Axis Financial Consultants: Internal Code / Handling of Complaints-Procedures and Organisation
Complaints Procedure
If you wish to make a complaint about our services, please contact our company by calling +33 1 39 70 98 54 or by emailing phil.loughton@axis-finance.com, stating that you wish to lodge a complaint. It would be very helpful if you could provide details about the nature of the issue.
Alternatively, you can write to our offices at:
Axis Financial Consultants
374 Avenue de la Gaule
78955 Carrieres sous Poissy
France
This will initiate our complaints procedure, which is detailed below for your information.
If Axis Financial Consultants receives a complaint from an `eligible complainant`, then the Firm will comply with the following procedure:
1All complaints, i.e. expressions of dissatisfaction, should be recorded in the issues log. The log should identify whether the complainant has suffered a financial loss, material distress, or material inconvenience, and whether the business the customer is complaining about is a regulated or unregulated investment, pension, or insurance contract business.
Wherever possible, staff should ensure that complaints are resolved on the day they are made or the next business day.
Where it has not been possible to resolve the complaint within 24 hours of receiving it, and the complainant has suffered financial loss, material distress or material inconvenience, then the following procedures should be followed:
- The Compliance Officer should be informed by e-mail and given as much information as possible.
 - All incoming documentation (if any), whether hand-written or by email, relating to a complaint should be forwarded to the compliance officer.
 - The Compliance Officer will record the complaint in the `Complaints Log` and issue the complaint with a unique `Complaint reference number`.
 - The Compliance Officer will record in the Complaints Log whether or not the complaint relates to the ORIAS-regulated business.
 - If staff members doubt whether the complaint should be forwarded to the Compliance Officer, they should contact the Compliance Officer to discuss the matter.
 
The Compliance Officer will decide whether to investigate the complaint personally or appoint a suitably qualified senior person who is not involved in the subject matter of the complaint. This person will have the seniority to investigate the complaint effectively and have the authority to resolve the matter. All relevant documentation, including facts and client records, will be available to the person investigating the complaint. 
The person investigating the complaint will first assess whether the complaint falls under the requirements outlined in the l’ORIAS procedural guide. If the complaint falls into one of the following categories, then the Firm is not subject to the requirements for complaints handling procedures set out in the above:
- The complaint is not made by an eligible complainant, either directly or indirectly, or
 - The activity complained of does not relate to an activity which falls within the jurisdiction of l’ORIAS or
 - The complaint does not involve any allegation that the complainant has suffered or is likely to suffer financial loss, material distress or inconvenience.
 
If the Firm receives a complaint that does not fall into one of the categories above, it will investigate and report back to the complainant.
If the Firm cannot resolve the complaint within one business day following receipt, it will send a written acknowledgement of receipt within ten business days.
The written acknowledgement will:
- Confirm receipt of the complaint;
 - Identify the person who is to investigate the complaint; and
 - Supply a copy of the Firm’s Complaints Handling Procedure.
 
Within eight weeks of receiving the complaint, the firm will send the complainant either:
- A Final Response, together with a copy of l’ORIAS regulations, setting out how the firm has resolved the complaint and a reminder that the complainant may refer the matter to l’ORIAS within six months of receiving the Final Response, or
 - A Holding Response indicating that the matter is still under investigation and that the Firm will contact the complainant in due course.
 
Where the Firm does not resolve the matter within four weeks following receipt of the complaint, then within eight weeks after receipt of the complaint, it will send the complainant either:
- A Final Response, together with a copy of the l’ORIAS regulations, setting out how the Firm has resolved the complaint and a reminder that the complainant may refer the matter to l’ORIAS within six months of receiving the Final Response.
 - A response stating that the Firm is still unable to resolve the matter, together with an indication of when it will be able to resolve the complaint.
 
Where a complaint is not referred to the Compliance Officer, the staff member will handle it unless the Compliance Officer or the staff member’s manager indicates otherwise. When handling a complaint, staff should record all the steps taken to resolve it within the issues log.
When the Firm offers compensation for a complaint received, it will ensure the compensation offer is fair.
Where compensation is to be offered, the Firm will provide the complainant with a reasonable opportunity to consider it for at least seven business days from the date of the offer.
The Firm will make and retain records of complaints for a minimum period of three years from the date of its receipt of a complaint.
