Complaints Policy

Argus Management Ltd ( the Company) maintains a Complaints Handling Policy which describes the appropriate actions to be taken for the resolution of complaints submitted by Investors of funds managed by the Company without undue delay. The objective of the Company's Complaints Handling Policy is to recognize, and protect Investors’ rights, including the right to comment and complain and provide an efficient, fair and accessible mechanism for resolving and recording Investors’ complaints.

We are committed to transparency and accountability. Our Complaints Handling Policy is outlined herein to ensure a fair and responsive resolution process, fostering trust and confidence with our Investors.

In its efforts to restore confidence in the complainant, the Company shall:

Always treat the complainant with tact, courtesy and fairness.

Always maintain appropriate confidentiality of the complaint.

Ensure that the complainant is not victimized or harassed due to the submission of a complaint against the Company.
The below constitutes a non-exhaustive list of examples for which Investors may place a complaint:

Complaint about fraudulent activities or misappropriation of subscribed funds.

Complaint about confidentiality.

Complaint about poor performance.

Complaint about excessive or incorrect charges.

Complaint about inaccurate statements or declarations made by the Company.

Complaint about the level of service that is being provided.

Dispute instructions or requests provided by an officer representing or servicing the Company e.g. execution of forms or confirmations.

Complaint about inaccurate or delayed reporting.

Complaint about a minor problem that occurs repetitively.

Submit allegations of bad faith, malpractice or impropriety.

It is emphasized that the purpose of the above list is to highlight common industry concerns. The Company acknowledges that various other issues may arise that are not mentioned in the above list, since complaints can vary widely depending on each Investor’s unique situation.

Investors are encouraged to openly share any complaint or issue not covered in the list.
An Investor may contact any officer of the Company and submit a formal written complaint or grievance, using either of the following means:

Via e-mail, either to the email address of a known contact person or to support@argusmanager.com; or

Through the completion of the relevant form found in the last section of this webpage; or

By post to 25 Demostheni Severi Avenue, Metropolis Tower, 4th Floor, 1080 Nicosia, Cyprus; or

Physically, at the Company’s premises that is situated at the above address, where a complaint is drafted with the assistance of Company officers.

It is essential that Investors follow the specific complaint submission process outlined in this section to ensure that the complaint reaches the appropriate officers for prompt and effective resolution. If an Investor complains over the phone or verbally during a meeting, then he or she shall be asked by the officer of the Company receiving the compliant to follow the predefined procedures and place the complaint in writing, as this practice shall facilitate the speedy identification of the appropriate action to be taken.
A formal complaint should contain essential information to ensure it can be properly addressed and investigated. The minimum, indicative, information that a formal complaint should have includes:

Contact Information: The complainant's full name, address, phone number, and email address should be provided to establish communication and verify the identity of the person lodging the complaint.

Date and Time: The date and time when the incident or issue occurred, if applicable, should be mentioned to provide a clear timeline for investigation purposes.

Description of Complaint: A detailed and specific description of the complaint is crucial. It should include the nature of the issue, the persons involved (if applicable), and any relevant supporting details to help understand the situation better.

Relevant Documentation: If there are any supporting documents, evidence or records related to the complaint, they should be attached or referenced to provide additional context and evidence for the investigation.

Desired Resolution: The complainant should clearly state their desired resolution or outcome they are seeking from the complaint process.

Witnesses (if any): If there were witnesses to the incident, their names and contact information should be provided to allow for independent corroboration of the events.

Signature (if applicable): If the complaint is placed via a letter delivered by post or drafted at the Company’s premises, a formal complaint may require the complainant's signature to validate its authenticity.
Assignment
Reference No.
Classification
Examination
Facts Verification
Resolution
Ratification
Communication
Final Actions
Assignment
Complaints are, upon receipt, forwarded to and assigned to a complaint processing officer (the Complaint Processing Officer) who is responsible to ensure that the complaint handling process is attended to until resolution. The role of the Complaint Processing Officer is assigned to the Company's Head of Regulatory Compliance, unless the complaint relates to the Head of Regulatory Compliance, or the Head of Regulatory Compliance has a conflict of interest, whereas in those cases the complaint is forwarded to the Chief Executive Officer.
Resolution
The Company requires that all complaints are resolved as soon as possible, depending on its importance and complexity.

Important or moderately important complaints must be resolved within fifteen (15) Business Days from the date the Company officers received the relevant complaint and complaints of extremely high importance within three (3) months.

This may not always be possible, as sometimes the complexity of the complaint may require more time to be fully investigated. If the Complaint Processing Officer is unable to resolve the complaint within the predefined fifteen (15) Business Days or three (3) months (depending on the importance) of receipt, the complainant is contacted to explain why the Company is not in a position to resolve the complaint within the given timeframe and provide an indication of a finalization timeframe.

If the resolution period exceeds the timeframe of three (3) months, a letter signed by the Chief Executive Officer is sent to the complainant, three (3) months after the receipt of the formal complaint with information on the procedure to be followed.

It is provided that, throughout the investigation of the complaint, the Complaint Processing Officer informs the complainant of any progress and status, where deemed necessary.
Complaint Reference Number
Upon receiving the complaint, the Complaint Processing Officer registers the complaint in a complaints book/register (the Complaints Book) and assigns a 10-units unique reference number to the complaint for tracking purposes. The unique reference number is communicated to the complainant. The Complaint Processing Officer informs the complainant that the said reference number should be used in all future communication with the Company, the Financial Ombudsman and/or CySEC regarding the specific complaint. The complaint reference number is communicated to the complainant within five (5) Business Days.
Complaint Classification
The Complaint Processing Officer exercises critical thinking and classifies the matter in one (1) of the below categories:

Extremely Important – may refer to allegations of fraudulent activities, misappropriation of subscribed funds, confidentiality matters, bad faith etc.

Important – may refer to complaints about poor performance, inaccurate statements, or excessive/inaccurate charges.

Moderately Important – may refer to service experience, delayed reporting and others.

Examination of the Complaint
The Complaint Handling Officer reviews the complaint and determines whether there is sufficient information to proceed with resolving it or if further information is required. Additional information or clarifications may be requested from the complainant or stated witnesses and interviews with involved officers of the Company or of a provider servicing the Company may be taken.

Complaints classified as extremely important are communicated to the Board of Directors which has the absolute discretion of resolving to additional measures and actions that may be deemed necessary for the proper resolution of the complaint.
Final Actions
If a complaint has been resolved, the Company should take every action to ensure that the complainant is satisfied and that the complainant’s satisfaction is recorded. Once the issue is resolved, all relevant documents and information are sent to the Head of Regulatory Compliance (if not the same with the Complaint Processing Officer) for archiving and updating the Complaints Book. The Board of Directors is informed accordingly at the next scheduled Board meeting.

In addition, our Head of Risk Management analyses, on an on-going basis, complaints-handling data, to ensure that any recurring problems and potential legal and operational risks are identified and dealt with. Useful findings and data may be extracted by:
(a) Analysing the causes of individual complaints to identify the root causes common to each type of complaint; or
(b) Considering whether such root causes may also affect other processes, including those not directly referred to in a complaint; or
(c) Correcting, where reasonable to do so, such root causes.
Communication
The Complaint Processing Officer, or one of the Chief Executive Officer if deemed more appropriate, communicates with the complainant to address the subject. The Company’s final response will advise of its findings and, where appropriate, what action has or will be taken to resolve the matter. The resolution is communicated in writing and uses plain language that is clearly understood.
Action Ratification
The action recommended by the Complaint Processing Officer for resolving the matter is communicated to the Chief Executive Officer who bears the responsibility of ratifying, rejecting or altering it. Complaints classified as extremely important are ratified by the Board of Directors. Where the complaint is upheld, the Company must ensure that it will offer a resolution that is consistent with treating all Investors of the specific AIF fairly.
Financial Ombudsman
Court
CySEC
Financial Ombudsman
The complainant can refer a complaint to the Financial Ombudsman if the complainant is dissatisfied with the assessment and ruling of the Company, provided that:

The complaint does not relate to an amount exceeding €170,000.

The Investor first files a formal complaint to the Company within fifteen (15) months from the date that the Investor is aware or ought to be aware that the reason of the compliant has occurred.

The Investor submits the complaint to the Financial Ombudsman within four (4) months from the date the Investor received the Company’s final response or from the closing date the Company ought to provide it to the Investor, if the Investor did not receive the Company’s final response.

No judgement has been issued from a Court for the same complaint or no judicial procedure is pending for the examination of the same complaint.

The complainant should ensure that the unique reference number provided by the Company is is referred to when addressing a formal complaint to the Financial Ombudsman. The contact details of Financial Ombudsman are as per below:

Name: Financial Ombudsman of the Republic of Cyprus

Address: 13 Lord Byron Avenue, 1096 Nicosia, Cyprus

Phone: +357 22 848900

Fax: +357 22 660584, +357 22 660118

Email address: complaints@financialombudsman.gov.cy

Website: http://www.mcit.gov.cy/ccps

Send us your Feedback

In case you are a subscribed Investor in one of the funds managed by Argus Management Ltd and you have a complaint to report, feel free to complete this Complaints Form.

We will attend to your report with undue delay and care.

Complaints Policy

Assignment

Resolution

Complaint Reference Number

Verification of Facts

Complaint Classification

Examination of the Complaint

Final Actions

Communication

Action Ratification

Financial Ombudsman

Court

CySEC

Send us your Feedback

Complaints Form

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