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Appointed Representative Complaints Policy

Luna Investment Management is an appointed representative of Thornbridge Investment Management LLP. As such, both Thornbridge and ourselves are required to have in place effective and transparent procedures for the reasonable and prompt handling of complaints in relation to the services we provide.

A. Our Commitment to You

Your experience of the services we provide is extremely important to us. Inevitably, however, there may be occasions when we fall short of the standards you expect. In such circumstances, we are committed to dealing with your concerns fairly and effectively. Our aim is to reach a mutually satisfactory conclusion as quickly as possible.

To assist, we have established procedures for investigating any complaint you may have with the intention of swiftly resolving any matter while at the same time keeping you fully informed of the steps we are taking.

B. Who We Are

Luna Investment Management is an Appointed Representative of Thornbridge Investment Management LLP (“Thornbridge”) who are authorised and regulated by the Financial Conduct Authority (“FCA”). Thornbridge’s FCA Firm Reference Number is 713859.

As such, both Thornbridge and ourselves are required to have in place effective and transparent procedures for the reasonable and prompt handling of complaints in relation to the services we provide.

As Thornbridge are our Principal firm, all complaints must be directed to them. They will then liaise with us to best handle any complaints received and comply with all our regulatory requirements.

C. How to Make a Complaint

We would encourage you to first to contact us by emailing TIM’s Compliance Officer, Patrick Hall, at compliance@thornbridge detailing your complaint or issue as best you can. You can also include your contact point at Luna Investment Management if you wish. If you’d prefer to write to us then please send your correspondence to:

Patrick Hall
Thornbridge Investment Management LLP
13 Austin Friars
London
EC2N 2HE

If you’d like to talk to us on the phone then you can reach us on +44 203 9724 510.

D. What Happens Next

Your complaint will be logged in our system and a designated Thornbridge team member will be allocated to handling your matter who will work with Luna Investment Management to resolve the complaint or issue.

We would like to assure you that the team member handling your complaint will be an experienced member of staff and, where appropriate, someone who was not directly involved in the matter about which you are raising a complaint. They will have the authority to settle your complaint or will have access to someone who has such authority.

E. Steps Towards Resolving Your Complaint

Step 1 – the designated team member will acknowledge receipt of your complaint, either by post or by email, within 3 business days and confirm who you should contact for further information and how you should contact them.

Step 2 – we will carry out a thorough investigation into your complaint at the conclusion of which we will prepare an incident report that will incorporate a complete breakdown of the matter and any conclusions that we have reached. You will receive a copy of this report.

Step 3 – we will invite you to provide your comments particularly if we have omitted something that you consider of relevance to the matter.

Step 4 – Thornbridge will provide you with a final response confirming our position on your complaint and setting out our conclusions. We, of course, anticipate being able to resolve every complaint satisfactorily but we will also provide contact details for the Financial Ombudsman Service (“FOS”) to enable you to escalate the matter if you are, in any way, dissatisfied (for further details, please see below).

F. Timings

We aim to resolve your complaint and issue our final conclusions within eight weeks of receiving your complaint. However, in exceptional circumstances, if we cannot give you a final response within that time period, we will contact you to let you know why not and to confirm when you can expect to receive a substantive response from us.

G. What Happens if You Are Not Satisfied with Our Response

Although you can contact the FOS at any time for guidance, they do require you to contact the firm in the first instance. If you remain dissatisfied with how we are handling your compliant or our final response, you may be eligible to refer your complaint to FOS. Although this service is free of charge, there are a number of conditions you should be aware of:

  1. You must contact them within six months of the date of our final response. If you do not, the FOS will not have our permission to consider your complaint and will only be able to do so in exceptional circumstances.
  2. The FOS only handles complaints raised by private individuals, micro-enterprises (businesses employing fewer than 10 persons whose annual turnover and/or annual balance sheet does not exceed EUR 2 million) and charities (whose annual income is less than £1 million).
  3. The FOS will only consider complaints about regulated products and services.
H. Complaint Records

Our regulator, the FCA, obliges us to keep a record of each complaint received and the measures taken for its resolution. We retain these records for a minimum of three years from the date the complaint was received.

I. FOS Contact Details

Financial Ombudsman Service
Exchange Tower
Harbour Exchange Square
London
E14 9SR
www.financial-ombudsman.org.uk

Telephone: +44 800 023 4567

Head Office

The Old Schoolhouse
5-7 Byrom Street
Spinningfields
M3 4PF

Telephone

0161 518 3500

The value of your investments may go down as well as up, and you could get back less than you invested.
The Defaqto 5 Star Rating applies to both the Luna Model and Bespoke Portfolio Services only.

Luna Investment Management Limited (FRN: 923454) is an appointed representative of Thornbridge Investment Management LLP (FRN: 713859) which is authorised and regulated by the Financial Conduct Authority. Luna Investment Management is registered in England. No 12280396