×
disclaimer

Introduction

Astra Asset Management UK Limited (Astra or “the Firm”) conducts its business in line with our clients’ best interests.

Although Astra’s culture is to “get things right the first time”, it is accepted that on occasion a client may feel that the Firm has fallen short of this aspiration.

It is important that every complaint received is considered by the Firm and is responded to in an appropriate manner, not only to comply with any regulatory obligations but also to ensure that the integrity of the Firm is maintained. In addition, an analysis of the cause of the complaint may provide Astra with a learning opportunity to improve the services that we offer to clients.

This policy sets out how Astra deals with both “complaints” and “MiFID complaints”.



Complaint or MiFID Complaint

A complaint can be regarded as any oral or written expression of dissatisfaction, whether justified or not, concerning the provision of a financial service and which alleges that the complainant has suffered (or may suffer) material distress or material inconvenience.

A MiFID complaint basically relates to MiFID business. MiFID sets out how firms such as Astra should deal with such complaints.


MiFID complainant or Eligible complainant

The MiFID complaints handling requirements apply to clients’ or potential clients’ complaints. As such they are applicable to retail clients, professional clients and to eligible counterparties.

An “eligible complainant” is a UK concept and refers to both a “consumer” (see below) and certain other entities such as a micro-enterprise, small charities and a trustee of a small trust.

A consumer is any natural person acting outside of their trade, business or profession. Therefore a consumer, and hence an eligible complainant, can be an individual that is either a retail client or a professional client.

Given the above, a “MiFID complainant” could also be an “eligible complainant”.

The distinction is important as only an eligible complainant is permitted to refer a complaint to the Financial Ombudsman Service (FOS) where eight weeks have elapsed since receipt of the complaint.



Complaints handling, oversight and monitoring

The firm has established, and maintains, complaints management procedures for the prompt handling of clients’ complaints. The policy has been endorsed by the firm’s management body.

The firm is required to establish a “complaints management function” responsible for the investigation of complaints. This role is carried out by the compliance function under the supervision and oversight of Mark Murray, the Chief Compliance Officer.

The firm’s compliance function, even where it is not the appointed “complaints management function”, is specifically charged with responsibility for analysis of complaints and complaints-handling data to ensure that risks and issues are identified and resolved e.g. identification of root causes and the impact upon other processes or products, including those not directly complained of. The compliance monitoring undertaken by the firm addresses this requirement.

For the avoidance of doubt, responsibility for implementation of the complaints management policy and for monitoring compliance with it rests with the firm’s senior management.



Complaints awareness

Details of the firm’s complaints handling process must be published (e.g. in brochures or the firm’s website) and made available to clients or potential clients on request or when acknowledging a complaint (see below). The details will include information about the complaints management policy and the contact details of the complaint management function (see below).

Where there are potential eligible complainants information about FOS, and its website address, must be provided (“in a clear, comprehensible and easily accessible way”) on both the firm’s website and in the general conditions of the contracts with eligible complainants. Such information will include the right of an eligible complainant to approach the FOS when eight weeks have elapsed since receipt of the complaint.



Making a complaint

A complainant should set out their complaint in writing, providing as much detail as possible and either post the complaint to:

Compliance Officer

Astra Asset Management UK Limited

35 King Street

London

EC2V 8EH

UNITED KINGDOM


Or, alternatively, send the complaint by email to: compliance@astra-amco.com



Complaints handling process



Reporting and publication

The “complaints reporting rules” in the FCA Handbook require a twice-yearly report to be provided to the FCA concerning complaints received from eligible complainants. This requirement also applies to MiFID complaints, except that information must be included about such complaints received from retail clients, professional clients and, where relevant, eligible counterparties rather than just eligible complainants.