if dissatisfied and, if so, do so within six (6) months of the date of our final response; and
  iv. indicates whether or not we consent to waive the relevant time limits.

B. provide a written response, which:

• explains why we are not in a position to give a final response and provide an indication as to when we expect to be able to do so;
• informs the complainant that he or she may now refer the complaint to the FOS;
• indicates whether or not we consent to waive the relevant time limits;
• encloses a copy of the FOS standard explanatory leaflet or provide a link to; and
• provides the website address of the FOS.

The FOS is an independent service in the UK established by the Parliament for settling disputes between businesses providing financial services and their customers. 

TheFOS will make a determination after reviewing your complaint and all relevant issues, for example, any relevant FCA rules. The FOS has the authority to resolve the complaint, and the Company will be bound by their determination. Should you decide to utilise The FOS, you can do so free of charge. You can contact the FOS by writing to:

‍Financial Ombudsman Service
Exchange Tower, LondonUnited Kingdom, E14 9SR
Phone: 0800 023 4567
Email: complaint.info@financial-ombudsman.org.uk
‍Web: http://www.financial-ombudsman.org.uk 

Please note that the FOS will not consider a complaint until we have had the opportunity to address the complaint, and any reference to FOS should not be made by you until you receive a final response from us or eight weeks after the date of your complaint, whichever is sooner. 

You can also choose to raise a complaint via the EuropeanCommissions Online Dispute Resolution Platform.However, since the Financial Ombudsman Service was established to deal with complaints regarding financial service firms based in the United Kingdom, it is likely that you will be referred to the Financial Ombudsman Service, whose details are outlined above.