Havelock London

Modern Value Investing

Complaints policy summary

A summary of Havelock London’s complaints handling process is detailed below. This must be made available on request and may be posted to the company’s website.

Making a complaint

A complaint or issue of dissatisfaction should be submitted to Havelock London, free of charge, in the following ways:

On receipt of your communication we will determine if it constitutes a complaint and what kind of complaint it is. There are different requirements for different types of complaint, and these are set out below.

Complaints about a fund

If your complaint relates to a fund, we may be required to forward your complaint to the fund’s management company. We will tell you if we do this and will give you the management company’s contact details.

MiFID complaints

If your complaint relates to our investment management services (or other MiFID business), it shall be treated as ‘a MiFID complaint’.  We will provide written acknowledgement of your complaint promptly and will keep you informed of our progress in reviewing your complaint.

We will ensure that we investigate your complaint competently and diligently. We will review the complaint impartially and will ensure that we seek additional information where necessary. Our assessment of the complaint will be made promptly, fairly and consistently. We will review the subject matter of the complaint and assess whether the complaint should be upheld. We will assess the remedial action or redress that is appropriate if the complaint is upheld and will also assess whether another respondent party who is solely or jointly responsible for the issue raised within the complaint. Where the offer of remedial action or redress is accepted, we will ensure that we comply with the terms of this.

Eligible complainants

If you are eligible to refer your complaint to the Financial Ombudsman Service (FOS), then you shall be treated as an ‘Eligible Complainant’. We will endeavour to provide you with a resolution within three business days. We will provide you with a written summary resolution which will contain details as to how you can escalate your complaint to the Financial Ombudsman Service (“FOS”), should you be satisfied with our resolution.

Within our written resolution we will provide details as to any findings we have made as a result of our investigation into your complaint and whether any remedial action we have taken. We will ask you to confirm if you are satisfied with our conclusion.

If you are not satisfied with our conclusion then we will not close your complaint and will continue to seek resolution. You may raise your complaint to the FOS if you feel dissatisfied with our resolution. If you wish to raise your complaint to the FOS, there are set time limits within which you must do this. We will provide these time limits in our final response. We reserve the right to waive this time limit and will notify you if we do this.

If we feel your complaint requires further review and we cannot respond to you with a resolution within three business days, we will inform you of this. We will provide you with details of who is responsible for handling your complaint and providing you with updates.

We will provide you with a written Final Response Letter within eight weeks of the date of your original complaint. Within this letter we will provide details as to any findings we have made as a result of our investigation into your complaint and whether any remedial action will be taken by ourselves. We will ask you to confirm if you are satisfied with our conclusion.

Financial Ombudsman Service (FOS)

If you are an Eligible Complainant, you may refer your complaint to The Financial Ombudsman Service online at https://www.financial-ombudsman.org.uk/; by phone on 0800 023 4567; or by post at Exchange Tower, Harbour Exchange, London, E14 9SR. Further information on your rights is available on the service’s website.