Client Complaint Policy.

1. Introduction.

Cordros is committed to providing excellent customer service to its clients in accordance with global best practices. Our aim is to continuously improve our services by encouraging honest feedback from clients who are satisfied or dissatisfied with our service delivery.

We recognize that complaints from clients are inevitable and they reflect badly on us if not properly handled; hence, we have designed this group client complaint management policy to show our commitment to ensuring that complaints received from our clients are dealt with in a responsive, efficient and effective manner.

2. Purpose.

The policy primarily aims at providing an avenue for effective client communication and feedback, and offering a fair and accessible platform for managing and promptly resolving our clients' complaints and monitoring feedback in order to improve our performance and service delivery.

3. What is a Complaint?

For the purpose of this policy, a complaint is defined as the expression of dissatisfaction by a client in relation to the provision of our services, quality of our product, our processes or the misconduct of a member of staff. It also involves a situation where a client alleges that he/she has suffered or is likely to suffer financial prejudice, material distress or inconvenience as a result of Cordros, which include but are not limited to:

• Contravening or failing to comply with an instruction/mandate given by the client, or the provisions of an agreement entered into with the client;
• Contravening or failing to comply with applicable laws, directives, rules and regulations governing its operations;
• Acting dishonestly, negligently or recklessly; or
• Treating the client unreasonably and unfairly.

4. Principles For Effective Complaint Management.

The following principles govern our complaints management process:

• All complaints received will be treated with the highest level of confidentiality.
• All identifiable information will be protected from disclosure unless the complainant expressly consents to the disclosure of such information.
• All clients are encouraged to voice their concerns at the point of service or as soon as they feel dissatisfied.
• Receipt of each complaint will be acknowledged immediately. Complaints will be handled in an efficient and effective manner. Complainants will be treated courteously and kept informed of the progress of their complaint throughout the complaint handling process.
• All complaints will be attended to promptly and treated in a timely manner.
• All clients will have access to our complaints management policy, which is available on our website as well as an extract of the policy which is included in the Terms and Conditions of our account opening forms.
• We will collect all available information and ensure there is a balanced consideration of all information and evidence before proceeding to resolve a complaint.
• All parties involved in a complaint handling process will be treated equally and fairly.
• Cordros will pay due attention to individual differences and needs to ensure each case is considered on its merits.

5. Categorization of Complaints.

Client's complaints can be categorized into the following:

Negligible/Minor: These complaints pose zero to minimal financial or legal risk to the client or the company and can be promptly resolved at the point of receipt by any member of staff.

Moderate: These complaints also pose minimal financial or legal risk to the client or the company and may require minor assessment of or investigation into the facts of the complaint before it can be resolved.

Major: These are complaints that have high potential financial or legal implications and require further investigation (includes a breach of applicable laws, rules or regulation, negligence, breach of an obligation, conflict of interest, fraud, unauthorized transactions on a client's account etc.).

A complaint may be orally communicated by a client over the phone or during a visit to our office or in writing via e-mail, text messaging, hand written text or any of our social media and messaging platforms.

6. Channels of Complaints.

When lodging a complaint, the Complainant is advised to use the Client Complaint Management form. However, if the Complainant is unable to access the form, the following details must be provided by the Complainant:

• Name
• Full Residential address
• Date
• Mobile number/email address
• Details of complaint
• Supporting Document (if any)

Complaints can be lodged through any of the following channels:

Verbally:

• Speaking to a customer service representative in person or by calling 0700 267 3767.
• Speaking to a Relationship Manager or any employee of Cordros or any individual acting on behalf of Cordros or at any of our offices.

Oral complaints between moderate and major categories must be written by the Complainant or staff who receives it. The Complainant should fill the complaint form or provide the details listed above.

Emails: Complaints can be reported via email through:

• [email protected]
• [email protected]

They may also be sent via our website contact form or any staff email, with both addresses in copy.

Letters: Complaints can be lodged via letters addressed to the concerned business in the Group.

WhatsApp: By sending a message to 02012910538

Social Media: LinkedIn, Instagram, Twitter and Facebook.

7. Employee Duties Under this Policy.

• Employees must educate themselves on this policy and inform clients about it.
• Provide clients with copies or share the website link upon account creation or when requested.
• Deal with complaints in a timely manner.
• Track all complaints consistently.
• Send regular progress reports to clients.
• Assess and categorize complaints upon logging.
• Always observe privacy and confidentiality.
• Treat anonymous complaints on their merits.

8. Complaint Handling Procedure.

Acknowledgment: All complaints will be acknowledged within 24 hours via email, text, or social media. Complaints by post will be acknowledged within 5 working days.

Entry in the Complaints Register:

• Name of client and/or complainant
• Contact details
• Date received
• Nature and description of complaint
• Contact person
• Category

Investigation and Resolution: Complaints will be resolved within 10 business days. If unresolved, they will be referred to a competent authority within 2 working days. A summary and documents will accompany the referral. Complainants may escalate to the SEC if dissatisfied.

Communication: Policy is displayed on Cordros' website. Major complaints are reported to regulators quarterly.

Monitoring: The Compliance Department will review all complaints and ensure procedures were followed.

9. Complaint Management Structure.

Complaint Review Officers (CROs) will manage the process from receipt to resolution. They must be independent, skilled, and have access to all resources.

Frontline Complaints Points: Minor complaints are handled quickly at the point of service. May involve apology or explanation. The decision must be reported to the compliance unit for logging.

Escalation occurs if:

• Client is not satisfied.
• Complaint requires deeper investigation.
• Complaint is serious or unforeseen.

Internal Complaints Point: Handles escalated and major complaints. Full investigation is carried out. Involved employees may be interviewed. CRO may recommend a panel to avoid bias. Final decisions are reported to compliance.

10. Referral of Complaint.

• Unresolved or unsatisfactory complaints are referred to a competent authority within 2 days after the 10-working-day period.
• A summary and relevant documents must be attached.
• Competent authorities must resolve within 20 working days.
• If unsatisfied, complaints can be escalated to the SEC and then to the Investment and Securities Tribunal (IST).

11. Feedback.

• Regular progress reports will be provided.
• Outcomes will be communicated as soon as possible.
• Reasons will be given for negative decisions.
• Clients will be informed about internal or external review options.

12. Complaints Register.

An electronic register will include:

• Complainant’s name
• Date
• Nature and details
• Category
• Comments
• Follow-up actions

It will be updated regularly and reported to the SEC quarterly.

13. Implementations.

All employees are responsible for this policy’s implementation. It will be reviewed annually or as required by changes in regulations or industry standards.

14. Violation.

Cordros will regard any violation of this policy as a serious breach of an employee's obligations towards the Company and its Clients.