Introduction
Ebury Partners Markets Cyprus Limited (hereinafter the 'Company', the 'Firm', 'EPMCY', 'We' or 'Us' ) is a Cyprus Investment Firm licensed and regulated by the Cyprus Securities and Exchange Commission ('CySEC') under license number 459/25. The Company is a limited liability company incorporated under the laws of the Republic of Cyprus with incorporation number HE 439971, located at DOMS Assets Business Centre, 33 Neas Engomis Street, 2409 Engomi, Nicosia, Cyprus.
EPMCY maintains effective and transparent procedures for the reasonable and prompt handling of complaints received from the Complainants and keeps records of each complaint as well as the actions that were taken to remedy any situation.
We appreciate things can go wrong some time and as such we ask that our clients (hereinafter the 'Client' or 'you') get in touch with us prior to submitting a complaint as issues may be able to be resolved prior to reaching this level. If you have a complaint about any aspect of our service, then we would like to hear from you. You can contact us by email at complaints@ebury.com. Our complaints department will be best placed to receive your complaint and work with you to resolve it.
Definition of a Complaint
A complaint is a statement of dissatisfaction addressed to the Company by a natural person or a legal entity relating to the provision of any investment service and/or provision ancillary services provided by the Company.
A complainant is any natural person or legal entity who is an active or potential client of the Company and is presumed eligible to launch a complaint and who has already launched a complaint.
Complaints Procedure
Complaint Reception
A complaint can be either a written or oral statement and it can be received by any of the Company employees who manage directly the communications with the client. Complaints may also arrive directly to the complaints inbox at complaints@ebury.com.
The Company has established an internal complaints procedure to ensure your complaint is dealt with efficiently and by the correct person. To help us investigate and resolve the problem as quickly as possible, please make sure you give us the following information:
(i) Your full name and surname,
(ii) Your Client Reference number (if you have an account open),
(iii) Your contact details such as email address and contact number
(iv) Any affected transaction number(s)
(v) The date and time of the event(s)
(vi) An accurate description of the issue.
Timeframe
We will try to resolve your complaint immediately and with minimum inconvenience to you. The first step is for us to be really clear on what the problem is and to identify with you what we can do to put it right. The more information you can give us, the better.
Sometimes we will not be able to solve the problem for you immediately. If we are unable to resolve your complaint by the following day and if we have not already contacted you to agree with our proposal for resolving it, we will send an acknowledgement of your complaint in writing within five (5) business days confirming receipt of the complaint and the estimated time under which the client shall be given a reply.
We will create a unique reference number to you for the specific complaint in accordance with Circular C338. You should use said reference number in all future contact with the Company (and the Company shall do the same), the Financial Ombudsman and/or the CySEC regarding the specific complaint.
The unique reference number will consist of ten (10) digits with the following breakdown:
○ the first two digits are the code of the CIF regarding the Transaction Reporting System - TRS
○ the following four digits define the year, and
○ the last four digits denote the number of each complaint serial number (e.g. for 2018 - AA20180001, AA20180002, for 2019 - AA20190001, AA20190002).
The Compliance Department shall register the complaint directly to the Company's internal register, as soon as possible and in an appropriate manner;
Within four (4) weeks of receipt, the Company shall send the client a Final Response or a holding response, which will explain why it is not yet in a position to resolve the complaint and give an indication of when further contact shall be made. In such case an answer shall be given within eight (8) weeks of receipt;
Within eight (8) weeks of receipt of the complaint, the Company shall send to the client either a final response or a response which explains why a final response cannot be given with an explanation as to why and an indication of when the Company anticipates on providing a final response;
Upon sending the final response, the client shall be given a period of eight (8) weeks to respond. If a response is not received within eight (8) weeks, then the Company shall not be obliged to take the complaint further unless further correspondence is received from the client indicating that he/she is still dissatisfied.
Please note that the Company shall consider a complaint as closed when a period of three (3) months has elapsed from the date of submission of the complaint and the client has failed to respond to the Company's investigating officer's requests and due to this the investigation cannot be carried forward.
Clients or potential clients can submit complaints to the Company free of charge. When handling a complaint, communication with clients or potential clients shall be clear, in plain language that is easy to understand.
It is understood that Clients' right to take legal action remains unaffected by the existence or use of any complaints procedures referred to above.
Firm Response
In our final response we will include:
● A summary of your complaint;
● A summary of the outcome of our investigation;
● Whether we acknowledge there has been any fault on our side and whether the complaint will be upheld;
● Details of any offer to settle the complaint and how long this offer will remain open; and
● If you are an eligible client, a notification of your right to refer the matter to the Financial Ombudsman Service.
Financial Ombudsman Service
If you are not satisfied with the Company's final decision, you have the right to address your complaint(s) to the Financial Ombudsman of Cyprus, provided that each complaint does not exceed the amount of one hundred and seventy thousand euro (€ 170,000), within 4 months after the Company provides its final response.
Website: https://www.financialombudsman.gov.cy
Email: complaints@financialombudsman.gov.cy
Postal Address: P.O. Box 26722, 1647 Nicosia, Cyprus
Telephone: +357 22 84 8900
Fax: +357 22 66 0584, +357 22 66 0118
If the client does not accept a decision taken by the Financial Ombudsman, he/she may take civil action by taking his/her case to court. Further information can be found on http://www.financialombudsman.gov.cy.
Cyprus Securities and Exchange Commission
Alternatively, Clients may refer their complaint to CySEC's Department of Market Surveillance and Investigations, which however, does not have restitution powers and therefore does not investigate individual complaints.
Website: https://www.cysec.gov.cy
General email: info@cysec.gov.cy
Postal Address: P.O. BOX 24996, 1306 Nicosia, Cyprus
Telephone: +357 22 50 6600
Recordkeeping
EPM CY will continuously hold and update records of all complaints received by clients with details of the investigation conducted, including the final outcome and any mitigating measures taken for the resolutions, as well as everything that has been communicated from and with the client.
The Company, as required by its regulatory obligations, shall report to CySEC information regarding client complaints and how these have been handled as this is required by Circular C338 and Article 26 of Regulation 2017/565.
The Company shall also ensure that as per the requirements set by Circular C338, that it sends the regulator (in the appropriate form) of all the complaints received for the previous calendar month.
Review of this Procedure
This policy shall be regularly reviewed and updated by the Compliance Function in line with applicable legislation updates and when considered necessary and each updated version shall be approved by the Company's Board of Directors.
The Company will inform its Clients of any material changes to this procedure by posting the updated version of the policy on its Website.
