COMPLAINTS HANDLING PROCEDURE
1 Introduction and definitions
All complaints, including a complaint related to how personal data has been processed, handled and any appeal against any decision made in this respect, are subject to this procedure so as to be handled in an efficient and transparent manner in accordance with applicable legal requirements.
The terms client, compliant and complainant shall be understood as follows.
“Clients”, as well as former or prospective clients and entities who have been noteholders, or in other ways been processed by “Quantrom P2P Lending DAC” or “Quantrom Ltd”, are to be considered as clients for this procedure.
A “compliant” is defined as an oral or written statement of dissatisfaction, whether justified or not, from, or on behalf of a person (the “Complainant”) alleging that the Complainant has suffered (or may suffer) financial loss, material distress or material inconvenience relating to “Quantrom P2P Lending DAC” or “Quantrom Ltd.” provision of, or failure to provide, its service or products, and where “Quantrom P2P Lending DAC” or “Quantrom Ltd.” has failed to remedy such loss, distress or inconvenient within a reasonable time.
Every client of Quantrom P2P Lending DAC (hereinafter “the Company”) is entitled to submit a complaint or claim. Any and all such complaints shall be investigated by the Company and Quantrom Ltd (hereafter “the investment manager”) in a joint effort to remedy the situation.
Examples of complaints that clients may be that they believe that the Company has failed to adhere to contractual arrangements, or if it acts in conflict with the legal provisions. Client complaints may also be related to content of provided information or towards actions and behaviour by Company partners or employees. As a result, any complaint shall be treated with utmost care to avoid any litigation or other legal recourse against the business operations of the company and investment manager.
2 The requisites of a Complaint
Every complainant must include following information within his/her complaint:
a) Client’s name and surname
b) Client’s contract agreement
d) Phone number
This minimum information is required from the complainant in order to investigate the complaint properly. As such, the partner or employee receiving the complaint shall advise the complainant that it is important to obtain such information, including a description of the subject of the complaint as well as all other relevant information, including any requirements from the complainant to settle the complaint (if appliable). Supporting documentation may be appended to the complaint.
3 Method of submitting a Complaint and its form
Clients can submit a complaint directly in one of the following methods.
- Via email to the following e-mail address: firstname.lastname@example.org
- Or in writing to: Quantrom Limited, 59-60 O'Connell Street, Limerick, Ireland, V94 E95T
It may also be the case that a client submits his/her complaint to a partner or employee directly, in which case the partner or employee shall forward the complaint to the above-mentioned e-mail address for logging and record-keeping of the complaint received.
4 Complaint confirmation
The company will confirm receiving the complaint to the complainant in writing (by e-mail or letter) within 5 business days that the complaint has been received. The name, contact details and person in charge of handling the complaint as well as the estimated timeline, which shall not exceed one month from the receipt of the complaint, shall be included in the written response to the complainant.
5 Time limits for settling the complaint
Complaints shall be handled as soon as possible, however, the maximum time limit for handling the complaint is one month from receiving the complaint. This time limit is subject to having received complete information to be able to settle the complaint with the complainant.
The person in charge of handling the complaint is entitled to ask the complainant to provide additional information, if he/she finds that the complaint has submitted incomplete information to handle the complaint appropriately. Subsequently, the complainant may modify the complaint or supplement it within 10 working days after delivery of the request to provide additional information about the complaint. However, the person in charge of handling the complaint shall inform the complainant in writing that due to missing information, the complaint might not be handled within on month of receipt and provide a new deadline to the complainant within the same correspondence in which additional information is requested.
Should for any reason, the complaint not be able to be handled within the one-month timeframe, the company and investment manager shall inform the complainant of the reason why such delay will occur and inform the complainant at the latest 35 business days after having received the complaint and indicate a new deadline for handling the complaint.
The company and investment manager shall always apply best effort to ensure a smooth as possible collaboration with the complainant to ensure appropriate information is provided and exchanged to support in remedying the complaint.
In any case, the person in charge of handling the complaint shall at all times keep the following e-mail address, i.e. email@example.com, in copy to ensure an audit log on the complaint is kept by the company.
6 Possibility of appeal to the Board
If the complainant is not satisfied with the settlement of the complaint within the agreed timeline, the complainant may contact the members of the company’s Board of Directors directly via the Company Secretary or Transfer Agent of the company.
7. Out-of-court complaint resolutions
Should a complaint result in a litigation against the company or investment manager, the company’s Board of Directors shall be kept informed about the ongoing litigation case.
The person in charge of handling the complaint/litigation shall, based on the instructions received from the company’s Board of Directors, aim to settle the litigation out-of-court within 12 months of having received the complaint in order to avoid lengthy legal proceeding.