Complaints Policy

Fair and transparent handling of complaints in accordance with the principles of good corporate governance and applicable law

1. Policy Statement

We understand that sometimes things go wrong. Every complaint is handled in a prompt, fair and clear way. Your view of how the Group deals with you matters. The Group may not always be able to give you the outcome you want, but it will always explain its decision. Every complaint is read by a director.

The NeoBankers Group Limited (the "Company") is committed to handling all complaints fairly, promptly, and transparently. The Company treats every complaint as an opportunity to improve its operations and to uphold the trust placed in it by partners, counterparties, and stakeholders.

2. Scope

This policy applies to complaints received from any person in connection with the Company or any member of the Group, including prospective and existing partners, contractual counterparties, service users, professional advisers, regulators, and members of the public. The policy extends to complaints received orally, in writing, or through electronic channels.

3. Definition of a Complaint

A complaint is any expression of dissatisfaction, whether oral or written, and whether or not justified, relating to the provision of, or failure to provide, a service, product, communication, or information by the Company or any member of the Group, where the complainant alleges that they have suffered, or may suffer, financial loss, material inconvenience, or material distress.

4. How to Submit a Complaint

The complaints route is for complaints only; other matters should be raised through the relevant enquiry channel. You will not be charged for the handling of your complaint.

Complaints may be submitted in writing to:

Email: the Regulatory and compliance form
Post: Complaints Officer, The NeoBankers Group Limited, 167-169 Great Portland Street, 5th Floor, London W1W 5PF, United Kingdom.

All complaints should include: (a) the complainant's full name and contact details; (b) a clear and detailed description of the matter giving rise to the complaint; (c) the date or dates on which the relevant events occurred; (d) copies of any relevant correspondence, contracts, or other documentation; and (e) the outcome sought by the complainant.

What to include in your complaint:

• who you are and how to reach you;
• your relationship to the Group (partner, supplier, candidate, journalist or other);
• the name of anyone at the Group you have dealt with;
• what happened, and the outcome you want;
• copies of any supporting documents.

The Company is not subject to the FCA’s complaint-handling rules (DISP). It follows their principles and timescales as good practice.

5. Acknowledgement

The Company will acknowledge receipt of a complaint in writing within five business days of receipt. The acknowledgement will identify the person responsible for handling the complaint and provide the complainant with a copy of this policy.

The first reply names the person responsible for the complaint and either answers it or gives a timetable for the full response.

6. Investigation and Response

Each complaint will be investigated thoroughly, impartially, and with due regard to the rights and interests of all parties. The investigation will be conducted by a person of appropriate seniority who was not directly involved in the matter giving rise to the complaint. A substantive written response setting out the Company's findings and proposed resolution will be provided within eight weeks of receipt. It will set out a summary of events, what was investigated, the Company’s decision and the reasons for it, and any further steps open to the complainant. Where the complaint cannot be resolved within eight weeks, the Company will write to the complainant before the end of that period, explaining the reasons for the delay and the progress made, and giving a new date for its response.

What happens after you complain:

1. The Company acknowledges your complaint.
2. It asks for more information, if needed.
3. It investigates.
4. It sends you a written response.

7. Escalation

If the complainant is not satisfied with the Company's response, the matter may be referred in writing to the Board of Directors for further review. The Board will consider the matter at its next scheduled meeting or, in the case of an urgent complaint, within 15 business days of receipt. The Board's determination will be communicated to the complainant in writing.

8. External Remedies

Nothing in this policy limits the complainant's right to seek independent legal advice, to refer the matter to any applicable ombudsman, regulator, or dispute resolution body, or to pursue any available legal remedy. As the Company is not authorised or regulated by the Financial Conduct Authority, the Financial Ombudsman Service does not have jurisdiction over the Company's activities at the date of this policy.

A complaint about the handling of personal data may be raised with the Information Commissioner’s Office (ico.org.uk), which generally expects it within three months of the last meaningful contact with the Company.

9. Record-Keeping

The Company maintains a confidential register of all complaints received, including the date of receipt, identity of the complainant, nature of the complaint, actions taken during the investigation, and the final outcome. This register is reviewed by the Board on a periodic basis and is retained for a minimum of six years from the date of resolution.

10. Confidentiality

All complaints will be treated in confidence. Information relating to a complaint will be disclosed only to those persons within the Company who are directly involved in its investigation and resolution, and to external parties where required by law or regulation.

11. Review

This policy is reviewed and, where necessary, updated on an annual basis by the Board. The next scheduled review is April 2027.

12. Governing Law

This policy is governed by the laws of England and Wales.