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Complaints Policy

Introduction

Shares Financial Assets ("SFA", "we", "us"), as an authorised Investment Firm, is subject to the applicable regulations relating to the handling of complaints from its clients or potential clients and therefore put in place all the necessary measures to handle these complaints.  

Regulatory references :

Definition of a complaint

A complaint is defined as an expression of dissatisfaction with the professional to whom it is made.

Complaints may be made by any person, even if there is no contractual relationship with the professional: customers (private individuals or professionals), former customers, beneficiaries, persons who have requested a product or service from the professional or who have been solicited by a professional, including their agents and beneficiaries.

It should be noted that the following will therefore not be considered as complaints :

  • a request for a service;
  • a request for information;
  • a request for clarification ; and
  • a request for advice.

The recognised nature of the dissatisfaction expressed or the absence thereof, as well as the intentional nature of the alleged misconduct or the absence thereof, are not decisive criteria in classifying a complaint. If in doubt, the analyst in charge of receiving complaints may refer the matter to his or her supervisor and/or the Compliance Department.

Receipt of a complaint

Any complaint against SFA is free of charge and can be made:

If a complaint is received via our instant messaging service, the agent in charge of the conversation will invite the user to submit the complaint by e-mail in order to ensure that it is properly preserved on a durable medium. The team responsible for receiving complaints will ensure that they are centralised and traceable.

Complaint handling

Within 24 hours - during working days - of receiving the complaint, SFA will acknowledge receipt of the complaint to the user in a clear and understandable language.

The complaint will then be investigated impartially, with skill and care, which involves:

  • Analysing the complaint to understand its nature;
  • Gathering the necessary information from the user and/or other departments in order to identify the malfunction in question;
  • Identify possible remedies;
  • Inform the user of the progress of the resolution; and
  • Provide the user with an answer and/or  solution.

The complaint handling team has the appropriate qualifications, including a good knowledge of SFA's products, services, contracts, tools and procedures.

Response time

SFA undertakes to respect the following deadlines:

  • Acknowledgement of receipt sent within 24 hours of receipt of the complaint.
  • Final response within 15 working days from receipt of the complaint.

In the event that SFA is unable to meet these deadlines, whether or not for reasons beyond its control, the user will be duly informed in advance and provided with an explanation for the delay, where possible.

In all cases, SFA will not exceed the maximum authorised time limits of :

  • 10 days to acknowledge receipt of the complaint.
  • 2 months to provide a resolution.

Mediation

If you are not satisfied with SFA's response to your complaint, you may refer the matter free of charge to the Autorité des Marchés Financiers Ombudsman (AMF):

Please note that the AMF Ombudsman (i) will probably not deal with your request if it has not yet received a final response from us and (ii) does not have jurisdiction in tax, insurance (life insurance policies, PERP, etc.) or banking matters (savings accounts, term deposits, PEL savings plans, loans, overdrafts, overindebtedness).

Record-keeping and retention period

In accordance with our obligations, each complaint, together with any corrective measures taken, is kept in a confidential register for at least 5 years from the date of receipt.

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