Complaints Procedure

This is Amber (Isle of Man) Limited's complaints policy and procedure. This policy was last updated on 22nd April 2020.

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If you would like to raise a complaint please contact your usual client service manager directly or email clearly stating the nature of your complaint.

1. What Does this Policy Cover?
  • This Complaints Policy sets out the responsibilities of those who work for Amber (Isle of Man) Limited (or any of its subsidiaries) (“Amber”, “we”, “us” or “our”) with regard to observing and upholding our reputation and to ensure our clients are treated in a fair and consistent manner.
  • This Policy also exists to act as a source of information and guidance for those working for It helps them recognise and deal with complaints, as well as understand their responsibilities.
2. Policy Statement
  • We are very proud of our professional reputation and look to provide the best service possible. If a client should be unhappy with the level of service provided by us, we must ensure that this is dealt with as effectively and efficiently as possible. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships.
  • Every complaint is an opportunity for us to see Amber’s flaws through our clients’ eyes. It is a great opportunity to get feedback about things that may not be working right and to make corrections in that area to identify and remedy systemic or recurring problems. We will constantly uphold all regulation relating to complaints in all the jurisdictions in which we operate.
3. Who is covered by this Policy?
  • This Policy applies to all employees (whether temporary, fixed-term, or permanent or any of our subsidiaries, no matter where they are located. The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.
4. Definition of a Complaint
  • A complaint is any written or spoken expression of dissatisfaction with Amber in respect of a service provided or not provided as the case may be.
  • A complaint may be received in writing, over the phone or face-to-face.
  • If a member of our staff are unsure whether a matter should be treated as a complaint, it may be appropriate to ask the client whether they would like the matter treating as a formal complaint or not.
  • Our complaints procedure is not a method of examining legal issues, of re-considering cases upon which a decision has been made, or of querying technical issues. It is a means for clients to complain about procedural matters or the level of service received.
5. What happens if we receive a Complaint?
  • Any complaints received by any of our members of staff should be referred to the manager of the file as recorded on our internal systems.
  • Complaints in respect of fees should be settled, where possible, by the file manager. Where a credit note is to be required this will be subject to approval in the normal way.
  • On receiving a complaint, the file manager must as soon as possible:
    • Agree who within the department who will handle the complaint. The complaint handler should not be conflicted and should have appropriate authority to deal with the complaint.

    • Report the matter to our Head of Compliance, including the name of whom will handle the complaint. When reporting the matter to the Head of Compliance please include the following information:

      • The date the complaint was received;

      • Who made the complaint;

      • The name of the client and client company concerned;

      • A brief description of the complaint; and

      • Who will be dealing with or be responsible for the complaint.

  • The Head of Compliance will enter the case in our complaints register and advise the complaint handler of the reference number of the case in the register.

  • If the complaint contains a claim for damages or a threat of legal action, then our Legal Department should be notified without delay by the Head of Compliance. The respective directors of Amber will also consider whether professional indemnity insurers must be notified.

  • The complaint handler must commence a complaints checklist to control investigation of the complaint received. The checklist is available in the schedule to this Policy. The complaint register reference number should be entered on the checklist.

6. What happens if you are the Complaint Handler?
  • As a complaints handler you must ensure that you read, understand, and comply with the information contained within this policy, and with any training you are given.
  • The complaint handler will commence a complaints checklist to control investigation of the complaint received. As detailed on the complaint’s checklist, complaints must be acknowledged in writing within seven working days and be resolved as quickly as possible.
  • If the complaint is not resolved within seven working days to the satisfaction of the client, the acknowledgement must include:
    • A summary of the complaint;
    • Details of Amber’s complaints-handling procedures (for example a copy of this policy);
    • Whenever appropriate, a request for further details in writing, with supporting evidence; and
    • Advise of the existence of any local Ombudsman Scheme (where appropriate).
  • If the complaint is not possible to resolve quickly, the complaint handler needs to write to the client within eight weeks to advise of the progress and when the investigation will be completed.
  • If the investigation has not been completed within eight weeks please inform the Head of Compliance (including the reason why it has not been concluded).
  • The complaints handler must track the complaint to completion.
  • Once fully dealt with a copy of the completed complaints checklist should be sent to the Head of Compliance who will record the resolution of the complaint on the Complaints Register.
7. Record Keeping and Time Limits
  • Complaints must be acknowledged in writing within seven working days and be resolved as quickly as possible.

  • We should endeavour to complete our investigations of a complaint within eight weeks and send a resolution letter within this time period.

  • If the investigation has not been completed within eight weeks or looks like it will not be resolved within the eight-week timeframe, please inform the Head of Compliance as soon as possible. The Head of Compliance may then be required notify the local Regulator if applicable.

  • Our compliance department will keep and maintain the complaints register which is not under any circumstances to be made available to clients or the public.

  • The complaint handler will ensure the completed complaint checklist and any accompanying paperwork is recorded as part of the client’s records.

8. Monitoring and Reviewing
  • Our compliance department is responsible for monitoring the effectiveness of this Policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.
  • Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this Policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to our Head of Compliance.