1. Introduction

   1. Circle Square Capital Management AG (hereinafter the “Company”) is incorporated under the laws of Switzerland and regulated as a Financial Institute under License Nr. CH-626.3.010.031-6 (herein the “Law”).
   2. The Complaint Handling Procedure (hereinafter the “Procedure”) sets out the process adopted by the Company for the reasonable and prompt handling of complaints, disputes and grievances received from Clients (hereinafter the “Complainant”).
   3. As part of the Company’s commitment to provide the highest standard of service to its Clients, the Company maintains effective and transparent procedures for the reasonable and prompt handling of complaints for all existing and prospective Clients. The Company maintains relevant records of complaints and the measures taken for complaint resolution in accordance with the applicable Laws, Rules and/or Regulations.

2. Complaints

   1. The Company shall accept and investigate any written expression of dissatisfaction which Clients have levelled against the Company relating to the investment and/or ancillary services provided by the Company under the Law. Such matters shall be dealt with in accordance with the Complaint Handling Procedures set forth herein. The aforesaid reasons for dissatisfaction may include, but are not limited to, the following:
      1. Dissatisfaction with the Company’s response to a Client’s inquiry or the time taken for the provision of a response being provided.
      2. The Company’s refusal to provide information related to a Client’s Account and/or Transaction.
      3. Dissatisfaction with Clients’ rights under the “Client’s Agreement”, “Client Categorization Policy”, “Order Execution Policy”, “Conflicts of Interest Policy” and/or any other Legal Documentation listed on Company’s website.
   2. To facilitate the effective and efficient handling of complaints, the Client’s complaint should include as much descriptive information as possible and must include the following information:
      1. the Client’s name and surname;
      2. the Client’s trading account number;
      3. the relevant transaction numbers, if applicable;
      4. the date that the issue arose and a description of the issue;
      5. any relevant attachments.
   3. A Complaint or grievance should be reported to the company, in writing, within three (3) working days from the occurrence of the event that gave rise to the complaint. Failure to file a complaint within the above mentioned time period and through the procedures detailed in this policy may be considered, at the reasonable discretion of the company, as a ratification by the client of all actions undertaken by the company prior to making a formal complaint.
   4.  The complaint should be clear and concise in content may not include any offensive language directed towards the Company or any employee.

3. Procedure

   1.  In the event that a Complainant is dissatisfied with the Company’s services, has a query regarding their account activity or is deemed to have a complaint against the Company, the Client may contact Company’s Customer Support Department via email at compliance@fox-markets.com. The relevant Departments shall determine if the inquiry can be resolved immediately or whether it requires further investigation.
   2. If the Client is dissatisfied with the response from any of the Departments and/or if any of the Departments are unable to resolve the complaint, the matter shall be forwarded to Compliance Department at compliance@fox-markets.com.
   3. A complaint submitted to Compliance Department must only be sent from the Client’s registered email address or by a representative officially authorised by the Client.
   4. The receipt of a complaint shall be confirmed to the Client within five (5) business days and the Client shall be provided with a unique reference number.
   5. The member of staff tasked with handling a client complaint, in addition to the above, should make all best efforts to ensure that where a complaint is of such a nature that can be resolved immediately, to do so without introducing the necessity for the filing of a formal complaint. In doing so, the member of staff does not commit themselves in any way to the client, address any issues pertaining to best execution or legal issues, and does not commit the company to taking action prior to the formal examination of the issues raised.
   6. In the case where a complainant wishes to proceed with a formal complaint, the complaints form developed by the company, which can be found on our website should be completed in the fullest detail before being submitted to the company via email to compliance@immofunding.com.
   7. The Company will, without undue delay, thoroughly investigate all complaints and shall take into account any relevant information contained within the Company’s records. This information shall include, but not be limited to, the Client’s trading account history.
   8. If, based on the information provided by the Client, the Company is unable to adequately identify or investigate the complaint the Company may revert to the Client for further details to clarify the situation. Such communication may be made via email or by telephone.
   9. The Company will send its response to the Client within ten (10) business days from the date the complaint was received. In the event the complaint requires further investigation, and it cannot be resolved it within ten (10) business days, it will issue a written holding response. When a holding response is sent, it will indicate when the Company makes further contact and inform the Client of the investigation’s progress.
   10.  The Company will conclude an investigation and provide the Client with an outcome/decision within two (2) months from the date of receipt of the complaint.
   11. In the unlikely event that the Company is unable to conclude the investigation within two (2) months, the Company must inform the Complainant of the reason for the delay and indicate the timeframe within which the investigation will be finalised. The indicated time must not exceed three (3) months from the date of receipt of the complaint.

4. Record Keeping

   1. The Company maintains and updates its complaints’ register with details of all complaints received per month. Such records are retained for a period of five (5) years.
   2. The following information is recorded in the complaints’ register:
      1. date of the complaint;
      2. account number;
      3. identification of the complainant;
      4. reason for the complaint;
      5. the financial instrument;
      6. the disputed amount;
      7. settlement date if applicable;
      8. any relevant comments thereto.

5. Principle of the Procedure

   1. All complaints shall be treated confidentially.
   2. The Company shall deal with Client’s complaints without undue delay.
   3. The company will resolve all complaints in a fair manner.

Contact:
Customer Support Department: support@immofunding.com
Compliance Department: compliance@immofunding.com