Client Complaints Management Policy
Art. 1. The Client Complaints Management Policy (Policy), which “Lenno Global Advisory” (hereinafter referred as „Investment intermediary “, „II “, „Company “or „LGA “JSC) shall apply are part of the Investment Intermediary’s Internal Rules under Art. 68 of Markets in Financial Instruments Act (MFIA) and are prepared on the basis of Art. 26 of Delegated Regulation (EU) 2017/565.
Art. 2. The purpose of the Policy is to establish, implement and maintain effective and transparent policies and procedures for managing complaints and procedures for timely consideration of complaints by clients or potential clients. Filing of complaint, its examination, the measures taken for its resolving and subsequently communicating it to the client is carried out in accordance with the procedure set out in this Policy.
Art. 3. Complaints related to disputes between the parties arising in connection with the provision of investment and ancillary services within the meaning of MFIA could be filed by any client or potential client of „LGA “JSC.
Art. 4. In order to ensure an impartial and competent examination of the complaints, as well as to avoid real and potential conflicts of interest, the complaints are reviewed by the “Internal control” department of the Investment intermediary.
Art. 5. When reviewing a complaint “Lenno Global Advisory” JSC maintains a clear, understandable language relationship with the client or the potential client and responds without undue delay.
Art. 6. The applicants have the right to file complaints free of charge. The information on complaints procedures is provided free of charge.
Filing of complaints. Content of the complaint.
Art. 7. Complaints are filed in writing in one of the following ways:
a) On-site at the office of „Lenno Global Advisory “JSC;
b) By post to the following address: Sofia 1000, 2 Maria Luisa, Tzum, North reception, level 5, office 5;
c) By email to:
Art. 8. The complaint should be in a written form as the evidence in relation the complaint should be attached.
Art. 9. The complaint must contain:
a) Data identifying the complainant (full name, PIN/ID number, type, number and data of identification document, UIC, unique client’s number of the applicant (if he is a client);
b) Data of the identification document of the proxy (if the complainant is represented by a proxy);
c) Address for correspondence and email address;
d) At least two contact phones;
e) An email to which the applicant wishes to receive a response to his complaint;
f) The nature and circumstances of which the applicant is dissatisfied, which he wants to be reviewed or for which he wants to receive an answer.
g) Comprehensive evidence relating to the complaint made;
h) Signature of the complainant (the proxy).
Art. 10. The investment intermediary does not review and does not respond to anonymous complaints. The same can be analysed in order to improve the quality of services.
Art. 11. No complaints filled again on an issue that already has a solution are reviewed, unless there are based on new facts and circumstances.
Procedure for accepting complaints.
Art. 12. The complaints submitted on-site in a Company’s office are accepted by an employee from “Front-office” and/or “Brokerage” departments who is required to issue a registration number and to enter the complaint in the journal of “Complaints“.
Art. 13. Upon submitting the complaint on-site in “LGA” JSC office, if the applicant wishes, he could speak with an employee of the Investment intermediary and discuss the issue. At the applicant’s discretion and if necessary an employee from the “Internal control” department may be present at the meeting.
Art. 14. When the complaint is submitted in written form and is received by post in the office of “Lenno Global Advisory” JSC at: Sofia 1000, 2 Maria Luiza Blvd, TZUM, North Reception, level 5, the complaint is being entered into the registry of incoming correspondence of the II with a registration number from the date of receiving the letter. After which it is passed to an employee from either or both the “Front-office” and “Brokerage” departments for entering in the Journal of “Complaints” and for taking subsequent actions.
Art. 15. When the complaint is submitted by email, it should be send to: , after which it is being entered into the registry of incoming correspondence of the Company with a registration number from the date of receiving the email. After which it is passed to an employee from either or both the “Front-office” and “Brokerage” departments for entering in the Journal of “Complaints” and for taking subsequent actions.
Procedure for registering complaints.
Art. 16. Complaints shall be conducted in order of their entry into the “Complaints” journal.
Art. 17. If in connection to a complaint that has already been filed, follows communication with the applicant in which he continues to have the same or new complaints, then the subsequent letters and correspondence is not entered and reviewed as new complaints received in the journal of complaints, and since they are logically and procedurally related to the initial complaint, they are filled under its unique number as subsequent communication.
Art. 18. The „Complaints“ journal is kept by the “Internal control” department on an electronic carrier. The new circumstances in the journal are entered in a way so that the information from the previous entering won’t be affected and when deleting or correcting information it is done in a way that doesn’t lead to destroying or damaging the information. The correctness of the entries in the journal of complaints is verified by the head of the “Internal control” department.
Art. 19. The journal of „Complaints“ shall include:
a) The date of filling and the unique number of the complaint in the Company;
b) The unique client number of the applicant (if he is a client);
c) The corresponding number of primary documents stored in the archives of the II, as well as any additional information;
d) The name and signature of the person, who made the entry under items from a) to c);
e) The date of reviewing the complaint by the II;
f) The measures taken in relation to the complaint;
g) The name of the person, who made the entry under d) and item e).
Procedure for handling complaints.
Art. 20. The head of the “Internal control” department is reviewing the filled complain, after which he assigns it to an employee of the department to promptly make the necessary investigations or inspections, and/or he does this by himself.
Art. 21. The head or employee of the “Internal control” department conducts in good faith comprehensive internal investigation of the facts and circumstances described in the complaint and the II’s actions concerning the specific case aiming to collect and examine all relevant evidence and information relevant to the claim.
Art. 22. The head or employee from the “Internal control” department upon conducting the internal investigation can request data, documents and explanations from Company employees in relation to the specific case. The employees of the II are obliged to fully cooperate with the “Internal control” department in connection to the ongoing internal investigation. If necessary, at any stage of the reviewing and reviewing the complaint, the matter may be referred to the Board of directors of ”Lenno Global Advisory” JSC.
Art. 23. The Company may require the applicant to provide additional information and/or documentation in relation to the complaint, setting a deadline for the provision.
Art. 24. The head of the “Internal control” department may, at his discretion, hold a meeting or a telephone conversation with the compliant to resolve the case. At his discretion, the II’s employee against which the complaint is filled can attend the meeting.
Art. 25. When reviewing the complaint and conducting the internal investigation the head or employee of the “Internal control” department acknowledge and seek to avoid actual and potential conflicts of interest, and if such conflicts are identified, they should be reduced.
Art. 26. When reviewing the complaint and preparing an answer the head or employees of the “Internal control” department are guided by the regulations in force, contractual relationships in effect, applicable internal rules and deeds of the Investment intermediary.
Art. 27. When the complaint is well founded in part or in whole, the head of the “Internal control” department makes every effort to meet the applicant’s claims and to prevent potential legal or arbitration disputes.
Art. 28. If necessary, at any stage of the researching and reviewing the complaint, the Representatives of the II participate as well.
Art. 29. In a period of 14 (fourteen) business days from the date of receiving the complaint from the “Internal control department” and when it is reviewed by the Company’s Representatives – in a period of 7 (seven) days from their decision, the Department issues a written response to the applicant. The answer should be drafted in plain, intelligible language.
Art. 30. In a need of a long internal investigation or for additional information and/or documents to be provided by the applicant, and/or the complexity of the facts require so, the period for response can be extended to 8 (eight) calendar weeks from the date of receiving the complaint.
Art. 31. The II may extend the period for answering more than once, but the maximum period between receiving the claim and sending an answer cannot extend past 3 (three) months.
Art. 32. If extending the period is necessary, ”Lenno Global Advisory” JSC informs the applicant about the reason for the delay, as well as for the period, in which to expect his claim to be answered. If the period is being extended more than once, for each individual extension there is a separate notification.
Art. 33. If the applicant has received an answer to his complaint, but after that submits a subsequent complaint or comment in relation to the answer and the communication continues this cycle one or more times, the II reviews and answers the subsequent complaints in the order in which reviews and responds to the complaint itself, as the period for answering the subsequent complaints commence from the date the initial complaint is received. The total period for answering is determined on per complaint basis as periods are not cumulative.
Art. 34. The answer of the complaint is send to the email indicated by the applicant.
Art. 35. In the answer to the complaint, Lenno Global Advisory JSC informs the applicant that If he is not satisfied by the answer of the complaint, he has the right to seek protection of his interests by the competent authorities – the Conciliation committees for consumer dispute resolution under the Consumer Protection Act, the Financial Supervision Commission and the competent court in the Republic of Bulgaria.
Art. 36. The “Internal control” department of “Lenno Global Advisory” JSC analyses the data from the complaints and their review in order to ensure that any potential risks and/or issues are identified and addressed. The analyses establish recurring and systematic problems as well as potential legal and operational risks, so that they could be resolved. The analysis includes:
a) Analysis of the causes of individual complaints so that the root causes that are common to different types of complaints are established;
b) Assessment whether these root causes can affect other process and/or products as well, including those in relation to which direct complaints haven’t been filed; and
c) Correction of these causes, when appropriate.
Art. 37. The head of “Internal control” department is entitled to make suggestions to the senior management and/or the Company’s Board of directors if as a result of the analysis a change to the Investment Intermediary’s internal regulations and/or to the existing documents governing the relations with clients is needed, and to take other actions that are compatible with the functions of performing internal control and/or functions resulting therefrom.
Art. 38. „LGA“ JSC keeps all documentation and information relating to complaints of clients and internal inspections relating to client complaints on magnetic (electronic) and/or paper form.
Provision of information
Art. 39. Until the 15 (fifteenth) day of the month from the new quarter, the Investment intermediary informs the Financial Supervision Commission about the number and summary of contents of:
a) The received written complaints, if any during the last quarter as well as the results from reviewing the received complaints;
b) Lawsuits related to the activity of the II, undertaken during the past quarter from or against him, respectively against the members of the management and supervisory bodies and the individuals working under a contract for it, as well as all judgements in the pending cases, if there are any.
Art. 40. With the current Policy for managing client complaints “Lenno Global Advisory” JSC provides clear, precise and up-to-date information to the public for the process of handling claims, which includes details of how to submit complaints and the process of reviewing. The information shall be provided to clients and potential clients as the current Policy is published on the Company’s website – www.lenno.com.
This policy is adopted with a decision of the BD of II “Lenno Global Advisory” JSC from 27.12.2019 and is entered into force on the day of its adoption. The Policy supersedes all previous provisions of the Client Complaints Management Policy of the “Lenno Global Advisory” JSC.