Complaints Handling Procedure
Purpose
To describe how Zeyro identifies, records, and resolves complaints in line with DISP 1.3–1.6 of the FCA Handbook. This procedure supports the ZYC-COMPL-001 Complaints Handling Policy and provides an auditable workflow in Jira Service Management.
Scope
Applies to all complaints received:
Direct complaints — about Zeyro’s services (MiFID-relevant).
Indirect complaints — about a client’s financial promotion approved by Zeyro (reportable under FCA returns).
Workflow (coded into Jira Service Management)
Issue type: Complaint
Stage
Purpose
Responsible
Notes / Automation
Intake
Complaint logged with essential details (complainant, category, received date).
Any staff member / MLRO
Auto-create “acknowledgement due in 1 day.”
Acknowledged
Confirmation sent to complainant.
MLRO
Starts 8-week final-response SLA.
Investigation
Review facts, collect evidence, coordinate with relevant teams or clients.
MLRO / operational lead
All notes and evidence uploaded to SharePoint and linked.
Response Drafted
Prepare proposed response and outcome.
MLRO
Peer-review optional for complex cases.
Final Response
Send outcome letter or summary to complainant.
MLRO
Automation logs closure date and creates entry in Complaints Register.
Closed
Case complete.
MLRO
Jira auto-archives issue; evidence retained 5 years.
Fields (Jira configuration)
Complainant name / email
Category:
Zeyro/Client PromotionMiFID relevance: Yes / No
Date received (auto-set on creation)
Acknowledgement sent (checkbox)
Final response due (auto = received + 8 weeks)
Outcome:
Upheld / Partially Upheld / Not Upheld / WithdrawnLinked Promotion (where relevant)
Evidence Links (SharePoint URLs)
SLAs
SLA
Target
Trigger
Owner
Acknowledgement
≤ 1 business day
Complaint logged
MLRO
Final Response
≤ 8 weeks
Acknowledged
MLRO
Escalation
Immediate
Alleged regulatory breach or financial loss
MLRO / Board
Automations
On creation → set 1-day acknowledgement target.
On “Acknowledged” → start 8-week SLA countdown.
On “Final Response” → create entry in Complaints Register (ZYC-REG-001) with outcome, category, and closure date.
If category = “Client Promotion” → notify relevant client and link to associated FinProm approval issue.
Evidence & Record Keeping
All communications and investigation notes are stored in SharePoint – Complaints Evidence.
Jira issue serves as the full audit trail (timestamps, comments, SLA events).
Records retained for 5 years minimum.
Reporting
Quarterly: MLRO summarises complaint volumes, outcomes, and trends for the Board.
Annually: Data exported from Jira Register to complete FCA Complaints Return.
Ad hoc: Serious or systemic issues escalated to FCA within 24 hours (SUP 15).
Review
This procedure is reviewed annually or following any regulatory or process change affecting complaints handling.
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