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Complaints Policy

v.102020

Introduction

As an authorised firm, Alpha FX Europe Limited takes complaints very seriously and ensures that they are investigated thoroughly and resolved fairly in line with the rules and regulations issued by the Malta Financial Services Authority (‘MFSA’).

Nature of the Complaint
We follow the MFSA definition of a complaint, namely “A statement of dissatisfaction addressed to a Regulated Person by a Client relating to the provision of an investment service/product provided under MiFID or related to an insurance contract (as applicable)”

2. Receiving Complaints

We allow complaints to be made by any reasonable means and to be made free of charge. This may include by letter, email, telephone or in person. If we receive a verbal complaint, the employee receiving the complaint should make a note of the substance of the complaint as soon as possible. Complaints will be promptly referred to our Compliance Officer. In the event that the Compliance Officer is involved in the subject matter of the complaint, it will be referred to another member of senior management who is not involved.

3. Acknowledging Complaints

We will promptly acknowledge a complaint in writing.

4. Investigating Complaints

4.1 Investigating the Specific Complaint
We will investigate the complaint competently, diligently and impartially. We will promptly assess the specific circumstances surrounding a complaint by reviewing all appropriate records and speaking to the individuals involved, with a view to deciding whether the complaint should be upheld and whether any remedial action and/or redress may be appropriate. The criteria that may be considered when determining whether a complaint should be upheld include:

  • whether we have breached a rule set out by the MFSA;
  • whether we have acted unreasonably;
  • whether there has been an administrative or trading error;
  • whether we have received similar complaints from other complainants, perhaps indicating a systems or processes failure on our part; and
  • any relevant MFSA guidance.


4.2 Complaint Analysis
We will identify and remedy any recurring or systemic problems and therefore minimise the risk of compliance failures, for example, by:

  • analysing the causes of individual complaints so as to identify root causes common to types of complaint;
  • considering whether such root causes may also affect other processes or products, including those not directly complained of; and
  • correcting, where reasonable to do so, such root causes.

Where we identify recurring or systemic problems, we will consider whether other customers may have suffered detriment from, or been potentially disadvantaged by, such problems but who have not complained. If so, we will take appropriate and proportionate measures to ensure that those customers are also given appropriate redress or a proper opportunity to obtain it.

We will provide management information on the causes of complaints and the products and services complaints relate to, including information about complaints that are resolved by the firm by close of business on the business day following receipt. Senior Management will also be informed of recurring or systemic problems.

5. Resolving complaints

The MFSA requires complaints to be handled and resolved promptly. Specifically, within fifteen business days of receiving a complaint we will ensure that we revert with a final response which either:

  1. (a) accepts the complaint and, where appropriate, offers redress or remedial action; or
    (b) offers redress or remedial action without accepting the complaint; or
    (c) rejects the complaint and gives reasons for doing so;

and which:

when providing a final decision that does not fully satisfy the complainant’s demand, Alpha shall provide a thorough explanation of the Company’s position on the complaint and that if the complainant is not satisfied with the way the complaint was resolved by the Company, Alpha will inform the complainant that the complaint may be referred to the Office of the Arbiter for Financial Services. Such decision shall be provided in writing.

Should it be the case that the complaint needs to be investigated further beyond the fifteen-day period, we will inform the complainant about the causes of the delay and provide an indication as to when the investigation will be completed.

6. Closing Complaints

We may regard a complaint as closed in the following circumstances:

  • once we have sent a final response to the complainant; or
  • where the complainant has indicated in writing their acceptance of an earlier response that we have sent to them.


6.1 Contact Details

The contact details for the Office of the Arbiter for Financial Services are:

Office of the Arbiter for Financial Services
1st Floor
St Calcedonius Square
Floriana, FRN 1530
Malta

The contact details to where you should direct your complaint are:

In writing:
Alpha FX Europe Limited
171, Old Bakery Street
Valletta VLT 1455
Malta
(Registration No. C96623)

By e mail:
grahamsciberras@alphafx.co.uk

By telephone:
+44 (0)203 854 9265