ZYC-COMPL-001 Complaints Handling Policy
Purpose
To ensure all complaints received by Zeyro — or made to our clients about promotions we have approved — are handled promptly, fairly, and in line with FCA requirements under DISP and the UK MiFID framework.
Scope
Applies to:
Complaints directly about Zeyro’s services (e.g. facilities services under MiFID).
Complaints made to our clients by consumers about a financial promotion that Zeyro approved under the Section 21 gateway.
Policy Statement
Zeyro treats all complaints seriously, even where the FCA’s formal DISP requirements apply only to our MiFID-regulated activity. We record, investigate, and respond to all complaints proportionately, identifying whether they reveal any weakness in our compliance controls or client oversight.
Definitions
A complaint is any oral or written expression of dissatisfaction (whether justified or not) that:
alleges financial loss, distress, or inconvenience; and
relates to a service provided by Zeyro, or to a financial promotion we have approved.
Complaints About Zeyro’s Own Services
Acknowledgement: within 24 hours of receipt.
Investigation: MLRO or delegate investigates and records findings in Jira Service Management.
Response: within eight weeks, explaining the outcome and any remedial action.
Escalation: include right to refer to the Financial Ombudsman Service (FOS) where relevant.
Recording: all complaints logged in the Complaints Register in Confluence.
Complaints About Client Promotions
When Zeyro receives or becomes aware of a complaint about a financial promotion we approved:
Record: open a Jira ticket linked to the promotion.
Review: confirm compliance of the approved promotion with FCA rules and internal standards.
Liaise with Client: notify the client and request their investigation and response.
Action: require amendment or withdrawal if non-compliant.
Close: record findings and outcome in the Complaints Register, tagged “Client-originating.”
Complaints Data Collection from Clients
Zeyro collects monthly complaints and frictions data from clients to monitor potential consumer harm.
Clients submit data via Zeyro’s Complaint Tracking Table and Frictions Reporting Template by the first Friday of each month.
Operational staff verify accuracy before upload to each client’s Confluence archive page.
Data are used to identify trends and reported in the FCA’s Complaints Return where required.
Oversight and Reporting
The MLRO monitors complaint trends and reports quarterly to the Board on significant issues or remedial actions.
Zeyro includes both direct and client-related complaints in its FCA RegData Complaints Return.
Records are retained for at least five years under ZYC-REC-001 Record Keeping & Data Retention Policy.
Roles and Responsibilities (RACI)
Role
Responsibility
Accountability
Consulted / Informed
Operational Staff
Identify, record & triage complaints in Jira; collect client data monthly; ensure records complete.
MLRO
MLRO (for outcomes), Board (for summaries)
MLRO / Compliance Officer (SMF 16 & 17)
Investigate complaints; determine regulatory relevance; maintain register; prepare FCA returns; update policy.
Board
Operational staff (for fact-finding)
Board
Review quarterly summaries; approve policy; oversee complaint-handling effectiveness.
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MLRO
Clients (external)
Report complaints & frictions data to Zeyro; cooperate in investigations of approved promotions.
MLRO
Operational staff
Controls risk: establishes clear accountability for complaint logging, investigation, and escalation, ensuring FCA DISP compliance and proportionate oversight.
Review
This policy is reviewed annually, or earlier if regulatory or operational changes affect complaint-handling obligations.
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