Complaints Policy
Introduction
According to the Joint Committee Report on guidelines for complaints-handling for the securities (ESMA) and banking (EBA) sectors (‘’the guidelines”, pursuant to article 16 of the ESA Regulations, Alternative Investment Fund Managers must put in place a complaints management policy.
EOS Global Investors AIFM “the Company” will fully comply with the guidelines, to ensure the fair treatment of its stakeholders (internal and external).
Definitions
Complaint: A statement of dissatisfaction addressed to a firm by a natural or legal person relating to the provision of (i) an investment service provided under MiFID, the UCITS Directive or the AIFMD; or (ii) a banking service listed in Annex I to the CRD; or (iii) a service of collective portfolio management under the UCITS Directive.
Complainant: A natural or legal person who is presumed to be eligible to have a complaint considered by a firm and who has already lodged a complaint.
ESG: Environmental, Social, Governance
Scope
This policy and procedure are designed to ensure that stakeholders’ complaints are managed through an effective and consistent process that meets the requirements of the guidelines.
Complaints of internal or external stakeholders will be managed in relation to the violation of policies and procedures of the Company and relevant legislation including ESG issues (i.e. non-compliance with the Code of Conduct, policies, labor relations, discrimination, corruption, money laundering, ESG policy, anything that could damage the Company's reputation or any attempt to cover up the above).
Procedure for lodging complaints
Complaints may be submitted by post directly to the premises of the Company or by email to info@eosglobalinvestors.com.
The following information should be included on behalf of the complainant:
- Full Name, Surname
- Name of Organization or Authority (if any)
- Address
- Phone number or Email Address
- Description of the complaint in detail (type of violation)
- Evidence to support the complaint (files, photos, etc.)
The complainant will be notified once the complaint has been received. The Company may request any further information and will keep the complainant informed throughout the process.
Management of Complaints
- Complaints received will be treated in a fair, direct, effective, and confidential manner by the relevant department of the Company.
- Complaints received by the Regulatory Authorities will be handled within 10 days and complaints from the stakeholders within 45 days from receipt, in accordance with Bank of Greece Governor’s Act 2501/2002.
- An escalation process will be in place for complaints that cannot be resolved at the initial stage. This process will define who should be contacted and at what point.
- Complaints that are not within the authority of the department will be redirected to a third party. Where a referral to a third party has not already been obtained, the Company must, due to the complainants’ right to information privacy, consult with the complainant.
- Complainants who are disadvantaged, have a disability, education, language barriers or require additional assistance lodging a complaint should be directed to call +30 216 2005500.
- All complaints will be recorded and documented, including the information required for each complaint.
- The effectiveness of the complaints management process will be regularly monitored and reviewed, with assessments of complaint trends, outcomes, and necessary adjustments to the process.
- A non-retaliation policy will be maintained to assure complainants that they will not face adverse consequences for lodging a complaint in good faith.
- The EU general data protection regulation (GDPR) is fully respected.