Linchpin IFM Limited (“Linchpin”) has implemented a Complaints Handing Policy to ensure that it is able to handle customer complaints quickly, easily and in a transparent manner. Complaints must also be handled fairly and provide consistent outcomes for all customers, as required under the Financial Conduct Authority’s (“FCA’s”) Principle of Treating Customer Fairly. For the purpose of complaints, Linchpin considers that an Investor may make a complaint as well as a Client.
Linchpin Advisory Limited, which is a fully owned subsidiary of Linchpin, is not registered with the FCA but has chosen to adopt the same policies when handling complaints. Complainants to Linchpin Advisory will by definition not be eligible complainants under the FCA’s rules and so the procedure described under (i) below will be followed.
COMPLAINTS HANDLING PROCEDURE
The following complaints procedure should be followed if a complaint is received:
- If a formal complaint is received it should be referred to William Bourne immediately.
- Where the complaint has been made verbally the investor or client should be asked to put the complaint in writing (e-mail is acceptable). However, it should be noted that failure to do so by the client does not remove Linchpin’s obligation to investigate the complaint and treat the customer fairly.
- Complaints should be resolved as soon as possible. Linchpin has three business days (after having received the complaint) in which to resolve the complaint. Linchpin will not be required to send the complainant a final response letter if the complaint has been resolved within this timeframe.
- However, Linchpin is required to send the complainant a summary resolution communication which will contain details of how they can direct their complaint as appropriate to the Compliance Officer of the relevant Client should they be dissatisfied with the resolution provided by Linchpin.
- The complaint will be considered closed when the client has accepted the summary resolution by the client or if no response has been received within 10 days, following the provision of the summary resolution.
- Where it has not been possible to resolve a complaint within three business days, William Bourne will take responsibility for ensuring its resolution or, if appropriate, escalating it to the relevant Client.
- Where a complaint cannot be resolved within three business days, Linchpin has an obligation to promptly acknowledge the complaint and provide the complainant with a copy (or summary) of its complaint handling procedures.
- Linchpin then has an ongoing obligation to keep the complainant informed of the progress of their complaint.
- Linchpin must, by the end of eight weeks after its receipt of a complaint, send the complainant:
- A final response; or
- A written response, which:
- Explains why it is not in a position to make a final response and indicates when it expects to issue one;
- Informs the complainant that she/he may refer the matter to the FOS; and
- Encloses a copy of the FOS explanatory leaflet.
- A complaint is closed where Linchpin has sent a final response or the complainant has indicated in writing its acceptance of Linchpin’s earlier response.
- In addition, the client may, in some circumstances, have the right to make a claim for compensation under the Financial Services Compensation Scheme (“FSCS”) in respect of an inability of Linchpin to satisfy a claim made against it by the client.