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Complaint Handling Policy

iTrade Global (CY) Ltd, Complaint Handling Policy


1.1. iTrade Global (CY) Ltd hereinafter referred to as “the Company” is an
Investment Firm that owns and operates the brand “TradeFW” ( The
Company is incorporated and registered under the laws of the Republic of Cyprus,
with registration number HE 335424 and is authorized and regulated by the Cyprus
Securities and Exchange Commission (CySEC ), with CIF license number 298/16.

1.2. This Complaint Handling Policy hereinafter “the Policy” sets out the processes
employed when dealing with Complaints received by customers.


2.1. A Complaint is an expression of dissatisfaction by a client regarding the provision of
investment and/ or ancillary services provided by iTrade Global (CY) Ltd and its brands.

2.2. A Complainant is defined as any person, natural or legal, who has read, agreed with
and accepted all the Terms and Conditions of the Company which are contained in the
Client Agreement and without modifications, has opened a trading account with the
Company and has submitted a Complaint.

2.3. If a Customer wishes to report a Complaint, then he/she must send his/her
message to the Company’s Back Office/Account Opening Department with the
following information included:

i. Customer’s name and surname
ii. Customer’s account number
iii. Detailed enquiry description and other relevant information
iv. References of transactions involved in the specific Complaint
v. Date and time that the concern/problem arisen
vi. Any attachment that supports his concern/problem.

2.4. If a situation arises which is not expressly covered by the Back Office/Account
Opening Department, the parties shall agree to try to resolve the matter on the basis of
good faith and fairness and by taking the necessary actions which are consistent with
the current market practices.

2.5. The Customer’s right to take legal action remains unaffected by the existence or
use of any Complaints procedures referred to above.


3.1. If the Customer has any Complaint in relation to any of the services provided by
the Company, this Complaint should be transmitted in writing through the “Support”
section (button) which can be found on the Company’s website or by sending an email
to [email protected] All Customers’ Complaints are then received by the Back
Office/Account Opening Department as soon as the issue is submitted by the

3.2. Both the Back Office/Account Opening Department and the Compliance Department
shall thoroughly examine any Complaints as required (taking into account any information
contained within the books and records of the Company, including but not limited to the
client’s trading account journal) to reach a fair outcome.

3.3. The Head of Back Office /Account Opening Department and when necessary the
Compliance Officer shall:

i. Send an initial written response to the client within 48 hours or not later than
five days informing him/her of the Officer that is handling the Complaint.
ii. Registers the Complaint directly to an internal register, giving it a unique
reference number as detailed below on Paragraph 4.
iii. Informs the complainant that he should use the said reference number in all
future contact with the CIF, the Financial Ombudsman and/or the CySEC
regarding the specific Complaint
iv. Resolve the Customer Complaint as soon as reasonably practicable but within
8 weeks from the receipt of the Complaint. In cases whereas more information
and investigation is needed and the 8 weeks’ period is not sufficient, then the
responsible Officer must update in writing the Customer of the reasons of delay
and indicates the period of time within it is possible to complete investigation.
This period of time cannot exceed three months from the submission of the

3.4. Upon completion of the Investigation, an Internal Complaint Report shall be prepared
by the Back Office /Account Opening Department and/or the Company’s Chief Executive
Officer (CEO) or an Executive Director stating the facts and brought to Executive
Management’s attention, which will decide on the formal response to the client and the
action to be taken.

3.5 If the customer receives a response from the Back Office /Account Opening
Department but deems that the Complaint needs to be raised further the client may either
ask the Back Office /Account Opening Department to escalate it to the Compliance
Department or directly contact the Compliance Department which will independently and
impartially investigate it at [email protected]

3.6. The Head of Back Office/Account Opening Department shall send a weekly report
to the Executive Management of the Company with all Complaints not resolved for more
than 10 working days.

3.7. In the case where a client Complaint is valid, the Executive Management shall take
the necessary actions to which the Complaint is related in order to identify and verify:

i. Reasons for failure of procedure followed.
ii. Weaknesses of the internal controls.
iii. Implementation of internal controls that would prevent any Complaint in the future.
All suggested procedures shall be sent for approval to the Board of Directors following
the completion of the investigation procedure.

3.8. When the final decision of the Complaint does not fully satisfy the complainant’s
demands, the Company shall notify in writing the complainant using a thorough
explanation of its position on the Complaint and set out the complainant’s option to
maintain the Complaint e.g. through the Commission, the Financial Ombudsman, ADR
Mechanism, or the relevant Courts.


Information regarding the Complaints received by the Company shall be disclosed to
CySEC for the purposes of compliance with paragraph 13(5) of CySEC’s Directive. The
Company must register the Complaints it receives as soon as possible, in an internal
register with an appropriate manner, as well as for easy reference and retrieval.

4.1. The Head of Back Office/Account Opening of iTrade Global (CY) Ltd apply the

Upon receiving the Complaint, the Back Office/Account Opening registers the Complaint
directly to an internal register, giving it a unique reference number.

1. The unique reference number must be consisted of ten digits:
• the first two digits are the code of iTrade Global (CY) Ltd regarding the
September 10, 2017 iTrade Global (CY) Ltd 5
Transaction Reporting System – TRS (i.e. “XXX”)
• The following four digits define the year, and
• The last four digits denote the number of each Complaint serial number (e.g.
for 2015 – AA20150001, AA20150002, for 2016 – AA20160001, AA20160002).

2. The unique reference number is communicated by the Back Office/Account
Opening to the complainant with the first written response of the Company as
detailed in paragraph 3.


The Head of Back Office must prepare a monthly report with information regarding the
Complaints it receives and how these are being handled.

In particular, the Back Office /Account Opening completes every month (reporting
month) the form XX_yyyymmdd_T144-002-01 (excel file, the ‘Form’) and sends it to the
Executive Directors for review and Submission to CySEC within five days after the
reporting month. The ‘Form’ is sent in electronic form via the TRS. In case where the
Company did not receive any Complaint within the reporting month, the Company will
send the form empty to the Executive Directors stating that there is no Complaint for the
reporting month. In this case the Company has no obligation to send the Form.

In the event where the Company has resolved and/or revised a Complaint which was
referred to the CySEC in a previous submission of the Form, the Head of Back Office
/Account Opening must complete all the fields of the ‘Form’ and select the ‘U’ from the
column Record Type.


The responsible department for the record keeping of Complaints or grievances
received is the Back Office / Account Opening Department. In particular, the Head of
Back Office, or his/her designee, will keep a record of each Complaint and the
measures taken for the Complaint’s resolution.

Once received the Complaint shall be registered in internal archive and with an
appropriate manner. The Head of Back Office/Account Opening, or his/her designee,
shall maintain a central record of all Complaints that includes the following information:

• name, address and account number (if available) of the complainant;
• date on which the Complaint was received;
September 10, 2017 iTrade Global (CY) Ltd 6
• department(s) involved the Complaint investigation along with the names of the
responsible employees;
• description of the nature of the Complaint;
• Disposition of the Complaint;
• Actions taken to resolve the Complaint; and
• Resolution Date

The Company shall maintain all Complaints or grievances for a minimum period of five


All Complaints shall be treated with confidentially.

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