Complaints Management Policy

1. Introduction

1.1. General

The Complaints Management Policy (the Policy) is developed in accordance with the requirements of the Applicable Law.

The Company will review and monitor on at least an annual basis the effectiveness of this Policy to:

• identify and implement any required amendments to this Policy;
• ensure the Policy is fit for purpose; and
• ensure the Policy reflects any changes to the Applicable Law.

The most up-to-date version of this Policy is available on the Company website.

The Company shall notify Clients of material changes to this Policy by providing a 14 calendar days’ notice to the Client’s email address.

1.2. Scope and purpose

This Policy is developed with the purpose of outlining how the Company considers and settles Complaints made by Retail and Professional Clients (Clients) against the Company in connection with the provision by the Company of Investment Services.

1.3. Definitions and Meanings

"AIFC" means the Astana International Financial Centre. "AFSA" means the Astana Financial Services Authority.

“Applicable Law” means the relevant AIFC Rules and Regulations, the Kazakh national legislation and international legislation and standards, that are applicable to the Company’s business.

“Complaint” means any oral or written expression of dissatisfaction (whether justified or not) about the provision of, or failure or provide a Service(s), which alleges that the Complainant has suffered (or may suffer) financial loss, distress, or inconvenience.

“Complainant” means broadly someone who would fall within the description of a Retail Client or a Professional Client and to whom the Company provides its Service(s).

"Website" means Raison’s website (including the mobile site) the address of which is: https://raison.app or as it may be from time to time.

Complaints management

2.1. Policy statement

The Company is committed to delivering high quality Investment Services and welcomes Client feedback on its products, Services, performance and Personnel as a means of monitoring and improving Service delivery to Clients, as well as enhancing overall organisational effectiveness and efficiency.

The Company is also committed to ensuring that all Complaints are managed promptly in a responsive, fair manner and in the best interests of Clients. Clients will be treated with respect and will receive a professional level of service throughout the Complaint Management process.

2.2. Filing a Complaint

If the Client has any objections or concerns on the provision of Investment Services and/or the performance of Investment activities, the Client is encouraged to submit a Complaint using one of the following channels:

• via [email protected] indicating "Client complaint" in the email subject line;
• via Online Chat in the Client’s personal account in the Raison App mobile application or on 
the Website indicating the subject “Сlient complaint";
• by submitting a Client Complaint Form as attached in Annex 1 to the Policy; or
• by submitting a request to the Company in a free format.

Upon submission of the Complaint, the Client shall be notified of its receipt by the Company’s Customer Support within 7 (seven) calendar days.

The notification shall indicate a unique reference number and which should be used by the Client in all future contact with Company and/or AFSA regarding the specific Complaint and its resolution.

2.3. Receipt of a Complaint Acknowledgment of receipt

On receipt of a Complaint, the Company must:

• acknowledge the Complaint promptly in writing within 7 days from its receipt;

• provide the Complainant with:

the contact details of any individual responsible for handling the Complaint;
 details of the Company’s Complaints handling procedures; and
 a statement that a copy of the procedures is available free of charge upon request; and

• investigate the Complaint.

2.4. Timing of Complaints resolution

The Company will ensure Complainants are kept informed on the progress of resolution of their Complaints. The Company shall inform the Client in writing about the outcome of the investigation into the Complaint within 60 (sixty) calendar days.

The Company will provide an update to the Complainant in circumstances where the resolution of the Complaint is taking longer than 30 days.

If the Company is unable to respond within 60 (sixty) calendar days, the Company must inform the Client about the reasons for the delay and indicate the expected period within which the investigation into the Complaint will be completed. This period cannot exceed 90 (ninety) calendar days from the date of submission of the Complaint.

During the investigation into the Complaint, the Company shall inform and update the Client of the Complaint management process every 10 (ten) business days.

2.5. Complaints resolution

When the Company has completed its investigation of a Complaint, it must promptly:

• advise the Complainant in writing of the outcome;
• propose redress (if applicable) to the Complainant; and
• provide redress if accepted by the Complainant.

If the Complainant is not satisfied with the redress offered by the Company, the Client shall be provided a thorough written explanation of the Company’s decision on the Complaint, setting out the Client’s options to proceed with the Complaint further.

The Client may address the following authorities to file an appeal against the Company’s decision or in cases of a delay in a decision:

• AFSA. Kazakhstan, 010000 Astana, 55/17 Mangilik El Avenue, C 3.2. Website http://www.afsa.aifc.kz.

• AIFC Court
. Kazakhstan, 010000 Astana, 55/16 Mangilik El Avenue, C 3.1 Level 1. Telephone: +7-7172-64-73-37 or +7-7019-81-73-20. 

E-mail: [email protected].

2.6. Complaints Register

Any Client Complaints should be directed to the Compliance Officer who will make a formal record of them in the Complaints Register.

The Complaints Register must contain the following information:

• the name of the Complainant;
• the substance of the Complaint;
• a record of the Company’s response;
• any other relevant correspondence or records; and
• the action taken by the Company to resolve each Complaint.

All material Complaints will be reported to the Senior Management and if needed to the BOD and action will be taken to correct recurrent or systemic problems.

Annex 1
. Client Complaint form

If you are not satisfied with the Company’s Service, you may file a complaint:

Please, fill in the Client Complain Form below, print, sign and send it out it to [email protected], or submit a complaint via Online Chat in the App or on the Website.

Client Complaint Form

Full name:

ID/Passport No:

Account No:

Contact details including e-mail:

Complaint cause, detailed explanation, and screenshots/copies of correspondence to the details of the complaint (if available):

Financial instrument (if applicable):

The date of the last correspondence with Raison Personnel and the name of that Personnel:

A detailed summary of the events leading up to a complaint:

Expected resolutions/outcomes to rectify the situation: ... 
This paragraph should describe the requirements, requests, and expectations of the Client as a result of complaint consideration

Personal signature:

Date: