Complaints
Handling

1.2The Policy is issued in satisfaction of the Company's obligation under the Client Agreement to designate a complaints channel, to acknowledge, investigate and issue a reasoned response, and to state any escalation or regulatory route available to the Client.

1.3This Policy does not create, extend or limit any contractual right. Where this Policy and the Client Agreement address the same matter, the Client Agreement prevails in accordance with the order of precedence stated in it.

1.4Nothing in this Policy shortens a mandatory limitation period, excludes access to the relevant regulator, a competent court or another mandatory external mechanism, or removes a protection conferred on the Client by Applicable Law that cannot lawfully be excluded.

1.5Terms defined in the Client Agreement have the same meaning in this Policy.

1.6The Company treats complaints as a source of information about the quality of its Services. A complaint is investigated on its merits, and the fact that a Client has complained does not affect the way the Company deals with that Client.

2.2Each entity is separately licensed and separately supervised. The external escalation route available to a Client depends on the contracting entity and is set out in the entity variation table above and in section 16.

2.3Where a Client holds Accounts with more than one entity, a complaint should identify the Account and the entity concerned. The Company will confirm which entity is handling the complaint in its acknowledgement.

2.4Where a complaint concerns a third party rather than the Company, including a payment provider, an introducing broker or a technology provider, the Company will say so in its response and will assist the Client in directing the complaint appropriately, so far as it reasonably can.

3.2A complaint may be made whether or not the Client has suffered a financial loss, and whether or not the Client identifies it as a complaint.

3.3Matters commonly raised as complaints include execution, pricing and slippage; Margin, close-out and stop-out; deposits, withdrawals and payment processing; fees, financing and charges; account access and platform availability; the conduct of a Relevant Person or an introducer; the accuracy of a statement or confirmation; and the handling of personal data.

3.4The following are not complaints and are handled through other channels: a general question about the Services; a request for information, a document or a copy of a record; a routine instruction relating to an Account; and an objection to a specific entry on a statement or confirmation, which is dealt with under section 15.

3.5Where the Company receives a communication that is unclear, it will treat it as a complaint if a reasonable reading indicates dissatisfaction requiring a response, rather than requiring the Client to label it correctly.

4.2Where a complaint is made by a representative, the Company may require evidence of authority before it discloses Account information or issues a substantive response. The complaint is registered and investigated in the meantime.

4.3The complainant must have a direct interest in the subject matter of the complaint. The Company does not accept a complaint made on behalf of a Client by a person with no authority and no interest.

4.4A complaint should be submitted from, or verifiable against, the contact details recorded for the Account. Where it is not, the Company will take reasonable steps to verify the complainant's identity before disclosing Account information.

4.5A prospective Client whose application was declined or is being processed may complain about the handling of that application.

5.2Where the Company publishes a dedicated complaints address or facility for the contracting entity, that channel takes precedence and will be identified on the Website and in the Client Portal.

5.3A complaint may be made in English. Where a Client submits a complaint in another language, the Company will make reasonable efforts to accept and respond to it, but the English text governs in the event of conflict.

5.4A complaint made verbally to a member of staff, including on a recorded telephone line, will be recorded and registered. The Company may ask the Client to confirm the complaint in writing so that its scope is clear, but it will not refuse to register a complaint because the Client has not done so.

5.5The Client should not use trading or withdrawal instruction channels to submit a complaint, as those channels are monitored for operational instructions rather than for complaints handling.

6.2Supporting material such as screenshots, statements, confirmations or payment records assists the investigation and should be provided where available.

6.3The Company will not reject a complaint solely because it is incomplete. Where material information is missing, the Company will register the complaint and ask the Client for what is needed.

6.4Where the Company has requested information that is necessary to investigate and the Client does not provide it within a reasonable period, the Company may issue its response on the basis of the information available and will say so.

6.5The Client should preserve relevant device, platform, payment and communication records while a complaint is under investigation.

7.2The Client bears the cost of any professional adviser the Client chooses to instruct.

8.2The Company will not refuse to consider a complaint solely because it was made after a period of delay. Delay may, however, affect the evidence available and therefore the outcome.

8.3Nothing in this section shortens a limitation period applicable under Applicable Law, or affects the Client's right to pursue a matter through an external route within the period allowed by that route.

8.4Where the complaint concerns an entry on a statement or confirmation, the objection period in the Client Agreement applies in addition to this Policy, as described in section 15.

9.2The acknowledgement confirms the complaint reference, the entity handling the complaint, a summary of the Company's understanding of the matter, the name or function of the person handling it, and any further information required from the Client.

9.3Where the Company can resolve a complaint to the Client's satisfaction within the acknowledgement period, it may do so by a single written response that records the outcome, without a separate acknowledgement.

9.4The Client should quote the complaint reference in subsequent correspondence about the same matter.

10.2The investigation may include reviewing platform, server, pricing and transaction records; reviewing recorded telephone, chat and email communications; obtaining information from counterparties, liquidity providers, payment providers or technology providers; and interviewing Relevant Persons.

10.3Where the complaint concerns execution, the Company assesses the Transaction against its Order Execution Policy, the prevailing market conditions and the records of the relevant execution arrangement.

10.4Where the complaint concerns a conflict of interest, it is assessed under the Conflicts of Interest Policy in addition to this Policy.

10.5The Company may refer a complaint and its proposed response to its legal advisers or to an external expert where the matter warrants it.

10.6The Company may, at any point, propose a resolution to the Client before completing its investigation. A proposal made on that basis is not an admission of liability.

11.2Where complete independence is not practicable because of the size of the relevant function, the complaint is reviewed and approved by a person of appropriate seniority who was not involved in the matter.

11.3The compliance function has access to complaints records and to the investigation, and may require a complaint to be reopened or reconsidered.

11.4A Client will not suffer any detriment in the Company's dealings with them as a result of having made a complaint.

12.2Where the Company is unable to issue a final response within that period, it will send the Client a holding response before the period expires. The holding response will explain why more time is required and give the date by which the Client can expect a final response.

12.3Where more time is required, the Company will issue its final response no later than sixty Business Days after receiving the complaint, unless a longer period is permitted or required by Applicable Law or by an authority, in which case the Company will keep the Client informed.

12.4A period may be extended where the Company depends on information from a third party, where the Client has been asked for necessary information and has not yet provided it, or where an authority, court or external body is considering the same matter.

12.5The final response sets out the Company's findings, the reasons for them, the evidence relied on so far as it can be disclosed, whether the complaint is upheld in whole or in part, any remedy offered, and the escalation routes available under section 16.

12.6Where a complaint is upheld, any remedy offered is implemented promptly once the Client accepts it.

13.2Where a complaint is upheld, the remedy is designed to place the Client, so far as reasonably practicable, in the position the Client would have occupied had the matter not arisen. Remedies may include correcting an entry, reversing or re-executing a Transaction, refunding or waiving a charge, adjusting an Account balance, correcting a record, and changing a process so that the matter does not recur.

13.3The Company does not offer a remedy conditional on the Client withdrawing a complaint, waiving a right that cannot lawfully be waived, or agreeing not to approach a regulator.

13.4Where a complaint is not upheld, the final response explains the basis for that conclusion and identifies the records relied on.

13.5Acceptance of a remedy is a matter for the Client. Declining a remedy does not prevent the Client from escalating under section 16.

14.2Making a complaint does not suspend the Company's rights, including its rights on an Event of Default and its close-out rights, except where the Company confirms otherwise in writing or where Applicable Law requires it.

14.3Where a complaint concerns a disputed amount, the Company may withhold that amount pending the outcome, and will say so. Undisputed amounts continue to be dealt with normally.

14.4Neither party is prevented by an ongoing complaint from seeking urgent injunctive, protective or limitation-preserving relief.

15.2An objection of that kind should identify the disputed Transaction or entry, the alleged error and the supporting facts.

15.3If an objection is not resolved to the Client's satisfaction, it may then be raised as a complaint under this Policy.

15.4Failure to object within the period stated in the Client Agreement may be evidence that the record was accepted, but it does not validate fraud, wilful misconduct, a Manifest Error or a liability that cannot lawfully be excluded, and it does not prevent a complaint being made.

16.2The Client may first ask the Company to review the matter internally. A review is conducted by a person who was not responsible for the original response, and the Company will confirm the outcome in writing.

16.3A Client of Royce Capitals Ltd. may refer the matter to the Labuan Financial Services Authority. A Client of Royce Global Markets Limited may refer the matter to the Financial Services Commission, Mauritius. Current contact details for each authority are published on the Website and are provided on request.

16.4The Client may also pursue the matter through a competent court, in accordance with the governing law and jurisdiction provisions of the Client Agreement, or through any other mandatory external mechanism available under Applicable Law.

16.5The Company does not require a Client to exhaust its internal procedure before approaching a regulator, and does not treat an approach to a regulator as a breach of the Agreement.

16.6Use of an external route does not by itself prevent the Company from continuing to seek a resolution with the Client.

17.2Complaints records are retained for the period required by Applicable Law and by the Company's records-retention arrangements, and are made available to the relevant regulator on request.

17.3The Company analyses complaints for recurring causes and for patterns across products, Services, functions, providers and introducers.

17.4Where a root cause is identified, the Company records it, assigns responsibility for remediation, and considers whether other Clients affected by the same cause should be identified and remedied without waiting for them to complain.

17.5Management information on complaint volumes, categories, outcomes, timescales and root causes is reported to the Company's governing body on a regular basis and at least annually.

17.6The effectiveness of this Policy is reviewed at least annually and whenever a material change occurs in the Company's business or regulatory obligations.

18.2Information about a complaint is disclosed internally only to those who need it in order to investigate or approve the outcome, and externally only to regulators, authorities, professional advisers, insurers, auditors and providers where lawful and necessary.

18.3The Company may withhold from its response information whose disclosure would breach confidentiality owed to another client or third party, would compromise the security of its systems or controls, or would breach Applicable Law, and will say that it has done so.

18.4Recordings, records and correspondence relating to a complaint remain the Company's records, subject to any access right the Client has under applicable data-protection law.

19.2The current version of this Policy is made available through an Approved Medium. The Company maintains version control and records the effective date of each version.

19.3The governing language of this Policy is English. A translation is provided for convenience only and, in the event of conflict, the English version prevails to the extent permitted by Applicable Law.