Complaints and Disputes

1. Purpose of the Policy

This policy sets out the procedures through which investors (“Members”) of Finesser (hereinafter referred to as the “Owner”), can submit complaints and/or appeals regarding the services provided. It is established in compliance with Article 7 of Regulation (EU) 2020/1503.

2. Customer Service Department

All complaints and appeals covered by this policy will be handled by Finesser’s Customer Service Department. The appointed Head of Customer Service must be a person of commercial and professional integrity, with sufficient expertise to evaluate and resolve disputes fairly.

3. Submitting a Complaint or Appeal

Members can initiate a complaint or appeal by submitting a request via email.

The complaint must be:

• Submitted in English.
• Clear and structured, outlining the facts, concerns, and desired resolution.
• Accompanied by any supporting documents.

Complaints and appeals are free of charge for all Members.

4. Timeframe for Filing Complaints

Complaints must be submitted within six (6) months from the date the Member becomes aware of the issue. Complaints submitted after this period will be deemed inadmissible.

5. Complaint Processing and Acknowledgment

Upon receiving a complaint, Finesser will send a written confirmation within 7 days, stating the submission date and expected resolution timeframe.

If additional information is required, the Member will be notified and given the opportunity to provide necessary documents. The time taken to submit these documents does not count towards the one-month resolution period.

6. Grounds for Inadmissibility

A complaint may be declared inadmissible if:

• It lacks essential information, and the Member fails to provide missing details.
• It pertains to matters outside the scope of Finesser’s services.
• A judicial, arbitral, or administrative process is already in progress regarding the same issue.
• The complaint repeats a previously resolved issue.
• The six-month submission deadline has passed.
• The matter is time-barred under applicable laws.

If a complaint is deemed inadmissible, the Member will be informed and given ten (10) calendar days to submit observations before a final decision is made.

7. Acceptance and Liquidation

If Finesser resolves the issue in favor of the Member before the complaint process is completed, the complaint will be considered settled and closed.

Members may withdraw their complaint or appeal at any time, which will result in immediate closure of the case.

8. Complaint Resolution Process

Once a complaint is admitted, Finesser’s Customer Service will review and resolve the matter within one (1) month from the date of receipt.

The resolution will be communicated to the Member in writing via email, unless the Member requests a paper response.

9. Escalation of Unresolved Complaints

If a Member is not satisfied with the resolution provided by Finesser, they may escalate the matter to the relevant financial or consumer protection authority in their jurisdiction.

10. Record Keeping and Compliance

Finesser maintains a complete record of all complaints and resolutions for regulatory compliance. These records will be made available to competent authorities upon request.