INVESTMENT SERVICES

Offered by Fiduserve Asset Management Ltd

The investment offering of Fiduserve derives from the business of Centaur Financial Services (a Mifid regulated investment advisor and portfolio management firm with 20 years track record), whose senior management team have joined Fiduserve Asset Management Ltd, our AIFM authorised entity. This enables us to create and oversee a range of macroeconomic investment strategies for our Discretionary Portfolio Management Offering, and to complement these with a comprehensive Fund Management offering which builds on the investment strategies applied successfully by Centaur in the past 20, market turbulent years.

Our Funds offering also includes the establishment and licensing of Private Funds for clients (Family offices, HNIs, Private equity Funds and Investment Groups), after the assessment and selection of the most suitable Fund jurisdiction depending on the type and location of the assets, type of investor and marketing rules. Such Private Funds can be fully or partially managed by Fiduserve, with the desired level of involvement of the client’s team of investment professionals. The offering extends to comprehensive Risk Management functions and regulatory compliance and reporting.

Leveraging our network of corporate clients, we offer transaction advisory and M&A support. This includes strategic analysis and recommendations in respect of investment opportunities in various asset classes, and on how to structure a transaction. We undertake mandates to source and present investment opportunities which fall within clients’ investment strategies and return parameters. We also undertake sell-side mandates following a full investment process.

Fiduserve Asset Management Ltd is a fully owned subsidiary of Fiduserve Management Ltd.

Our investment services offering includes:

– Discretionary Portfolio Management
– Fund Establishment, Licensing and Management Services
– Risk Management services
– Corporate valuations services
– Transaction advisory and M&A support services

Fiduserve Asset Management Ltd has been authorized by CYSEC as an Alternative Investment Fund Management Company with authorization no AIFM 20/56/2013

Before investing with Fiduserve Asset Management Ltd (hereinafter ‘Fiduserve’) the Customer should understand and accept that:

Fiduserve does not and cannot guarantee the initial capital of the Customer’s Portfolio or its value at any time. In particular, the Customer accepts that he could lose some or all of the value of the Customer’s Portfolio if markets for the investments he has allowed move in an adverse fashion.

Past performance of the Customer’s Portfolio or the portfolios of investments of other customers is not a guide to or guarantee of the likely future performance of the Customer’s Portfolio.

No level of performance on the Customer’s Portfolio is, or can be, guaranteed by Fiduserve.

In exercising discretion in relation to the Customer’s Portfolio Fiduserve does not represent or warrant that it will achieve any particular level of return or appreciation for the Customer or avoid depreciations whether to any specified level or at all. In particular, no measure of relative performance (or benchmarking) applies to the Customer’s Portfolio and that Fiduserve does not seek to achieve returns equivalent to any indices, market or investment or that the investment performance of Fiduserve in relation to the Customer’s Portfolio will be similar to that of other customers.

Derivatives Risk Warning Notice

This notice does not disclose all of the risks and other significant aspects of derivatives products such as futures, options, and contracts for differences. You should not deal in derivatives unless you understand the nature of the contract you are entering into and the extent of your exposure to risk.You should also be satisfied that the contract is suitable for you in the light of your circumstances and financial position. Certain strategies, such as a “spread” position or a “straddle”, may be as risky as a simple “long” or “short” position.

Whilst derivative instruments can be utilised for the management of investment risk, some investments are unsuitable for many investors. Different instruments involve different levels of exposure to risk, and in deciding whether to trade in such instruments you should be aware of the following points.

1. Futures

Transactions in futures involve the obligation to make, or to take, delivery of the underlying asset of the contract at a future date, or in some cases to settle your position with cash. They carry a high degree of risk. The “gearing” or “leverage” often obtainable in futures trading means that a small deposit or down payment can lead to large losses as well as gains. It also means that a relatively small market movement can lead to a proportionately much larger movement in the value of your investment, and this can work against you as well as for you. Futures transactions have a contingent liability, and you should be aware of the implications of this, in particular the margining requirements, which are set out in paragraph (6) below.

2. Options

There are many different types of options with different characteristics subject to different conditions:-

Buying options:

Buying options involves less risk than writing options because, if the price of the underlying asset moves against you, you can simply allow the option to lapse. The maximum loss is limited to the premium you paid to buy the option, plus any commission or other transaction charges. However, if you buy a call option on a futures contract and you later exercise the option, you will acquire the future. This will expose you to the risks described under “futures” and “contingent liability transactions”.

Writing options:

If you write an option, the risk involved is considerably greater than buying options. You may be liable for margin to maintain your position and a loss may be sustained well in excess of any premium received. By writing an option, you accept a legal obligation to purchase or sell the underlying asset if the option is exercised against you, however far the market price has moved away from the exercise price. If you already own the underlying asset which you have contracted to sell (known as “covered call options”) the risk is reduced. In any other circumstance (such as writing “uncovered call options” or writing put options) the risk can be unlimited. Only experienced persons should contemplate writing uncovered options, and then only after securing full details of the applicable conditions and potential risk exposure.

3. Contracts for differences (“CFDs”)

Futures and options contracts can also be referred to as a Contract for Differences. These can be options and futures on the FT-SE 100 index or any other index or individual stock, as well as currency and interest rate swaps. However, unlike other futures and options, these contracts can only be settled in cash. Investing in a contract for differences carries the same risk as investing in a future or an option and you should be aware of these as set out in paragraphs (1) and (2) respectively. Transactions in contracts for differences may also have a contingent liability and you should be aware of the implications of this as set out in the paragraph (6) below.

4. Off exchange transactions

It may not always be apparent whether or not a particular derivative is on or off-exchange. Your broker must make it clear to you if you are entering into an off-exchange derivative transaction.

Whilst some off-exchange markets are highly liquid, transactions in off-exchange or “non transferable” derivatives may involve greater risk than investing in on-exchange derivatives because there is no exchange market on which to close out an open position. It may be impossible to liquidate an existing position, to assess the value of the position arising from an off-exchange transaction or to assess the exposure to risk. Bid and offer prices need not be quoted, and, even where they are, they will be established by dealers in these instruments and consequently it may be difficult to establish what is a fair price.

5. Foreign markets

Different foreign markets will involve different risks. In some cases the risks will be greater than the risks in markets with which you are familiar. On request, your broker must provide an explanation of the relevant risks and protections, (if any), which will operate in any relevant foreign markets, including the extent to which he will accept liability for any default of a foreign broker through whom he deals. The potential for profit or loss from transactions on foreign markets or in foreign denominated contracts will be affected by fluctuations in foreign exchange rates.

6. Contingent liability transactions

Contingent liability transactions which are margined require you to make a series of payments against the purchase price, instead of paying the whole purchase price immediately. If you trade in futures or contracts for differences or write options you may sustain a total loss of the margin you deposit with your broker to establish or maintain a position. If the market moves against you, you may be called upon to pay substantial additional margin at short notice to maintain the position. If you fail to do so within the time required, your position may be liquidated at a loss and you will be liable for any resulting deficit in your account. Your loss may exceed your total investment or value of your Portfolio.

Even if a transaction is not margined, it may still carry an obligation to make further payments in certain circumstances over and above any amount paid when you entered the contract. Contingent liability transactions which are not traded on or under the rules of a recognised or designated investment exchange may expose you to substantially greater risks.

7. Collateral

If you deposit collateral as security with your broker, the way in which it will be treated will vary according to the type of transaction and where it is traded. There could be significant differences in the treatment of your collateral depending on whether you are trading on a recognised or designated investment exchange, with the rules of that exchange (and associated clearing house) applying, or trading off exchange. Deposited collateral may lose its identity as your property once dealings on your behalf are undertaken. Even if your dealings should ultimately prove profitable, you may not get back the same assets which you deposited and may have to accept payment in cash. You should ascertain from your broker how your collateral will be dealt with.

8. Commissions

Before you begin to trade, you should obtain details of all commissions and other charges for which you will be liable. If any charges are not expressed in money terms (but, for example, as a percentage of contract value), you should obtain a clear written explanation, including appropriate examples, to establish what such charges are likely to mean in specific money terms. In the case of futures, when commission is charged as a percentage, it will normally be as a percentage of the total contract value, and not simply as a percentage of your initial payment.

9. Suspensions of trading

Under certain trading conditions it may be difficult or impossible to liquidate a position. This may occur, for example, at times of rapid price movement if the price rises or falls in one trading session to such an extent that under the rules of the relevant exchange trading is suspended or restricted. Placing a stop-loss order will not necessarily limit your losses to the intended amounts, because market conditions may make it impossible to execute such an order at the stipulated price.

10. Clearing house protections

On many exchanges, the performance of a transaction by your broker (or the third party with whom he is dealing on your behalf) is “guaranteed” by the exchange or its clearing house. However, this guarantee is unlikely in most circumstances to cover you, the customer, and may not protect you if your broker or another party defaults on its obligations to you.On request, your broker must explain any protection provided to you under the clearing guarantee applicable to any on-exchange derivatives in which you are dealing. There is no clearing house for traditional options, nor normally for off-exchange instruments which are not traded under the rules of a recognised or designated investment exchange.

11. Insolvency

Your broker’s insolvency or default, or that of any other brokers involved with your transaction, may lead to positions being liquidated or closed out without your consent. In certain circumstances, you may not get back the actual assets which you lodged as collateral and you may have to accept any available payment in cash. On request, your broker must provide an explanation of the extent to which he will accept liability for any insolvency of, or default by, other brokers involved with your transactions.

Warrants Risk Warning Notice

This notice does not disclose all of the risks and other significant aspects of warrants. You should not deal in warrants unless you understand the nature of the transaction you are entering into and the extent of your exposure to potential loss. You should also be satisfied that warrants are suitable for you in the light of your circumstances and financial position.

In deciding whether to trade in warrants you should be aware of the following points.

1. Warrants

A warrant is a right to subscribe for shares, debentures, loan stock or government securities, and is exercisable against the original issuer of the securities. Warrants often involve a high degree of gearing, so that a relatively small movement in the price of the underlying security results in a disproportionately large movement in the price of the warrant. The prices of warrants can therefore be volatile. You should not buy a warrant unless you are prepared to sustain a total loss of the money you have invested plus any commission or other transaction charges. Some other instruments are also called warrants but are actually options (for example, a right to acquire securities which is exercisable against someone other than the original issuer of the securities, often called a “covered warrant”).

2. Off-Exchange transactions

Transactions in off-exchange warrants may involve greater risk than investing in exchange-traded warrants because there is no exchange market on which to liquidate your position. It may be impossible to liquidate an existing position, to assess the value of the position arising from an off-exchange transaction or to assess the exposure to risk. Bid and offer prices need not be quoted, and, even where they are, they will be established by dealers in these instruments and consequently it may be difficult to establish what is a fair price.

3. Commissions

Before you begin to trade, you should obtain details of all commissions and other charges for which you will be liable.

4. Foreign markets

Different foreign markets will involve different risks. In some cases the risks will be greater than the risks in markets with which you are familiar. On request, your broker must provide an explanation of the relevant risks and protections, (if any), which will operate in any relevant foreign markets, including the extent to which he will accept liability for any default of a foreign broker through whom he deals. The potential for profit or loss from transactions on foreign markets or in foreign denominated contracts will be affected by fluctuations in foreign exchange rates.

Foreign Exchange Transaction and Currency Fluctuation Risk Warning

Fiduserve or its representatives may from time to time effect on your behalf transactions in the foreign exchange markets the effect of which will be to expose your Portfolio to the risk of adverse movements in currency exchange rates.

1. Investments in foreign currencies

From time to time, Fiduserve may instruct your Portfolio to make investments in securities, hold money, or become overdrawn in currencies which are denominated in currencies other than the Base Currency of your Portfolio. As a result, your Portfolio may be exposed to negative effects on its valuation when the value of assets or liabilities in other currencies is translated to the Base Currency.

2. Foreign Exchange speculation

From time to time if permitted by you, Fiduserve may speculate on currency fluctuations for your Portfolio utilizing both spot cash transactions and/or foreign exchange forward contracts not traded on any recognized investment exchange. Such transactions are deemed to be speculative where they do not relate to the management of cash required to purchase investments for your Portfolio or arising from the realisation of such investments and where they substantially exceed in size any likely currency exposure arising out of investment purchases and sales. Such transactions and forward contracts may have the effect of gearing the exposure of your Portfolio to currency fluctuations either positive or negative.

Dealing in Securities Subject To Stabilisation

Fiduserve or its representatives may from time to time recommend to you or effect on your behalf transactions in securities the price of which may have been influenced by bids made or transactions effected for the purpose of stabilising the price of those securities. You should read the explanation below carefully. Its purpose is to enable you to judge whether you wish your funds to be invested at all in such securities and, if you do, whether you wish to authorise Fiduserve generally to effect transactions in such securities on your behalf without further reference to you or whether you wish to be consulted before any particular transaction is effected on your behalf.

Stabilisation is a process whereby the market price of a security is pegged or fixed during the period in which a new issue of securities is sold to the public. Stabilisation may take place in the securities of the new issue or in other securities related to the new issue in such a way that the price of the other securities may affect the price of the new issue or vice versa.

The reason stabilisation is permitted is that when a new issue is brought to market the sudden glut will sometimes force the price lower for a period of time before buyers are found for the securities on offer.

As long as he obeys a strict set of rules, the “stabilising manager”, normally the issuing house chiefly responsible for bringing a new issue to market, is entitled to buy securities in the market that he has previously sold to investors or allotted to institutions who were included in the new issue but who have decided not to continue participating. The effect of this may be to keep the price at a higher level than would otherwise be the case during the period of stabilisation.

The statutory stabilisation rules limit the period in which a stabilising manager may stabilise a new issue, fix the price at which he may stabilise (in the case of shares and warrants but not bonds), and require him to disclose that he may be (but not that he is) stabilising.

The fact that a new issue or a related security is being stabilised does not in itself mean that investors are not interested in the issue, but neither should the existence of transactions in an issue where stabilisation may take place be relied upon as an indication that investors are interested in the new issue or interested in purchasing at the price at which transactions are taking place.

Risk Disclosure Statement – Dealings in Foreign Markets

In order to acquire, dispose of, hold, exercise rights in relation to, or otherwise execute transactions in investments in any country or foreign market on your behalf or on behalf of your Portfolio, it may be necessary for Fiduserve or the Custodian to make use of brokers, intermediate brokers, nominees, banks, exchanges and settlement systems in such countries or foreign markets who may be subject to different legal and regulatory requirements from those with which you may be familiar. When Fiduserve or the Custodian arranges to acquire, dispose of, hold or exercise rights in relation to investments overseas your money and investments may not benefit from protections equivalent to those with which you are familiar. Fiduserve or your Custodian can provide you with further information on this issue.

Risk Disclosure Statement – Short Selling Shares

Some custodians offer their customers the ability to “short sell” securities such as shares in listed companies. This would involve you/your Portfolio borrowing such shares (facilitated by the Custodian) which you do not own and selling them in the relevant market and collecting the appropriate proceeds. If the price of such shares subsequently falls, you will be able to buy an equal number of shares in the market, deliver them to the lender to discharge your original borrowing of shares and retain a profit representing the difference between the price of the original sale less the price of the subsequent purchase. Such speculation involves a theoretically unlimited risk to your Portfolio in the event that the price of the shares you have sold continues to rise. In such as case, the higher cost to purchase the shares you have sold could result in your Portfolio realizing a very substantial loss. Most Custodians will require you to maintain assets in your Portfolio as margin against this risk if you are dealing in short selling of shares.

Where permitted by you, Fiduserve will from time to time short sell shares for your Portfolio. Any losses from such transactions are for your own account and risk and you represents that you understand the risks involved.

Risk Disclosure Statement – Underwriting

Should you agree to participate in underwriting or sub-underwriting (that is agree to subscribe for investments in advance of their being issued) you accept the risk that the market for such investments after issue is not assured and it may not be possible to sell the investment concerned at the subscription price or at all.

Risk Disclosure Statement – Illiquid Investments

Should you permit Fiduserve to purchase on your behalf investments that may be illiquid (that is investments in which there is a limited market or no market at all) you accept the risk that the investment concerned may be difficult to value or sell and you may have to perform any obligations associated with owning it. Please note that in any market and in relation to any investment there can be changes in liquidity which may be sudden. If you do not want us to deal in illiquid investments we will not do so but we may deal in investments and markets which may subsequently become illiquid.

Please read these terms of use carefully before using this site

By using this site, you signify your assent to these terms of use. If you do not agree to these terms of use, please do not use the site.

Restrictions on use of materials

This site is owned and operated by Fiduserve Asset Management Ltd. (referred to as “Fiduserve” “we,” “us,” or “our” herein). No material from the site may be copied, reproduced, republished, uploaded, posted, transmitted or distributed in any way, except that you may download one copy of the materials on any single computer for your non-commercial use only, provided that you keep intact all copyright and other proprietary notices. Modification of the materials or use of the materials for any other purpose is a violation of Fiduserve’s copyright and other proprietary rights. The use of any such material on any other Web site or networked computer environment is prohibited. Except as otherwise indicated on this site and except for the trademarks, service marks and trade names of other companies that are displayed on this site, all trademarks, service marks and trade names are proprietary to Fiduserve. In the event that you download any software from the site, the software, including any files, images incorporated in or generated by the software, and data accompanying the software (collectively, the “Software”) are non-exclusively licensed to you by Fiduserve. Fiduserve does not transfer title to the Software to you. Fiduserve retains full and complete title to the Software, and all intellectual property rights therein. You may not redistribute, sell, decompile, reverse engineer, disassemble, or otherwise reduce the Software to a human-perceivable form.

Disclaimer

The materials in this site are provided “as is” and without warranties of any kind either express or implied. To the fullest extent permissible pursuant to applicable law, Fiduserve disclaims all warranties, express or implied, including, but not limited to, implied warranties of merchantability and fitness for a particular purpose. Fiduserve does not warrant that the functions contained in the materials will be uninterrupted or error-free, that defects will be corrected, or that this site or the server that makes it available are free of viruses or other harmful components. Fiduserve does not warrant or make any representations regarding the use or the results of the use of the materials in this site in terms of their correctness, accuracy, reliability, or otherwise. You (and not Fiduserve) assume the entire cost of all necessary servicing, repair, or correction. Applicable law may not allow the exclusion of implied warranties, so the above exclusion may not apply to you.

Limitation of liability

Under no circumstances, including, but not limited to, negligence, shall Fiduserve be liable for any special or consequential damages that result from the use of, or the inability to use, the materials in this site, even if Fiduserve or a Fiduserve authorized representative has been advised of the possibility of such damages. In no event shall Fiduserve have any liability to you for damages, losses and causes of action (whether in contract, tort (including, but not limited to, negligence), or otherwise) for accessing this site.

Other

All claims, disputes or disagreements which may arise out of the interpretation, performance or in any way relating to your use of this site and any and all other Fiduserve site(s), shall be submitted exclusively to the jurisdiction of the courts located in the Country of Cyprus, and the City of Nicosia.

+ Privacy Notice
+ Right to Erasure Request Form
+ Subject Access Request Form

 

The Company acts in the best interests of the AIFs or the investors in the AIFs they manage when executing decisions to deal on behalf of the managed AIF in the context of the management of their portfolio.

Whenever the Company buys or sells financial instruments or other assets for which best execution is relevant, and for the purpose of the above paragraph, takes all reasonable steps to obtain the best possible result for the AIFs it manages or the investors in these AIFs, taking into account price, costs, speed, likehood of execution and settlement, size, nature or any other consideration relevant to the execution of the order. The relative importance of such factors shall be determined by reference to the following criteria:

  1. The objectives, investment policy and risks specific to the AIF, as indicated in the AIF rules and articles of association, prospectus or offering documents
  2. the characteristics of the investor including the categorization of the investor as retail or professional;
  3. the characteristics of the order;
  4. the characteristics of financial instruments that are the subject of that order
  5. the characteristics of investments that are subject to that order
  6. the characteristics of the execution venues to which that order can be directed.

The Company takes all reasonable steps to obtain the best possible result for the AIFs and their investors to the extent that it executes an order or a specific aspect of an order following specific instructions from the AIF and their investors relating to the order or the specific aspect of the order.

The above, also apply when the Company places orders to deal on behalf of the managed AIFs with other entities for execution, in the context of the management of their portfolio.

In the cases of non-listed equities and loan investments best execution presumes that the Company will make every effort for the execution of the transaction to be as cost effective as possible and within the remit of the legal and company law framework of the applicable jurisdictions.

 

  1. Execution of orders on behalf of AIFs and their investors
    The Company satisfies the following conditions when carrying out AIFs and their investors orders:

    1. ensures that orders executed on behalf of the AIFs and their investors are promptly and accurately recorded and allocated;
    2. carries out otherwise comparable investors’ orders sequentially and promptly unless the characteristics of the order or prevailing market conditions make this impracticable, or the interests of the investors require otherwise;
    3. informs a retail investor about any material difficulty relevant to the proper carrying out of orders promptly upon becoming aware of the difficulty.

    Where the Company is responsible for overseeing or arranging the settlement of an executed order, it shall take all reasonable steps to ensure that any investor financial instruments or investor funds received in settlement of that executed order are promptly and correctly delivered to the account of the appropriate investor.

    The Company does not misuse information relating to pending investor orders, and takes all reasonable steps to prevent the misuse of such information by any of its relevant persons.

  2. Reporting obligations in respect of execution of subscription and redemption orders

    Where the Company has carried out a subscription or, where relevant, a redemption of order from an investor, it shall promptly provide the investor, by means of a durable medium, with the essential information concerning the execution of that order or the acceptance of the subscription offer, as the case may be. The essential information shall include the following information:

    1. the identification of the Company;
    2. the identification of the investor;
    3. the date and time of receipt of the order;
    4. the date of execution;
    5. the identification of the AIF;
    6. the gross value of the order including charges for subscription or the net amount after charges for redemptions.

    The Company shall supply the investor, upon request, with information about the status of the order or the acceptance of the subscription offer, or both as the case may be.

  1. Aggregation of Orders
    The Company is not permitted to carry out an AIF order in aggregate with an order of another AIF, an investor or with an order made when investing their own funds unless the following conditions are met:

    1. it must be unlikely that the aggregation of orders and transactions will work overall to the disadvantage of any AIF or investor whose order is to be aggregated;
    2. it is disclosed to each AIF or investor whose order is to be aggregated that the effect of aggregation may work to its disadvantage in relation to a particular order;
    3. an order allocation policy is established and effectively implemented, providing in sufficiently precise terms for the fair allocation of aggregated orders and transactions, including how the volume and price of orders determines allocations and the treatment of partial executions.

    Where the Company aggregates an order with one or more orders of other AIFs or clients and the aggregate order is partially executed in accordance with its order allocation policy.

  2. Order Allocation
    It is not permissible for the Company to allocate trades in a way that is detrimental to the AIF or a client, where the Company aggregates transactions for its own account with one or more orders of AIFs or clients.

    The Company allocates the related trades to the AIFs or clients in priority over those for own account, where the Company aggregates an order of AIFs or clients with a transaction for its own account and the aggregated order is partially executed.

    Regardless of the above, if the Company is able to demonstrate to the AIF or to the client on reasonable grounds that it would not have been able to carry out the order on such advantageous terns without aggregation, or at all, it may allocate the transaction for its own account proportionally.

  3. Monitoring and Review

    The Company monitors compliance of its executions with the order execution policy on an ongoing basis and where appropriate corrects any deficiencies.

    The Company reviews its execution policy annually. Also, whenever a material change occurs that affects the Company’s ability to obtain the best possible resulted for the managed AIFs execution policy is being reviewed.

    The Company at all times has to be able to demonstrate that it has executed the orders on behalf of the AIFs in accordance with this execution policy.

    The Company makes available to investors in the AIFs it manages appropriate information on the best execution policy and on any material changes.

  4. Non-tradable securities/assets in Regulated Markets and specifically Private Equity
    The Company reviews, recalculates and makes sure that it obtains the best possible execution, a correct Net Asset Valuation (NAV), clients will be accordingly notified. The Company reviews all adjustments on the NAV and ensures that they are correct and reasonable. In addition to the above the Company reviews (where applicable) the following and makes sure that they are in accordance with the mandate:

    1. management fees
    2. transactions fees
    3. carried interest
    4. ratchets
    5. hurdle rates
    6. key man clauses
    7. claw back provisions
    8. distribution waterfalls
    9. tag-along, drag along rights
    10. no-fault divorces
    11. other investment restrictions.
  5. Best Execution vary between asset classes

    The process the Company delivers best execution varies from asset class to asset class. In this respect, different execution factors are taken into account in relation to the asset classes chosen by the AIFs under management including Private Equity, Venture Capital and Hedge Funds.

COMPLAINTS OR GRIEVANCES POLICY

  1. Complaint or grievance handling

     The Company shall establish, implement and maintain effective and transparent procedures for the reasonable and prompt handling of complaints or grievances received, and to keep a record of each complaint or grievance and the measures taken for the complaint’s resolution.

    Assignment of Responsibility
    Investor’s complaints or grievances, together with complaints from the Directors of the AIFs are handled by the Senior Management, in co-operation with the affected Departments.

    General Principles
    All units are required to handle complaints honestly, fairly and with professional integrity.

    All Complaints should be resolved promptly and within a maximum of ten (10) working days from the date of official receipt of the complaint. If it is not possible to meet the aforesaid deadline, the reason must be recorded and an estimated date for resolution agreed. The expected closure date must be communicated to the AIF or the investor who filed the complaint within three working days of receipt.

    A standardised form is used (the “Complaint Report” as per section 2) as a template to guide the Senior Management in carrying out the investigation and is also instrumental in providing a one stop trail of all actions and decisions taken in respect of the complaint. Copies of all resolution letters are kept by Senior Management to have a clear audit trail for all complaints.

    The complaint shall be sent to the Company either in hard copy at the head offices of the Company or by email to the email address that will be provided to the AIFs and investors for this purpose.

    The procedure which shall be followed by the Company, when handling with AIF’s and investor’s complaints or grievances, is the following:

    • All complaints must be submitted in writing, signed by a person authorised to act on behalf of the AIF or the investor and should be as descriptive as possible in respect of the events that led to the filing of the complaint. Complaints which are unsigned and do not contain the name and other details of the applicant will not be considered. If an AIF or an investor communicates a complaint verbally or by any other means, he /she should kindly be asked to contact the Senior Management, who will then explain the procedure for handling complaints.
    • A complaint or grievance is initially handled by a member of the Senior Management. The employee receiving the complaint or grievance shall take the necessary actions so that the complaint or grievance is properly addressed. The Senior Management communicates all the complaints received to the respective manager of the affected business or operations unit. The relevant manager ensures that the investigation conducted by Senior Management is facilitated to the highest possible degree.
    • The complaint or grievance in the form that has been received immediately (within three working days), should be forwarded to the head of the department where the complaint is addressed.
    • The member of the Senior Management shall inform the AIF and investor that the complaint or grievance has been forwarded to the relevant department/personnel, providing all details so that the AIF and investor is aware who is dealing with his/her complaint or grievance.
    • The member of staff, in addition to the above, should make all best efforts to ensure that in the case of the complaint or grievance being of such nature that can be resolved immediately, to do so that the AIF and investor will not have to pursue the filling of a formal complaint. The member of staff in such a case shall not:
      1. Commit him/herself in any way to the AIF and investor
      2. Address any issues in relation to best execution
      3. Address any issues relating to legal issues
      4. Commit the Company in taking any action prior to examining the issues in a formal manner
  2. Procedure to be followed when a formal complaint or grievance is received
    1. When a written complaint or grievance is received, this shall be forwarded to the relevant department which is the most appropriate for dealing with the complaint.
    2. The member of the Senior Management shall contact the AIF and investor to inform them that the complaint or grievance has been received and it is under investigation.
    3. Upon receiving a written complaint or grievance, the following details should be obtained and recorded:
      • The identification particulars of any AIF’s and investors’ having made a complaint or grievance.
      • The service provided by the Company and related to the complaint or grievance.
      • The employee responsible for the provision of those services.
      • The department where the employee belongs.
      • Date of receipt and registration of complaint or grievance.
      • Content of the complaint or grievance.
      • The capital and the value of the financial instruments/investments which belong to the AIF and/or investor.
      • The magnitude of the damage claimed by the AIF and investor.
      • Reference of any correspondent exchanged between the Company and the AIF and/or investor.
    4. The events leading to the complaint or grievance should be examined and assessed based on the information provided by the AIF and/or investor.
    5. The facts as stated by the AIF and/or investor have been examined and verified whether any additional information, need to be retrieved from the Company’s archive (electronic mail, recorded telephone calls, IT data, etc.).
    6. All non-trivial complaints or grievances shall be brought to the attention of and their resolution should be approved by the Senior Management.
    7. Upon completion of the investigation a report shall be prepared stating the facts and brought to Senior Management’s attention, which will decide on the formal response to the AIF and/or investor and the action to be taken.

    In the case where an AIF and/or investor complaint or grievance is valid, the management shall take such necessary action together with the Head of Department(s) to which the complaint or grievance is related in order to identify and verify:

    1. Reasons for failure of procedure followed.
    2. Weaknesses of the internal controls.
    3. Implementation of internal controls that would prevent any complaint or grievance in the future.

    All suggested procedures shall be approved by Senior Management at the meeting following the completion of the investigation.

  3. Record-keeping of complaints or grievances received

    The Company shall maintain all complaints or grievances for a minimum period of five years after the termination of the business relationship. The responsible department shall be the Senior Management.

  4. Complaints or grievance handling for individual portfolio management service and investment advice

     All complaints made by clients (or potential clients) either directly to the Company or indirectly through the Commission or the Financial Ombudsman, in relation to the way in which the Company conducts its business must be fully investigated by the Compliance Officer and where possible appropriate action taken to resolve the situation.

    Even an apparently trivial complaint which is mishandled or left unchecked could lead to serious and damaging consequences for the Company.  Any apparent complaint, whether written or oral, must be immediately referred to the Compliance Officer.

  5. Complaints Procedure

    All Company employees must ensure that the following procedure is followed on receipt of any apparent complaint.

    1. If a client complains over the telephone or verbally at a meeting, the client must be asked to put in writing his or her complaint with sufficient detail to enable action to be taken.

      The written complaint should be sent to the Compliance Officer who will implement the necessary procedure. The Compliance Officer will decide whether the matter is a “Significant Complaint”, that is one that cannot be settled quickly and directly, or one which involves sums which are material in relation to the financial circumstances of the complainant, or one which alleges:

      • A breach of a Client Agreement; or
      • A failure to comply with regulatory responsibilities; or
      • Bad faith, malpractice or impropriety; or
      • Repetition or recurrence of any matter about which there has been recent complaint.
    2. All significant complaints must be acknowledged in writing within 5 days of being received and a unique reference number be assigned to the complaint which shall be used for all future communication with the Financial Ombudsman and/or CySEC.

      It may be possible at this stage to offer a full reply / settlement which is reasonably expected to be acceptable to the complainant. In this case, the letter should also clearly state that his complaint will be treated as settled if he does not indicate dissatisfaction within one month of receiving the letter. If the complainant does not, in fact, indicate dissatisfaction within one month, the complaint may then be treated as settled.

      If it is NOT possible to resolve the complaint within 5 days, a letter of acknowledgement should be sent as indicated below in point 3.

    3. The letter of acknowledgement should include statements to the effect that the company will:
      1. Investigate the complaint; and
      2. On completion of the investigation, write informing the complainant of the outcome of the investigation within two months informing whether the complaint has been successfully resolved or why more time is needed to look into it (within maximum three months from the day of the complaint).

      The letter should also include the unique reference number as indicated in point 2 above.

    4. Each complaint must then be:
      1. Promptly and thoroughly investigated; and
      2. If practicable, the Compliance Officer should be assisted in his investigation by an employee of particular experience and competence who was not directly involved in the subject matter giving rise to the complaint.
    5. At the conclusion of an investigation a written report must be produced which explains clearly:
      1. The outcome of the investigation; and
      2. The nature of any offer of settlement which is considered appropriate or alternatively, the reasons for declining to offer a settlement.
    6. Within two months of the completion of an investigation a letter must be sent to the complainant explaining clearly:
      1. The outcome of the investigation.
      2. The nature and terms of any offer of settlement which the Company is prepared to make in satisfaction of the complaint.
      3. The letter should also clearly state that the Company will treat the complaint as settled if the complainant does not indicate dissatisfaction within one month.
      4. The availability to contact the Financial Ombudsman and/or the Commission when the final decision does not fully satisfy the complainants demands. This should be done within four months from receiving the final response from the Company.
      5. If the complaint has not been resolved within the two months, the reason why more time is needed to look into it with a maximum of three months from the date of the complaint.
    7. Where a client is unwilling to put his complaint in writing, the complaint automatically will be categorised as not Significant. A file note should be made to that effect and the Company employee responsible for that client relationship will continue to discuss the issue with the client. If the issue is not resolved satisfactorily within another month, the Compliance Officer should be informed.

    When a complaint is in writing, but judged by the Compliance Officer as not Significant, a copy of the written complaint should be filed in the Complaints Register. The Company employee responsible for that client relationship shall continue discussions with the client until the issue is resolved and shall keep the Compliance Officer informed and make a note for the Compliance Officer to file the eventual resolution.

    The Company must co-operate with the Commission and/or Financial Ombudsman in case it carries out its own investigation in relation to a client’s complaint.

  6. Complaints Record and Register

    A full record of each complaint, including all relevant documents, and of the action taken in response must be kept by the Company for 7 years after the date of the last response.

    The Compliance Officer is responsible for entering all complaints onto the Complaints Register and recording the outcome. The following information should be noted: –

    • the unique reference number of the complainant;
    • the identity of the complainant;
    • the Company employee to whom the complaint was made;
    • the Company employee responsible for that client relationship and his department;
    • the date on which the complaint was received and filed;
    • a summary of the complaint;
    • the value of the complainant’s portfolio;
    • the approximate value of any loss which the complainant claims to have suffered;
    • the date and a summary of the Company’s reply to the complaint;
    • a note of any other relevant correspondence with the complainant, which should be kept in the appropriate client file.

    The Complaints Record and Register should be available for inspection by the Commission at any time.

  7. Complaints-Handling Process

     Information about lodging a complaint:

    1. The type of information provided by the complainant should be clear and specifically state the nature of the complaint.
    2. All complaints should be sent to the company’s office address as stated on the website for the attention of the Managing Director.
    3. The complaint will be acknowledged in writing within 5 days of receipt.
    4. The complaint will then be investigated and depending on the severity of the complaint the Compliance Officer may also be involved.
    5. Within two months of the completion of an investigation a letter shall be sent to the complainant explaining in detail the outcome of the investigation. This may be extended to three months if more time is needed to resolve the complaint.
    6. The availability to contact the Financial Ombudsman and/or Commission within four months when the final decision does not fully satisfy the complainant’s demands shall be stated in the response.
  8. Financial Ombudsman Contact Details

     Investors who consider that they have any disputes with Regulated Entities, for which they are claiming damages, are encouraged to consider submitting their complaint to the Financial Ombudsman.

    Address:
    13 Lord Byron Avenue,
    1096 NICOSIA
    Phone: 22848900 (main number)
    Facsimile (Fax): 22660584, 22660118
    Email:

Please contact Andreas Persianis for Discretionary Portfolio Management services (apersianis@fiduserve.com), or Andreas Hadjioannou for Fund Management and Valuation Services (andreas@fiduserve.com).