Client Support Complaint Procedure

How to Process Client Complaints

1.    Background

 This Policy is based on:

  • The IOSCO Principles for Financial Benchmarks FR07/13, in particular Principle 16 “Complaints Procedures”

2.    Objective and purpose

The objective of this Policy is to institute an internal process which ensures that:

  • Clients can submit complaints and concerns in relation to Axioma products.
  • Complaints and concerns submitted by clients are handled promptly, efficiently and transparently.
  • Qontigo can assess whether the complaint is a result of procedural deficiency, carelessness or fraud and any financial or reputational consequences of a complaint; and
  • Structured documentation of the complaint is prepared and filed.

3.    Scope

This Policy applies to all Axioma products.

Complaints, according to this Policy, refers to any written correspondence received from a client in which the client complains about any Axioma product.  Complainants must be seeking remedy in respect of a financial loss or a measurable impairment of the complainant’s business.  Statements of dissatisfaction related to IT malfunctions (e.g. issues related to system availability or access) are considered as complaints, if the malfunctions represent a breach of contractual agreements and the complainant seeks a remedy of a financial loss or measurable impairment as a result of the IT malfunction.

For Qontigo to consider the correspondence as a complaint under this Policy, the complainant must fully substantiate their claim with evidence and sufficient detail to enable a comprehensive investigation by Qontigo. Where there is insufficient detail to pursue the investigation, the complainant will be notified as such.

4.    Dealing with Client Complaints

4.1 Submission of Complaints

Complaints can be submitted to Qontigo by means of the following channels:

- by postal mail/email to:

STOXX Limited

Regulatory Officer

STOXX Limited

Theilerstrasse 1A

6300 Zug

Switzerland

regulations@stoxx.com

or

Axioma Client Support at Support@axioma.com

In all cases, the complaint must include at a minimum the following information:

  • The full name and contact address of the complainant and if applicable the company name and the contact address;
  • A detailed description of the incident that lead to the complaint and of the implications of the incident on the complainant (including all relevant background information);
  • The Axioma product to which the complaint refers; and
  • The date of the complaint.

A complainant may use the form provided in Annex 1 to submit a complaint.

A copy of all incoming complaints as defined above will be forwarded to Qontigo’s Regulatory Officer together with the form “Complaint Report” (Annex 1). The Regulatory Officer can decide about an escalation to the competent governance body.

Complainants will receive a confirmation upon receipt of the complaint by Qontigo within five (5) business days and will be advised about the date by which they can expect to receive Qontigo’s answer to the complaint.