Customer Complaints Policy & Procedures

Finco Treasury Management Ltd. Customer Complaints Policy & Procedures

Part A: General

1. Overall Objective of Finco Treasury Management Ltd. Customer Complaints Policy & Procedures

Finco maintains this Complaints Handling Policy and Procedures in order to provide for the fair, reasonable, effective and prompt handling of complaints by clients.

Clients may request a copy of this document at any time.

This Policy and Procedures, as amended from time to time, is published on Finco’s website www.fincotrust.com

Finco shall periodically, but no longer than annually, review this Policy and Procedures to ensure that it remains updated. A version control log shall be maintained in order to determine when updates were made or whether the policy has been reviewed regularly.

This Version of the Policy and Procedures has been approved by the Board of Directors on 16^th June 2026.

2. Complaints Handling Officer

Investor may freely contact the Complaints Handling Officer of Finco with regard to any issues affecting his Portfolio, in particular the delivery of the service or in relation to any financial instrument.

In terms of this Finco Policy, the Complaints Handling Officer is granted all support, resources and independence to fulfil his duties in terms of law. The Complaints Handling Officer has the necessary authority and capability to conduct impartial investigations and to identify and appropriately manage potential conflicts of interest.

As of 20^th August 2026 the Complaints Handling Officer of Finco is Adv. Antoine Demicoli.

Part B: Interaction with Complainants, Complaints Received and their Investigation and Resolution

1. Submission of Complaints

Complaints may be submitted to the Complaints Handling Officer who may be contacted in any one of the following manners:

personal contact on a face-to-face basis;
or on phone number 2122-0002 or 2124-8179 specifically requesting to be passed on to Complaints Handling Officer at any time from Monday to Friday between 9 am and 5 pm.

In such a case of a complaint by telephone, Finco will forward a written summary of the complaint to the complainant’s preferred mode of being contacted wherein the complainant will be requested to confirm, by signing a duplicate of the letter, that the compliant summary represents a true and fair description of the complaint.
or by postal mail addressed as follows:

The Complaints Handling Officer
Finco Treasury Management Ltd
Office 2, The Bastions,
Floriana FRN 1281
or by e-mail on an address exclusively available to the Complaints Handling Officer on complaintsmanager@fincotrust.com

2. Details to be included when registering a complaint

When lodging a complaint, clients are requested to include the following information:

Name and address
Portfolio Number
ID Card Number
A clear description of the complaint in the language of preference of complainant
Copies of any relevant documents, if any.

The above information will assist Finco Treasury Management Ltd in resolving its investigation in the shortest time possible.

3. Distinguishing Complaints from mere expression of dissatisfaction or relating to an administrative enquiry

The Complaints Handling Officer shall distinguish between matters requiring formal treatment and those that constitute mere misunderstandings or administrative enquiries. The latter do not qualify as formal complaints and hence need not be recorded in the Complaints Register and be subject to Finco’s Complaints Management procedures. These constitute simple enquiries or issues capable of being resolved immediately by the Head of Administration and therefore fall outside the scope of formal reporting.

At FTM, in fact, clients often call to “complain” about such administrative measures such as:

to report that, for example, they had not received the interest due, and which complaints are almost invariably explained after investigation and explanation as to what actually happened.

to complain that the debt security selected by the Relationship Manager has an inadequate interest. In such cases, most often the client would be limiting himself to the coupon of the bond without giving attention to the price and the resultant YTM.

This type of inquiry should not be treated as Complaints for the purpose of the Customer Complaints Function.

4. Acknowledgement of all Complaints

All complaints received by Finco, in whatever form, will be acknowledged in writing in the Maltese and / or the English language by the Complaints Handling Officer.

The Complaints Handling Function shall ensure that any “complaints” received that have not been considered by it as Complaints for the purpose of the Customer Complaints Function as per Para 5 have been dealt with satisfactorily and resolved to client’s full satisfaction.

5. Time Period for Investigation of Complaints and provision of Final Reply

Finco shall endeavour to investigate and resolve a client complaint as quickly as possible.

Finco shall provide a final reply to the complainant within 15 working days from receipt of the complaint.

In terms of Article 21A(1) of Chapter 555 of the Laws of Malta, Arbiter for Financial Services Act, if due to exceptional circumstances beyond Finco’s control, Finco is unable to provide a final reply to the complainant within such 15 working days, Finco shall:

(i) inform the complainant about the reasons for the delay, and
(ii) provide an indication as to when a final reply is likely to be provided.

In any case, a final reply shall be provided within 35 working days – equivalent to 7 weeks – from the receipt of a complaint in writing.

6. Provision of Information to Clients and Complainants

6.1 Web Site Disclosures

The Complaints Handling Function shall ensure that this Policy and Procedures document is published in a clear, prominent, and easily accessible manner on Finco’s website and that it is maintained updated.

6.2 Other Documentation

The Complaints Handling Function shall ensure that all other communications relating to complaints is clear, simple, and easily understandable language to ensure that clients can make informed decisions. This shall include brochures and other relevant documentation.

7. Final Response to Complainants & Right of referral to Arbiter for Financial Services

7.1 Where the outcome does not fully uphold the complainant’s position, the Complaints Handling Function must clearly explain its reasoning in declining the complaint, in full or in part.

Any explanations provided to clients, including those relating to the outcome of their complaint, must be sufficiently detailed, transparent, and easy for the customer to understand by using simple and plain language, enabling them to make an informed assessment of the investment firm’ s position.

7.2 Furthermore, contemporaneously with the advice of the final outcome, complainants must be advised of:

i. their right to refer the matter to the Office of the Arbiter for Financial Services whenever the complainant considers that the complaint has not been handled and investigated in a reasonable, effective, timely and appropriate manner or where Finco advises the client that the complaint is not considered justified or is unable to assist client further;
ii. what time limits may apply for bringing such a complaint to such dispute resolution mechanism. Hence clients of Finco are advised that they have a right to refer any complaint against it to the Arbiter for Financial Services provided that such a complaint is filed beforehand with Finco not later than two years from the day on which the complainant first had knowledge of the matters complained of.

7.3 Complainants are advised of The Arbiter for Financial Services’ contact details as follows:

Office of the Arbiter for Financial Services

New Street in Regional Road, Msida MSD 1920

Telephone: 2124-9245 or on Freephone 80 072 366