Complaints Procedure

Scope:

Trustmoore Netherlands B.V. ("TMNL")

Owner

Compliance

Governance qualification

Level II

Effective Date:

02-11-2022

Version

Date latest review

02-11-2022

KEY PRINCIPLES

This Procedure is established to comply with legal obligations and as part of the aim of TMNL to provide good services. Besides, it is intended to ensure that TMNL handles complaints in a fair, efficient, and effective manner.

1. Definitions

Complaint	a complaint is a statement given in (1) writing that contains a strong negative criticism from a Client (2) expressed towards TMNL, including any of its employees and related to any of the services provided by TMNL to the Client and (3) requesting explanations and/or corrective actions from TMNL
Client	natural person or company with which TM enters a Business Relationship or for which a professional service is performed
Claimant	the claimant is the Client expressing the complaint
Feedback	opinions, comments, and expressions of interest or concern, made directly or indirectly, explicitly, or implicitly, to or about TMNL, about TMNL’s services or complaint handling where a response is not necessarily expected or required.
Complaints Register	a register, established and maintained by the Compliance Function (“CF”), officially submitted complaints
Responsible Managing Director	Astrid van Groeningen, member of TMNL’s Local Statutory Board

Terms that are capitalized, but not defined in this Procedure have the same meaning as in TMG Compliance Charter and Framework.

2. Background, Scope & Purpose

This Procedure outlines and implements a procedure on the handling of the Clients’ Complaint. As a financial service provider Trustmoore Netherlands B.V. (‘’TMNL’’) must have a procedure to handle Complaints in an efficient way.

TMNL is committed to provide quality services to its Clients and to provide for professional and transparent communication and interaction with its stakeholders and employees. TMNL aims to continuously improve the quality of its services and actively listens to the opinion of its clients.

TMNL aims to prevent Complaints as much as possible. However, involved parties must be allowed to submit possible Complaints in an accessible manner, which will then be handled quickly and professionally. With this in mind, and to ensure that Complaints are treated equally, this Complaints Procedure has been established.

3. Standards

a. When acknowledging, resolving, and managing complaints, all employees are expected to be open and transparent.

b. It must be always ensured that Complaints are dealt with as quickly as possible.

c. The Complaints Procedure must be followed unless the Complaint can be resolved immediately by a simple explanation or action.

d. During the whole Procedure, the Client should be handled as if no Complaint has been received.

4. Procedure

4.1 Responsible person

The Responsible Managing Director is responsible for the Complaints Procedure from start to finish. The Responsible Managing Director has sufficient knowledge and experience concerning TMNL’s products and services, the operational processes, and relevant laws and regulations.

4.2. Start of the Procedure

The Procedure begins when a Client submits a Complaint. Clients can submit their complaints in writing to their Account Manager or to the Responsible Managing Director who can be reached by email or by letter:

Email: [email protected]
Letter: Astrid van Groeningen, De Lairessestraat 145, 1075 HJ Amsterdam, The Netherlands

4.3 Steps

Within 24 hours after receiving the Complaint, a confirmation of receipt is sent to the Claimant. This confirmation refers to the Complaints Procedure and it does not address the content of the Complaint itself.
In case the Account Manager receives the Complaint, the Account Manager will share the Complaint with his or her senior and with the Responsible Managing Director (and vice versa).
The person receiving the Complaint will make sure that the Complaint is added into the Complaints Register (Section 5 – Complaints Register).
Both the Account Manager and the Responsible Managing Director will analyze the merits of the Complaint. All relevant information and evidence will be investigated.
After a thorough investigation of the Complaint, possible reactions will be discussed. The Responsible Managing Director is always involved in this discussion.
The solution will be communicated to the Claimant as soon as possible, in any case no longer than five working days. This communication will be in a plain and comprehensible language. In cases where no measures will be taken, this decision should be substantiated extensively to the Claimant.

4.4. Additional measures

In addition to the personal solution, it is also examined whether structural measures should be taken to prevent similar complaints in the future. Next to that, data relating to the complaints handling is analyzed on a permanent basis in order to enable the identification and treatment of any recurring or systemic problem, as well as any potential legal and operational risks.

4.5 Confidentiality

All complaints are treated confidentially. Depending on the nature of the complaint and if the case is suitable for this, a complaint can be discussed in a joint consultation to develop best practices.

5. Complaints Register

The Complaints Register, established and maintained by the CF, is a register of officially submitted complaints. Upon receival of the complaint, the CF needs to be informed of the complaint to be able to register it in the Complaints Register. Resolved complaints are kept in the Complaints Register for a minimum of 10 years.

6. Roles and Responsibilities

The Local Statutory Board - approves this Procedure and oversees its implementation on TMNL level. The CF – establishes and maintains the Complaints Register.
Employees - responsible for complying with this Procedure by following the rules, attending compliance trainings, and awareness sessions.

7. Governance

This Procedure is Level II Procedure that provides a local procedure adopted by and implemented in TMNL, in accordance with the TMG Corporate Governance Policy.