MDRN-FX Services Limited t/a Alpha Transfers
1. Purpose
The purpose of this Policy is to ensure that complaints concerning MDRN and its Services are identified, acknowledged, investigated and resolved fairly and promptly, and that customers receive clear information about the outcome of their complaint and any available escalation route.
MDRN is committed to the Financial Conduct Authority's Consumer Duty where it applies. In handling complaints, MDRN will seek to deliver good customer outcomes, including through clear and fair communications and appropriate customer support.
2. Scope
This Policy applies to complaints made by customers about MDRN's Services. It applies to all employees and other persons involved in receiving, investigating, responding to or overseeing customer complaints on behalf of MDRN.
For the purpose of this Policy, a complaint is an expression of dissatisfaction about MDRN's service which the customer wishes MDRN to investigate and resolve.
3. How a customer may make a complaint
Customers should be directed to submit complaints to MDRN by email at:
Where a member of staff receives a complaint through another customer contact channel, the complaint must be passed promptly to the person or team responsible for complaints handling so that it can be managed under this Policy.
4. Information to obtain from the customer
To help MDRN investigate the complaint, the customer should be asked to provide, where applicable:
- their full name;
- the telephone number and email address associated with their account;
- their company name, where they hold a business account;
- what the complaint is and when the problem arose;
- a description of the issue;
- the date the problem arose; and
- how they would like MDRN to put the matter right.
A complaint should not be delayed unnecessarily solely because some information is missing. Where further information is needed, MDRN may contact the customer to obtain it during the investigation.
5. Complaint registration and ownership
On receipt, the complaint should be recorded internally and assigned to an appropriate complaints handler. The record should be sufficient to identify the customer, the issue complained of, the date received, the applicable response deadline, the current status and the final outcome.
The complaints handler is responsible for progressing the complaint, requesting any further information required and ensuring that the applicable response deadline is monitored.
6. Acknowledgement
MDRN will acknowledge the complaint within three (3) Business Days of receipt and will tell the customer when they can expect a response. The acknowledgement may also request further information where this is needed to investigate the complaint.
7. Investigation and resolution
MDRN will aim to investigate and resolve complaints as quickly as possible. The investigation should be fair, objective and proportionate to the issue raised.
The complaints handler should, as appropriate:
- review the complaint and the outcome requested by the customer;
- review relevant account, payment, transaction, correspondence and system information;
- obtain information from relevant MDRN staff or service providers where necessary;
- contact the customer if additional information or clarification is required; and
- determine the complaint outcome and any appropriate remedial action.
8. Response timeframes
The maximum response timeframe depends on the nature of the complaint:
| Complaint type | Maximum response time | Additional requirement |
|---|---|---|
| Payment services-related complaint | Up to 15 Business Days | If exceptional circumstances apply, the response may take up to 35 Business Days and the customer must be notified. |
| Non-payment related complaint | Up to 8 weeks | The complaint should be resolved earlier where possible. |
Exceptional payment services cases. Where MDRN cannot provide its final response to a payment services-related complaint within 15 Business Days because exceptional circumstances apply, the customer must be notified and the final response must be provided no later than 35 Business Days after receipt of the complaint.
9. Final Response Letter
Once the investigation is complete, MDRN will send the customer a Final Response Letter. The Final Response Letter will include:
- a summary of the complaint;
- MDRN's investigation findings and decision; and
- where applicable, details of how the customer may refer the complaint to the Financial Ombudsman Service.
The Final Response Letter should be written in clear language and should explain the outcome sufficiently for the customer to understand MDRN's decision.
10. Financial Ombudsman Service
Where the customer is an eligible complainant and the complaint falls within the Financial Ombudsman Service's jurisdiction, the customer may be able to refer the complaint to the Financial Ombudsman Service if they are not satisfied with MDRN's final response.
Eligible complainants may include an individual customer, a small business or Micro-Enterprise, a Charity or a Trust, depending on the applicable eligibility criteria and the Financial Ombudsman Service's jurisdiction.
Financial Ombudsman Service information: www.financial-ombudsman.org.uk
11. Other escalation routes
Where the customer is not an eligible complainant, the complaint does not fall within the Financial Ombudsman Service's jurisdiction, or the customer does not wish to refer the matter to the Financial Ombudsman Service, the customer may pursue the matter through the courts in accordance with the applicable contractual terms.
12. Internal responsibilities
| Role | Responsibility |
|---|---|
| All staff | Recognise complaints and route them promptly to the complaints handling function. |
| Complaints Handler / Compliance | Acknowledge, record, investigate, communicate with the customer, monitor deadlines and prepare the Final Response Letter. |
| Senior Management | Provide appropriate oversight of the complaints handling process and support resolution of material or escalated matters. |
13. Complaint handling workflow
| Stage | Action | Timing |
|---|---|---|
| 1. Receipt | Identify the complaint and route it to the complaints handler. | Promptly |
| 2. Acknowledge | Confirm receipt and expected response timing; request further information if needed. | Within 3 Business Days |
| 3. Investigate | Review facts, records and relevant information and determine outcome. | As quickly as possible |
| 4. Payment-services response | Issue final response, or notify the customer if exceptional circumstances require more time. | 15 Business Days; maximum 35 Business Days in exceptional circumstances |
| 5. Other complaint response | Issue final response. | Up to 8 weeks |
| 6. Final response | Set out complaint summary, findings/decision and FOS information where applicable. | At conclusion of investigation |
14. Governance and review
Compliance is responsible for maintaining this Policy and ensuring that the complaints handling process remains aligned with MDRN's customer-facing terms. Any material change to the complaints provisions in those terms should be reflected in this Policy.