Complaints Handling and Dispute Resolution Policy

1. Purpose

1.1. The purpose of this Complaints Handling and Dispute Resolution Policy (the “Policy”) is to establish a fair, transparent, effective and consistent framework for the receipt, investigation, management and resolution of complaints received by Luramic Ltd (the “Company”).

1.2. The Company is committed to handling complaints promptly, objectively and without undue delay, whilst ensuring fair treatment of complainants and compliance with applicable laws, regulations and regulatory expectations.

1.3. This Policy further aims to ensure that complaints are appropriately recorded, monitored, analysed and reported, thereby assisting the Company in identifying operational weaknesses, enhancing internal controls and improving the quality of its services.

2. Scope

2.1. This Policy applies to:

1. all complaints received from clients, prospective clients, counterparties, business partners and other stakeholders;
2. all products, services and activities provided by the Company;
3. all directors, officers, employees, contractors and representatives of the Company involved in the receipt, handling, investigation or resolution of complaints.

2.2. This Policy applies irrespective of whether the complaint is received in writing, electronically or through any other communication channel approved by the Company.

3. Regulatory Framework

3.1. This Policy has been developed in accordance with applicable laws, regulations and regulatory guidance governing the activities of the Company, including any requirements issued by the Financial Services Commission (“FSC”) and any other applicable legal or regulatory obligations.

3.2. Nothing in this Policy shall limit the rights of a complainant to seek legal remedies or to refer a matter to any competent regulatory authority, court, tribunal, mediator or arbitrator.

4. Definitions

4.1. “Complaint” means any expression of dissatisfaction, whether oral or written, relating to the provision of services, execution of transactions, operational activities, conduct of employees, contractual arrangements, fees, charges, delays, systems, communications or any other matter connected to the Company’s business activities, where a response or remedial action is expected.

4.2. The following shall generally not constitute a Complaint:

1. requests for information or clarification;
2. requests for account assistance or operational support;
3. routine service enquiries;
4. general feedback or suggestions; or
5. trade instructions or order requests.

4.3. Where uncertainty exists as to whether a communication constitutes a Complaint, the Company shall treat the matter as a Complaint until assessed otherwise.

4.4. “Complainant” means any natural person, legal entity, partnership, trust, association or other organisation that submits a Complaint to the Company. Where a Complaint is submitted through an authorised representative, the Company may request evidence of the representative’s authority to act on behalf of the Complainant.

4.5. “Dispute” means a Complaint that remains unresolved following completion of the Company’s internal complaint handling procedures or where the Complainant remains dissatisfied with the Company’s final response.

4.6. “Business Day” means any day on which banks are open for business in Mauritius, excluding Saturdays, Sundays and public holidays.

5. Complaint Handling Principles

The Company is committed to maintaining an effective complaint handling framework that promotes fair client outcomes, protects the integrity of its operations and supports compliance with applicable legal and regulatory requirements. All complaints shall be managed in accordance with the following principles:

1. Fair Treatment and Objectivity: Complaints shall be assessed fairly, objectively and on their individual merits, taking into account all relevant facts, circumstances and applicable legal and regulatory requirements.
2. Independence and Avoidance of Conflicts: Complaints shall be reviewed by suitably qualified personnel. Individuals directly involved in the matter giving rise to the Complaint, or who have an actual or potential conflict of interest, shall not participate in the investigation or determination of its outcome.
3. Transparency and Effective Communication: The Company shall maintain clear and accessible procedures for the submission, investigation and resolution of Complaints and shall keep Complainants appropriately informed throughout the process.
4. Confidentiality and Data Protection: All Complaints and related information shall be handled confidentially and processed in accordance with applicable data protection, privacy and confidentiality requirements.
5. Timely Resolution: Complaints shall be acknowledged, investigated and resolved promptly and without undue delay, taking into account their nature and complexity.
6. Record Keeping: The Company shall maintain complete and accurate records of Complaints, investigations, decisions and any corrective actions taken.
7. Continuous Improvement: The Company shall periodically review Complaints and complaint trends to identify recurring issues, strengthen internal controls and improve its services and operational processes.
8. Oversight: The Company's complaints handling arrangements shall be subject to appropriate management oversight to ensure compliance with applicable legal, regulatory and internal requirements.

6. Governance and Responsibilities

6.1. The Company maintains appropriate governance arrangements to ensure that Complaints are handled fairly, independently, consistently and in accordance with applicable legal and regulatory requirements.

6.2. The Compliance Officer is responsible for overseeing the Company’s complaints handling framework, maintaining the Complaints Register, coordinating investigations and monitoring compliance with this Policy. The Compliance Officer shall ensure that Complaints are assessed objectively, handled within the applicable timeframes and appropriately escalated where necessary. The Compliance Officer shall also monitor complaint trends and identify any recurring issues, operational weaknesses or control deficiencies requiring corrective action.

6.3. All directors, officers, employees and representatives of the Company are required to promptly escalate any Complaint received to the Compliance Officer and to cooperate fully with any investigation. Personnel involved in the subject matter of a Complaint shall provide all relevant information requested but shall not participate in determining the outcome of the Complaint where doing so could impair objectivity or create a conflict of interest.

6.4. The Senior Management are responsible for ensuring the effectiveness of the Company’s complaints handling arrangements and for overseeing the resolution of material, complex or high-risk Complaints. They shall ensure that appropriate remedial measures are implemented where deficiencies, control weaknesses or conduct concerns are identified.

6.5. The Board of Directors retains overall oversight of the Company’s complaints management framework and shall periodically review complaint trends, significant Complaints and any material corrective actions implemented by management. The Board shall ensure that the Company’s complaints handling arrangements remain effective, proportionate and aligned with applicable regulatory expectations.

6.6. The Company shall ensure that all Complaints are assessed and investigated in an independent and impartial manner. Any individual who is directly involved in the matter giving rise to a Complaint, or who otherwise has an actual or potential conflict of interest, shall not be responsible for determining its outcome.

7. Submission of Complaints

7.1. A Complainant may submit a Complaint to the Company by email at support@luramic.com. To facilitate the prompt investigation and resolution of a Complaint, the Complainant should provide sufficient information regarding the nature of the Complaint, the relevant facts and circumstances, any supporting documentation and the outcome sought.

7.2. The Company encourages Complaints to be submitted as soon as reasonably practicable following the event or circumstances giving rise to the Complaint.

7.3. Where a Complaint is submitted by an authorised representative acting on behalf of a Complainant, the Company may request satisfactory evidence of the representative’s authority to act.

7.4. The Company may request additional information or documentation where reasonably necessary to assess, investigate or resolve a Complaint.

8. Complaint Handling Process

8.1. Upon receipt of a Complaint, the Company shall acknowledge, assess, investigate and resolve the matter in a fair, objective and timely manner.

8.2. The Company shall conduct an appropriate review of the facts and circumstances relevant to the Complaint, including any records, communications, transactions or information considered necessary for the investigation.

8.3. Where appropriate, the Company may seek clarification or additional information from the Complainant or relevant internal personnel to facilitate the investigation.

8.4. The Company shall communicate the outcome of the Complaint to the Complainant in writing, including the Company’s findings and any remedial actions or corrective measures considered appropriate.

8.5. Where a Complaint cannot be resolved within the expected timeframe, the Company shall inform the Complainant of the reasons for the delay and provide updates, where appropriate, regarding the status of the investigation.

8.6. The Company aims to acknowledge Complaints within five (5) Business Days of receipt and, where reasonably applicable, provide a final response within thirty (30) Business Days, subject to the nature and complexity of the matter.

9. Complaints Register

9.1. The Company shall maintain a Complaints Register containing sufficient information to enable the effective monitoring, management and resolution of Complaints.

9.2. The Complaints Register shall record, at a minimum, the date of receipt, reference number, complainant details, nature of the Complaint, status of the investigation, actions taken, outcome and date of resolution.

9.3. The Compliance Officer shall be responsible for maintaining the Complaints Register and ensuring that all Complaints are appropriately recorded, monitored and updated throughout their lifecycle.

10. Root Cause Analysis and Corrective Actions

10.1. The Company shall periodically review Complaints and complaint trends to identify recurring issues, operational weaknesses, control deficiencies, conduct risks or other systemic concerns.

10.2. Where deficiencies or areas for improvement are identified, the Company shall implement appropriate corrective and preventive measures to mitigate the risk of recurrence and enhance the effectiveness of its governance, systems and controls.

10.3. The Compliance Officer shall monitor the implementation of corrective actions and, where appropriate, report material findings and recommendations to senior management and the Board.