Complaints Procedure

Van Sterling Capital Ltd (the “Company”) is committed to handling any complaint promptly, fairly and free of charge. This page sets out the procedure to be followed if you wish to submit a complaint in relation to any service provided by the Company in connection with security tokens distributed on smarter-investments.com. The full internal Complaints Handling Procedure of the Company is available to the Malta Financial Services Authority on request and is summarised below for the benefit of clients and prospective clients.

How to submit a complaint

You may submit a complaint to the Company in writing, by email, by post or by telephone. While a written complaint allows the Company to investigate your case more efficiently, the use of any particular form is not a condition for the validity of a complaint, and the Company will reduce any oral complaint to writing for the purpose of its complaints register.

To assist us in handling your complaint as efficiently as possible, we invite you to use the Company’s Complaint Form, which you may download from this page, complete and return to us. If you prefer to submit your complaint in free form, please make sure that your communication includes, as a minimum, your full name, your contact details, a sufficiently clear description of the matter, the service or security token to which the complaint relates, and copies of any documents that support your complaint.

Where to send your complaint

Van Sterling Capital Ltd
Nu Bis Centre
Mosta Road
LJA 9012 Lija
Malta

By email: complaints@vansterling.com
By telephone: +356 27 289 615

How your complaint will be handled

The Company will acknowledge receipt of your complaint in writing within five business days of receipt. The complaint will be investigated by the Compliance Officer, who is independent of the staff involved in the matter complained of, in cooperation with the relevant departments and, where necessary, with the assistance of external legal advisers.

The Company will endeavour to provide you with a final response within fifteen business days of receipt of your complaint. If, exceptionally and for reasons beyond the Company’s control, a final response cannot be issued within that period, the Company will inform you of the reasons for the delay and will indicate the date by which a final response will be provided; in any event, a final response will be issued at the earliest opportunity and in line with the timeframes set out in the Joint Guidelines of the European Supervisory Authorities on complaints handling.

The final response will set out the outcome of the investigation, the Company’s position on each of the issues raised in the complaint and, where appropriate, the redress that the Company is prepared to offer.

If you are not satisfied with our response

If you are not satisfied with the Company’s final response, or if no final response has been provided to you within the applicable period, you have the right to refer the matter, free of charge, to the Office of the Arbiter for Financial Services in Malta, an autonomous and independent body established under Act XVI of 2016 (the Arbiter for Financial Services Act). The contact details are:

Office of the Arbiter for Financial Services
N/S in Regional Road
Msida MSD 1920
Malta

Internet: https://financialarbiter.org.mt
Email: complaint.info@financialarbiter.org.mt
Free of charge: 8007 2366
Phone: +356 2124 9245

Data protection

The personal data which you provide to the Company in the context of a complaint will be processed by the Company solely for the purposes of receiving, investigating, responding to and recording the complaint, and for the purpose of complying with the Company’s legal and regulatory obligations. Further information on the processing of personal data is available in the Company’s Privacy Notice, which is published on smarter-investments.com.

Issued by Van Sterling Capital Ltd, MFSA Licence VANS-IF-9616.

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