Complaints policy

1. Purpose
The purpose of this Complaints Policy is to provide a fair, transparent, and consistent process for receiving, investigating, and resolving complaints raised by clients, learners, employees, contractors, suppliers, partners, and other interested parties. Hemsley Fraser is committed to addressing concerns promptly, professionally, and objectively, using feedback and complaints as opportunities to improve our products, services, processes, and overall stakeholder experience.

2. Scope

This policy applies to all Hemsley Fraser Group entities and offices operating within the United Kingdom, United States, Germany, and Switzerland. It applies to all employees, contractors, consultants, agency workers, suppliers, business partners, associates, learners, clients, and any other individuals or organisations that receive, use, support, or contribute to the delivery of Hemsley Fraser products and services.

This policy covers complaints relating to Hemsley Fraser's products, services, business activities, employees, representatives, and operational processes. It also applies to information and assets within the scope of Hemsley Fraser's Information Security Management System (ISMS), including systems and applications covered by ISO 27001, as well as personal data processed in accordance with applicable data protection and privacy legislation in the jurisdictions where Hemsley Fraser operates.

Complaints involving the collection, use, storage, sharing, transfer, retention, or disposal of personal data will be handled in accordance with applicable laws and regulations in the jurisdiction concerned, including:
•    United Kingdom: UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018, and the Data (Use and Access) Act 2025 (DUAA). 
•    Germany: European Union General Data Protection Regulation (EU GDPR), the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG), and any applicable state-level privacy requirements.
•    Switzerland: Federal Act on Data Protection (FADP) and associated implementing ordinances.
•    United States: Applicable federal, state, and sector-specific privacy and consumer protection laws, including state privacy legislation where relevant to the complaint.

Where local legal, regulatory, contractual, or statutory requirements impose higher standards or additional obligations than those contained within this policy, those local requirements shall take precedence. Hemsley Fraser will investigate and manage complaints in a manner that is fair, consistent, confidential, and compliant with applicable legal and regulatory obligations across all jurisdictions in which it operates.

3. How to raise a complaint

Hemsley Fraser is committed to providing a fair, accessible, and transparent complaints process for all interested parties. Complaints may be raised by clients, learners, employees, contractors, suppliers, partners, associates, or any individual or organisation affected by our products, services, or business activities.

A complaint should, where possible, include the following information:
•    Expression of Dissatisfaction – A clear statement describing the concern, issue, or dissatisfaction experienced.
•    Reason for the Complaint – Relevant details, including what happened, when it occurred, and why the outcome is considered unsatisfactory.
•    Desired Resolution – The outcome sought, such as corrective action, clarification, improvement, apology, or other form of resolution.

Complaints may be submitted through any of the following channels:

• Via the Hemsley Fraser service desk or approved support platform, where applicable.

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  By email to the relevant department or to compliance@hemsleyfraser.com.

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  Through the contact form available on the Hemsley Fraser website.

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  Directly to a Hemsley Fraser representative, manager, or account contact, who will ensure the complaint is routed to the appropriate person for review.

  All complaints will be handled professionally, impartially, and, where appropriate, confidentially. Hemsley Fraser encourages concerns to be raised as soon as reasonably practicable after an issue is identified to support a timely investigation and effective resolution. While complaints can be submitted at any time, we recommend that they are raised within one month of the individual becoming aware of the issue wherever possible.

  Hemsley Fraser will not tolerate retaliation against any individual who raises a complaint in good faith and is committed to ensuring that all complaints are considered fairly, objectively, and in accordance with applicable legal and regulatory requirements.
  
  

4. Acknowledging complaints

Hemsley Fraser is committed to ensuring that all complaints are acknowledged promptly and handled in a professional, consistent, and transparent manner.

We will acknowledge receipt of a complaint within one business day (24 working hours) of receiving it. The acknowledgement will confirm that the complaint has been received, provide details of the person or team responsible for managing the complaint where appropriate, and outline the next steps in the process.

Where possible, responses and updates will be provided through the same communication channel used to submit the complaint. However, Hemsley Fraser may use an alternative communication method where necessary to support the investigation, protect confidentiality, improve accessibility, or ensure the most effective resolution of the complaint.

All complaints will be recorded, reviewed, and managed in accordance with this policy and any applicable legal, regulatory, or contractual requirements. Where additional information is required to investigate the complaint, the complainant may be contacted to provide further details.

5. Response time

Hemsley Fraser is committed to resolving complaints as quickly and effectively as possible while ensuring that all concerns are investigated thoroughly and fairly.

We aim to provide an initial response within two business days (48 working hours) of acknowledging a complaint. This response may include a resolution, a request for further information, or confirmation that an investigation is underway.

The time required to fully investigate and resolve a complaint will depend on its nature, complexity, and severity. While most complaints will be resolved within 10 business days, some matters may require additional time, particularly where multiple parties are involved, detailed fact-finding is required, or legal, regulatory, or contractual considerations apply.

Where a complaint cannot be fully resolved within 10 business days, we will provide an interim update outlining:
•    The status of the investigation.
•    Any actions taken to date.
•    Any further information required.
•    The anticipated timeframe for a final response.

Throughout the process, Hemsley Fraser will keep complainants appropriately informed of progress and will provide a final outcome as soon as reasonably practicable. Where local legal or regulatory requirements specify different response times, those requirements will take precedence.

6. Investigation and Resolution process

All complaints will be reviewed objectively, fairly, and in accordance with Hemsley Fraser's values, policies, and applicable legal and regulatory requirements.

Upon receipt of a complaint, Hemsley Fraser will:
•    Assess the nature, severity, and potential impact of the issue raised.
•    Assign the complaint to an appropriate individual or team with the authority and competence to investigate the matter.
•    Gather relevant information and evidence, which may include reviewing records, documentation, communications, systems, contracts, policies, and procedures.
•    Consult with relevant employees, contractors, suppliers, clients, or other stakeholders where necessary.
•    Identify the root cause of the issue and determine any corrective, preventive, or improvement actions required.
•    Escalate the complaint where appropriate to senior management, the Compliance function, Executive Leadership Team, or Board representatives.

Throughout the investigation process, Hemsley Fraser will maintain appropriate records of the complaint, investigation activities, findings, decisions, and actions taken.

Where an investigation remains ongoing, the complainant will receive periodic updates regarding:
•    The current status of the complaint.
•    Actions taken to date.
•    Any additional information required.
•    Anticipated timescales for completion.

Following completion of the investigation, a final outcome will be communicated to the complainant, together with any remedial actions, improvements, or lessons learned that are considered appropriate to share.
Hemsley Fraser views complaints as an opportunity to improve its products, services, processes, and stakeholder experience and will use complaint trends and outcomes to support continual improvement across the organisation.

7. Communication of outcome

Once the investigation has been completed, Hemsley Fraser will communicate the outcome of the complaint to the complainant in a clear, timely, and professional manner.

The outcome communication will include:
•    A summary of the complaint and the matters investigated.
•    The findings of the investigation.
•    The decision reached and the reasons for that decision.
•    Any corrective actions, remedial measures, or service improvements identified as a result of the investigation.
•    Details of any further actions available to the complainant, including escalation options where applicable.

Where a complaint is upheld, Hemsley Fraser will explain the resolution being offered and any corrective actions that will be taken to address the issue and minimise the likelihood of recurrence.

Where a complaint is partially upheld, we will clearly explain which aspects of the complaint have been substantiated and any actions arising from those findings.  

Where a complaint is not upheld, we will provide a clear explanation of the evidence considered and the rationale for our decision.

Our objective is to ensure that complainants understand the outcome of the investigation, feel that their concerns have been considered fairly and objectively, and have confidence that appropriate action has been taken where required. Complaints and their outcomes may also be used to identify trends, lessons learned, and opportunities for continual improvement across Hemsley Fraser's products, services, and business operations.

8. Appeals and Escalation process

Hemsley Fraser is committed to ensuring that all complaints are handled fairly, consistently, and objectively. If a complainant is dissatisfied with the outcome of a complaint, they may request a formal review of the decision through the appeals process.

Appeals must be submitted in writing to compliance@hemsleyfraser.com and should clearly explain the reasons why the complainant believes the complaint outcome, investigation, or resolution was inappropriate, incomplete, or inconsistent with the facts presented.

Upon receipt of an appeal, the matter will be reviewed by the Head of Compliance, or an appropriately independent senior representative where the Head of Compliance has been involved in the original investigation. The review will assess:
•    Whether the complaint was handled in accordance with this policy and any applicable procedures.
•    Whether the investigation was conducted fairly, objectively, and proportionately.
•    Whether all relevant evidence was considered.
•    Whether the outcome and any corrective actions were reasonable and appropriate.
Where the review identifies procedural concerns, conflicts of interest, new evidence, or other significant issues, the complaint may be escalated to a member of the Executive Leadership Team or the Board for further consideration.

Hemsley Fraser aims to provide an outcome to an appeal within 15 business days of receipt. Where this is not possible, the appellant will receive an update outlining:
•    The status of the appeal review.
•    The individual responsible for managing the appeal.
•    The reasons for the delay.
•    The anticipated date for a final decision.
The outcome of the appeal will be communicated in writing.

Where an appeal is upheld, Hemsley Fraser will explain any revised findings, decisions, corrective actions, or other measures that will be implemented as a result of the review.

Where an appeal is not upheld, the original complaint outcome will remain unchanged. The final response will include an explanation of the findings and rationale supporting the decision.

The outcome of the appeal represents the conclusion of Hemsley Fraser's internal complaints process. Any further action available to the complainant will be subject to applicable contractual, regulatory, statutory, or legal rights within the relevant jurisdiction.

9. Complaint Records and Confidentiality 

Hemsley Fraser maintains a centralised complaints management process to ensure that complaints are recorded, managed, and monitored consistently across all business operations.

All complaints will be logged and categorised according to their nature, severity, potential impact, and associated risk. Where complaints are submitted through designated service management or support platforms, an appropriate priority level may be assigned to support effective handling and resolution.

Information relating to complaints will be processed in accordance with applicable data protection and privacy legislation in the jurisdictions where Hemsley Fraser operates, including the UK GDPR, Data Protection Act 2018, Data (Use and Access) Act 2025 (DUAA), EU GDPR, Swiss Federal Act on Data Protection (FADP), and applicable United States privacy laws where relevant.

The complaints register will be maintained securely with access restricted to authorised personnel who require access for legitimate business, compliance, legal, or regulatory purposes. Records may include:
•    Complaint reference number.
•    Date received and acknowledgement date.
•    Details of the complainant.
•    Nature and category of the complaint.
•    Investigation activities and findings.
•    Decisions and outcomes.
•    Corrective or preventive actions implemented.
•    Date of closure.

Each complaint will be assigned a unique reference number to support tracking, reporting, and auditability throughout the investigation and resolution process.

Hemsley Fraser will take appropriate technical and organisational measures to protect the confidentiality, integrity, and availability of information relating to complaints. Any records containing personal, confidential, or sensitive information will be handled on a need-to-know basis and protected in accordance with applicable legal, regulatory, contractual, and information security requirements.

Complaint records will be retained in accordance with Hemsley Fraser's Records Retention Schedule and applicable legal, regulatory, and business requirements. Upon expiry of the applicable retention period, records will be securely archived or disposed of using approved methods.

Where permitted by applicable law, complainants may request access to information relating to their complaint during the investigation process or after closure, subject to any legal, regulatory, confidentiality, or privacy obligations.

10. Continual Improvement

Hemsley Fraser is committed to continually improving the effectiveness of its complaints management processes, products, services, and stakeholder experience. Complaints are recognised as a valuable source of feedback and insight, helping the organisation identify opportunities to strengthen controls, enhance service delivery, mitigate risks, and improve customer satisfaction.

Complaint trends, root causes, outcomes, and corrective actions will be periodically reviewed by management to identify recurring issues, emerging risks, and opportunities for improvement. Where appropriate, lessons learned from complaints will be used to improve policies, procedures, training, operational processes, products, and services across the organisation.

This policy will be reviewed regularly, and at least annually, to ensure it remains effective, relevant, and aligned with Hemsley Fraser's business objectives, stakeholder expectations, legal obligations, and regulatory requirements in all jurisdictions in which it operates.

Hemsley Fraser is committed to maintaining high standards of governance, information security, privacy, and compliance. Information relating to complaints will be managed in accordance with applicable legal, regulatory, and contractual requirements, ensuring that records are accurate, reliable, secure, and fit for their intended purpose.

By monitoring complaint outcomes and implementing continual improvement activities, Hemsley Fraser aims to enhance stakeholder trust, promote accountability, and demonstrate its commitment to delivering high-quality products, services, and business practices.

Last updated 25/06/2026