Complaints Procedure 

Global Capital has a person designated as its Complaints Officer for matters relating to the execution of client orders (for matters relating to portfolio management and corporate finance the designated complaint officers are the respective heads of the two departments). 

The Complaints Officer works independently both from the back office and the front office/brokers. 

1. A client notifies the Company of his/her complaint either in writing (including email) or by phone. 
2. When a client calls the Company’s Offices to make a complaint, the call is forwarded to the Complaints Officer who records the time of the complaint. This is the time considered for establishing whether the complaint is made within 24 hours from the time that confirmation of transactions executed is delivered. 
3. The Complaint’s Officer asks the complaining client to put the complaint in writing and sign it before submission to Global Capital either by hand, fax, or mail. 
4. In cases where a complaint is made within 24 hours, the Complaints Officer is responsible for giving the Company’s response to the complaint, within 24 hours from the time of receipt of the written complaint. 
5. In cases where the client files a complaint after the 24 hours following transaction confirmation, the Complaints Officer will still give the Company’s response in due time; however the Company is not bound to respond within a certain time limit. 
6. In cases where the client complaint involves the Head Broker (HB), the Complaints Officer will make any reasonable effort to resolve the problem by directly talking with the Head Broker to obtain answers. 
7. The Internal Auditor (IA) will be notified and where necessary, the IA will be consulted or asked to participate in the handling of a complaint case. 
8. In cases where the client complaint does not involve the HB, the Complaints Officer will refer the complaint to the HB who will handle the case and discuss with the Complaints Officer regarding the Company’s appropriate response. 
9. If the Client is not satisfied with the Company’s response he may raise the matter with the Company’s Chief Executive Officer or its Board of Directors. 
10. The Company maintains a register of all complaints made including the date received, processing time and response time with a basic description of the complaint and the company’s response.