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Complaints Policy

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Introduction
Manhattan VC Holding LLC (“Manhattan VC Holding”) is committed to providing a quality service and working in an open and accountable way that builds trust and respect. One of the ways in which we can continue to improve our service is by listening and responding to the views of our clients and stakeholders, and in particular by responding positively to complaints, and by putting mistakes right.
Therefore we aim to ensure that:
  • making a complaint is as easy as possible
  • we welcome compliments, feedback and suggestions
  • we treat a complaint as a clear expression of dissatisfaction with our service which calls for an immediate response
  • we deal with it promptly, politely and, when appropriate, confidentially
  • we respond in the right way - for example, with an explanation, or an apology where we have got things wrong, or information on any action taken etc.
  • we learn from complaints, use them to improve our service, and review annually our complaints policy and procedures We recognise that many concerns will be raised informally, and dealt with quickly. Our aims are to:
  • resolve informal concerns quickly
  • keep matters low-key
  • enable mediation between the complainant and the individual to whom the complaint has been referred This policy ensures that we provide guidelines for dealing with complaints from members of the public about our services, facilities and staff
Definitions
A complaint is defined as any expression of dissatisfaction, however, it is expressed. This would include complaints expressed face to face, via a phone call, in writing, via email or any other method. All staff should have sufficient knowledge to be able to identify an “expression of dissatisfaction” even when the word “complain” or “complaint” is not used.
A complaint covered by this Policy can be distinguished from:
  • staff grievances
  • responses to requests for feedback about the standard of our service provision
  • reports of problems or wrongdoing merely intended to bring a problem to our notice with no expectation of a response
  • service requests
  • requests for information
Scope
This policy applies to all staff receiving or managing complaints from our clients, their related parties and any member of the public made to or about us, regarding our products, services, staff and complaint handling.
Complaints
The formal complaints procedure is intended to ensure that all complaints are handled fairly, consistently and wherever possible, resolved to the complainant's satisfaction.
Responsibilities
Manisland’s responsibility will be to:
  • acknowledge the formal complaint in writing;
  • Explain the complaints process;
  • respond within a stated period of time;
  • Inform the complainant of the progress of the complaint and reasons for any delay
  • Inform the complainant of the possible or likely outcome of their complaint.
Confidentiality:
Except in exceptional circumstances, every attempt will be made to ensure that both the complainant and Manhattan VC Holding maintain confidentiality. However the circumstances giving rise to the complaint may be such that it may not be possible to maintain confidentiality (with each complaint judged on its own facts). Should this be the case, the situation will be explained to the complainant.
Record keeping:
Details and documents relating to customer complaints will be retained for a period of 5 years from the date the complaint has been resolved
Complaints Procedure:
Written records must be made by Vauban at each stage of the procedure
  • Stage 1
    • In the first instance, staff member(s) must establish the seriousness of the complaint. An informal approach is appropriate when it can be achieved. If concerns cannot be satisfactorily resolved informally, then the formal complaints procedure should be followed.
  • Stage 2
    • If the complaint cannot be resolved informally, the complainant should be advised that a formal complaint may be made and the following procedure should be explained to them. It may sometimes be appropriate for a different member of staff, preferably a member of the compliance team, to make this explanation.
      • A formal complaint can be made either verbally or in writing. If in writing the attached form should be used. If verbally, a statement should be taken by the team member or management team.
      • Upon receiving the complaint, the complainant will be contacted within 24 hours, confirming the complaint is being considered and advising when a response can be expected.
      • In all cases, the complaint must be passed on to the Team Lead. In the event of a complaint about the Team Lead the complaint should be passed to the The COO, and if the complaint is about the COO this must be passed on to the CEO
      • One of the above will investigate the complaint. Any conclusions reached should be discussed with the staff member involved and their Line Manager.
      • Complaints must be resolved by the end of 15 business days following receipt of the complaint. However in exceptional circumstances, where Manhattan VC Holding is unable to issue a final response within the 15 days of receipt, Manhattan VC Holding will issue a holding response including:
      • The reasons for the delays in resolving the complaint
      • A deadline in which Manhattan VC Holding will aim to issue the final response. This must be no later than 35 business days from the date of receipt.
  • Stage 3
    • If the complainant is not satisfied with the above decision, then a sub-group of the Board will be convened.
    • The sub-group will examine the complaint and may wish to carry out further interviews, examine files / notes. They will respond within four weeks in writing
    • When a final response has been given it will either:
    • Accept the complaint, and where appropriate, offer redress or remedial action;
    • Offer redress or remedial action without accepting the complaint; or
    • Reject the complaint and give reasons for doing so.
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