This document sets out the Exchange4free Ltd Complaints Procedure. It has been prepared to meet the requirements of the Financial Services Board (FSB) and to demonstrate our aim to treat customers fairly at all times, we believe it meets those requirements .

1. The Nature of a Complaint
These procedures cover any expression of dissatisfaction, whether oral or written, and whether initially justifiable or not, made by or on behalf of a complainant about the provision of, or failure to provide, a financial services activity by our firm. In the course of our investigations we will identify whether or not any complaint made meets the definition set out by the Financial Services Board.

2. Eligible Complainant
In order to be eligible to make a complaint about our firm you have to meet certain criteria. In addition to meeting one of the above criteria you must have been a customer of the firm at the time the complaint arose and the complaint must arise out of matters relevant to your having been a customer of our firm.

One of the first steps we will take when receiving a complaint is to identify whether a complainant is eligible. If we decide that the complainant is not eligible then we will write to that complainant accordingly and state our reason for coming to that decision. We will review any response by that complainant to see whether or not the correct decision has been made.  Upon receiving further information we will write to the complainant again saying whether or not they are now eligible.

3. Availability of our Complaints Procedure 
It is our duty to make sure that you are aware of our complaints procedure. You will be made aware of the basic principles at the point of sale, and then issued with a full procedure document should you actually make a complaint.

In addition to making the procedure knownto you we have posted a copy and made notice on our website indicating that we are covered by the Financial Ombudsman Service.

4. The Procedure
Your complaint will be investigated by our compliance officer who has sufficient competence to deal with the complaint and who preferably has not been involved in the matter which is the subject of the complaint. We will also ensure that the person dealing with the complaint either has the authority to settle your complaint or can have ready access to somebody who can make a decision on your complaint.

5. Time Limits
We will respond to your complaint within 10 days of its receipt and give you the name or job title of the person handling the complaint and let you have a copy of this procedure if you have not already received a copy.

We hope to be able to deal with your complaint within 5 days but if this is not possible then within 4 weeks of receiving the complaint we should have been able to resolve the matter or, if this is not possible, we will explain the position fully including the reasons why not and undertake to contact you again within 8 weeks of the receipt of the complaint.

By the end of that 8 week period we very much hope that your complaint will have been resolved. If it has not been resolved by then we will let you know about the Financial Ombudsman Service and you can refer your complaint to that service should you feel you wish to do so.

6. Final Response
When we give you our final response we will try and explain to you all the reasons why we have come to our conclusion. If we feel that redress is appropriate we will show how we have calculated this and we will have based it upon what we believe is fair and appropriate to your complaint.

You will have a window of 6 months from receipt of our decision in which to refer the case to the Financial Ombudsman after which it will be concluded that you are satisfied with our investigation and findings.

7. Third Party Representation
We are happy to deal with nominated third party representations throughout the whole of this procedure subject to your (The complainants) letter of authorisation.

Director of Compliance