Complaints Handling Policy

1.           Introduction

Pure North Markets(hereafter “the Company”) is an Investment Dealer (Full ServiceDealer, Excluding Underwriting) which operates as Investment Dealer. The Company is incorporatedin the Republic of Mauritius and is authorized and regulated by the Financial Services Commission (hereafter “FSC”) with License Number GB21026474.Company’s registered address is at C/o Alexander Management Services Limited3 Emerald Park,Trianon, Quatres Bornes,72257 Republic of Mauritius

2.          Scope and Purpose

The Company is required to establish, implementand maintain effectiveand transparent procedures for the reasonable and prompt handlingof complaints or grievances received from complainants and keep records of each complaint as well as any actionstaken by the Company to remedy the situation. This Policy sets out the method for the submission of complaints with the Company from its Clientsand the processes followed by the Company’spersonnel when dealing with such complaints.

3.          Definitions

“Complaint”is defined as a statementor an expression of dissatisfaction addressed to the Company by a client (natural or legal person) regarding the provision of investment and/or ancillary servicesprovided by the Company to the client.

“Complainant” is definedas any person, natural or legal, who has read, agreed with andaccepted all the terms and conditions contained in the Company’s Client Agreement (withoutmodifications), has openeda trading accountwith the Companyand has lodgeda complaint.

The Company considers having a complaint when thecomplainant has submitted a complaint to it to the Company in writing, in a format that makes it clear that the complainanthas a grievance against the Company, via the followingmethods:

(a)                       By email at support@tagmarkets.com; or

(b)                      By contacting the Company via its ContactUs page at the Company’swebsite.

In case the Company receivesa notification throughthe line of communication established by the Company to receive complaints, but which does not fall within the definition of “complaint” above and can be characterized as an enquiry,this shall be categorized as anenquiry rather than as a complaint and will be forwarded to the relevantdepartment to be handled accordingly. The Complainant has the right to requestfor the re-classification ofhis/her enquiry as a complaint.

The current Policy applies toall registered clients & trading accounts opened with the Company.

4.           Complaint Handling Procedure

The Support Department and if necessary, the Compliance Department of the Companyshall efficiently handle any complaint received by a Complainant. In the case that the complaint is against the Compliance Department, the complaint shall be handledby a member of the Senior Management.

4.1         Procedure tobe followed for Verbal Complaints

It is the Company’s Policy not to accept any verbal complaints or grievances. Should any of theCompany’s employees (regardless of department) receivea verbal complaint or grievance, the followingprocedure must be followed:

(i)                         The employeereceiving the verbalcomplaint or grievance shall take all thenecessary actions so that the complaint or grievance is properly addressed. The said employee will inform the Complainant that all the complaints or grievancesmust be made in writing.

(ii)                       If, following the receipt of explanation referred toin point (i) above, the Complainant submits a written complaint to their SalesAgent or Account Manager, then the complaint or grievance, in the form that has been received, must be forwardedby the relevant employee concernedto the Compliance Departmentwithin the same working day.

(iii)                    Subsequently, a member of the CustomerSupport Department will inform the Complainant that their complaint or grievance has been forwarded to the Company’sCompliance Department, providing all details so that the Complainantis aware who is dealingwith their complaint or grievance.

(iv)                     The member of staff, in additionto the above, should make all best efforts to ensurethat in the case of the complaintor grievance being of such nature that canbe resolved immediately, to do so that the clientwill not have to pursuethe filling of a formalcomplaint.

4.2         Procedure to be followed for Written Complaints

4.2.1                 When awritten complaint is received, in themanner described in Paragraph 3, the procedure which shall be followed by the Companyis the following:

(i)                         the complaint, in theform that has been received, must be forwarded, in theform it has been received, to the Compliance Department within the same workingday.

(ii)                       Once theComplainant submits a written complaint, amember ofthe Customer Support Department will send an electronic acknowledgment of receipt to theComplainant’s registered emailaddress within five (5) workingdays following receipt,to verify that the Company has received the written complaint.

(iii)                    A memberof the customer Support Department will investigate the grounds of thecomplaint and if, based on the information provided, the grievance does not fall within the definition of “complaint” or is not considered to be a complaint it will be categorised as an enquiryand will be forwarded to the relevantdepartment to be handled appropriately.

(iv)                     If the grievance falls within the definition of complaint or is considered to be a complaint, then a member of the Support Department will register the complaint to an internalregister by giving it a unique referencenumber which will becommunicated to the Complainant withinfive (5) workingdays.

4.2.2                 In addition, a member of theCustomer Support Department shall inform the Complainant of thefollowing:

(i)                         That theComplainant must use thegiven reference number inall future correspondence with the Companyregarding the submittedcomplaint;

(ii)                       The processwhich is followedwhen handling a complaint;

(iii)                    Who isthe person or thedepartment that is dealing with thecomplaint andtheir contact details;

(iv)                     What isthe indicative handling time (i.e., 15working days);

(v)                        That thecomplaint handling procedure isfree ofcharge.

4.2.3                 The following information should be obtained from theClient andrecorded:

(i)                         The client’s full name and surname;

(ii)                       The client’s trading account number;

(iii)                    The affected transactions (ifapplicable);

(iv)                     The date that theissue arose and adescription ofthe issue;

(v)                        The service provided bythe Company and related to thecomplaint;

(vi)                     The employee responsible forthe provision of those services;

(vii)                  The department where theemployee belongs;

(viii)                The content of thecomplaint;

(ix)                     The capital and thevalue ofthe financial instruments which belong tothe client;

(x)                       The magnitude of thedamage claimed by thecomplainant;

(xi)                     Any correspondence exchanged between the Company and thecomplainant.

4.2.4                 The Companywill thoroughly examineand assess the following:

(i)                         The facts and theinformation provided by thecomplainant;

(ii)                       The facts and theinformation provided by theemployee responsible for the provision of thoseservices (if applicable);

(iii)                    The information/data which have been retrieved from theCompany’s archive (i.e., the

Complainant’s transactions, trading history, correspondence, electronic email, recorded telephone calls,IT data etc.);

(iv)                     The events leading tothe complaint.

4.2.5                 The Companywill not handle or investigate a complaint if the Complainant does not provide the information requestedin paragraph 4.2.3 of this Policy. In such an event the Company shall revert to the Complainant and request him/herto send any additionalinformation. In any event, one of the Company’s officialsmay contact the Complainantdirectly in order to obtain further clarifications and information relating to his/her complaint.The Company shallneed the Complainant’s cooperation in orderto handle the complaint.

4.2.6                 The Companyupon examining the complaint and reaching a decision in this respect shall inform the Complainant about the Company’s decision, in writing and in plain languagewhich is clearlyunderstood, together with the reasoning of the Company’sdecision and any remedial measures it intends to take.

4.2.7                 The Companyshall make everyeffort to resolvethe complaint withinfifteen (15) working days.When deemed necessary, the Customer SupportDepartment or the Compliance Department shall conveythe complaint to the SeniorManagement for further investigation. In this case, the Company might take additional time to finalize the reply. The Senior Management shall investigate furtherand coordinate with relevant heads ofdepartments to attendto the subject of the complaint.

4.2.8                 In the event that the Companycannot provide a response to the Complainant within the handling time given to the complainant, it will keep the Complainant informed about reasons of delay and indicatewhen the investigation is expected to be completed. This period of time cannot exceedtwo months from the submission of the complaint.

4.2.9                 Once the complaint is concluded, the Support Department will keep an electronicrecord of the complaint received, detailing the courseof action which was taken,including what information, data and evidencewere gathered, what measures were taken for thecomplaint’s resolution, whether any conflicts of interest between the Company and its clientsand between other clientswere identified, what was the outcome and how that outcome wasreached.

4.2.10             Moreover, the Support Department will analyze, on an ongoingbasis, complaints handlingdata, in order to identify and address the causes of the individual complaints and/or any recurring or systematic problemsand/or any potential legal and operational risks.

4.2.11             The presentComplaints Handling ProcedurePolicy will be uploaded on the Company’s official website.

5.  Record Keeping of Complaints

The Company shall maintain record of all complaints for a minimumperiod of five years after the closure of the client’s trading account. The responsible department shall be the CustomerSupport Department.

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