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Retail Client Complaint Policy

1. Introduction

The company has an obligation to address client complaints. Policies and procedures regarding retail client complaints relate to three activities: internal complaint handling, Ombudsman file handling and dispute follow-up.

2. Policy

The company adopts the following principles for handling retail client complaints:

Commercial department on the front line, Compliance Officer on the back line

Complaints are initially handled by the commercial department, which can at any time transfer the file to the Compliance Officer. The Compliance Officer may, on his own authority, take over the handling of a complaint.

Prompt handling of the complaint

The company makes every effort to ensure that a client's complaint is dealt with as quickly as possible and that a definitive response is provided as quickly as possible.

Systematic reporting

All employees, regardless of their responsibilities or areas of expertise, practice systematic reporting of complaints.

Listening to and understanding the client's needs

Throughout the process of handling the client's complaint, the company makes sure to identify the client's request and needs behind the complaint.

3. Procedures

3.1. Complaint handling

Notion of complaint

A complaint is a written statement from a client or a person with standing (e.g. owner, co-owner, agent, lawyer) that the client is not satisfied with the services provided by the company.

The company does not consider a simple question or request for information as a complaint (file to be processed by the client service collaborator).

The sales department is primarily responsible for handling client complaints. It may instruct the Compliance Officer to handle a complaint. The Compliance Officer may also take over the handling of a complaint on his own authority.

Written procedure

The complaint procedure is a written procedure. The sales department will therefore only follow up on a letter, fax or e-mail (provided that the e-mail address used is the one listed in the client identification).


Complaints are kept in a separate file to which the sales department and the Compliance Officer have access at all times. The complaint tracking table is then completed by the commercial department as follows:

Table fields


Complaint number




Client account




Company theme


MiFID theme




Date complaint received by the company


Date complaint received by the Commercial Department


Date of sending acknowledgement of receipt to the client


Date answer sent to client




Financial impact for the company




Suggestion for improvement




As soon as a complaint is received, the person in charge of the complaint in the commercial department communicates it without delay to the Compliance Officer, attaching all the information and documents received.

The following time limits must be met in processing a complaint:

Processing the complaint

The various elements that must be taken into consideration for the proper handling of a complaint are:

The complaint manager of the commercial department may call upon other departments to help prepare the handling of the complaint (e.g., assistance in defining the problem, collection of relevant documents and evidence).

While the handling of a complaint generally does not require the use of in-house counsel, some sensitive complaints may require consultation with, or even a response from, in-house counsel.

The complaint manager of the commercial department responds to complaints in a clear, simple and easy to understand manner.

Retention of complaint records

Each complaint file is stored electronically in an individual file containing all complaints in the company's IT system. In particular, a complaint is recorded and handled via the "Case" object.

3.2. Dealing with files from the Ombudsman

The Compliance Officer is the only person competent to deal with cases coming from the Ombudsman. Cases coming from the Ombudsman are only admissible if they have first been the subject of a complaint. If this is not the case, the department will write to the Ombudsman stating that the case is inadmissible and giving the reason.

The procedure before the Ombudsman is a written procedure, but the Ombudsman may establish telephone contact to clarify any point in the case.

An "Ombudsman & Litigation Files Report" file containing the cases referred to the Ombudsman or litigation is completed. This report is structured as follows:

A case only disappears from this file when it is closed.

The Ombudsman will receive a response within one month of receiving the case.

Particular attention is paid to the consistency between (i) the response sent to the client in the context of the handling of her complaint and (ii) the response to be sent to the Ombudsman.

While the handling of a case from the Ombudsman does not generally require the use of in-house counsel, some sensitive cases may require consultation with or a response from in-house counsel.

An electronic version of the correspondence exchanged in this context is kept.

3.3. Litigation follow-up

Litigation follow-up is done in collaboration with the company's lawyers (i.e. different law firms depending on the subject matter of the litigation).

As soon as a subpoena is received, an e-mail is sent immediately to the company's lawyers with the subpoena attached, as well as any useful exhibits and evidentiary documents, and any information that may be useful in understanding the case.

Timeframes for submissions and hearing dates are listed in both the relevant section of the "Ombudsman & Litigation Files Report" and in the calendar of the manager of the case in the company.

The manager of case in the company, together with the lawyer, ensures consistency between (i) any correspondence exchanged in the context of a complaint / prior Ombudsman file and (ii) the submissions to be drawn up in the context of the litigation.

3.4. Reporting

Internal reporting

The Complaints Manager of the Commercial Department makes a monthly written internal report to the Compliance Officer.

The Compliance Officer reports quarterly to the Executive Committee.

External reporting

The Compliance Officer reports to the FSMA. This report is related to MiFID complaints and shall be sent to FSMA every year by June 30, including the data as of December 31 of the previous year.

3.5. Collaboration with the risk management function and internal audit

In order to learn as much as possible from the complaint files, the Compliance Officer makes his reports available to the Executive Committee, the Board of Directors and the Internal Auditor.

3.6. Lawyers' reporting letters

At the beginning of the year, the Compliance Officer must contact all the lawyers defending the company's interests to request a reporting letter, i.e. a letter in which the lawyers present, for each case, a brief description of the current situation of the litigation, the amounts involved and the grounds for the action, an estimate of the probable outcome of the case and its financial stakes, as well as any other information likely to have an influence on the company's financial situation.

3.7. Modification and update

The Executive Committee reserves the right to update the policy and procedures regarding retail client complaints in accordance with legal requirements.

3.8. Monitoring compliance with policies and procedures

The Compliance Officer is responsible for enforcing this policy and implementing these procedures within the company.


Easyvest is a brand of EASYVEST NV/SA, with company number 0631.809.696, authorized and regulated by the Belgian Authority for Financial Services and Markets (FSMA) as a portfolio management company and as a broker in insurances, with registered office at Rue de Praetere 2/4, 1000 Brussels, Belgium. Copyright 2024 EASYVEST NV/SA. Past performance is no guarantee of future results. Any historical returns, expected returns, or probability projections may not reflect actual future performance. All securities involve risk and may result in loss.