Complaints & Resolution Policy
Senior Manager Approval
Senior management has approved this Complaints & Resolution Policy to achieve and monitor our Company’s ongoing compliance with the requirements of the FCA and the implementing regulations under it, as well as maintaining a satisfied client base.
|AML/CFT||Anti-Money Laundering and Funding of Terrorism|
|AML Regulations||The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (SI 2017 No. 692)|
|UBO||Ultimate Beneficial Owner|
|Board of Directors||Board of directors of Berg Ltd|
|CDD||Customer due diligence|
|CTF||Counter Terrorist Funding|
|Company||BERG Limited [UK]|
|EEA||European Economic Area|
|FATF||Financial Action Task Force|
|KYB||Know your business|
|KYC||Know your customer|
|MLR||The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017|
|MLRO||Money Laundering Reporting Officer|
|NCA||National Crime Agency|
|PEP||Politically exposed person|
|POCA||Proceeds of Crime Act 2002|
|PSD2||Payments Services Directive 2|
|PSR||Payments Services Regulations|
|SAR||Suspicious Activity Reporting|
|TBD||To Be Determined|
The Berg company Complaints Policy is in line with the requirements of the Payment Services Directive [PSD] with regard to the following time frame:
Firms must give a full written response to complaints that involve rights and obligations under PSD2 within 15 business days, or 35 business days in exceptional circumstances.
Where Berg Money fails to resolve a client’s complaint within the 15 days time frame, or where the client feels that the complaint was not handled appropriately, (including cases where the complaint was not properly identified as a complaint), the client have the right to file a complaint to PayrNet if they believe that we provide our services improperly or our operations breach customers’ rights or legitimate interests. The filing of complaints and complaint handling process is free of charge at PayrNet.
PayrNet shall accept complaints submitted in person (directly to Customer Service employee, verbally or in writing), by regular or registered mail (sending it to PayrNet’s registered office or actual place of business: 138 Holborn, London, England, EC1N 2SW), email (at the address [email protected]) or through the digital channels provided by PayrNet’s online and mobile platforms.
Payrnet must be contacted in relation to the services directly provided by them, such as cards / ledgers.
Berg values complaints as they assist us to improve our products, services and customer service.
This policy has been designed to assist both customers and staff. Berg is fully committed to consistent, fair and confidential complaint handling and to resolving them as quickly as possible. We aim to make it easy for people to make a complaint if they are dissatisfied and we treat all customers making a complaint with a measure of care.
Berg generally manages complaints on two levels; participant complaints and client complaints. In both cases, the desire of Berg is to resolve the matter in a concise manner and well within the timelines defined by PSD2. While participant complaints are often based mainly in product-related issues, namely use of the e-wallet service, each interaction is handled with care by our operations staff; this may also require participation by other company departments depending on the type of issue that requires resolution. While the overall occurrence of participant related complaints will generally be low, our policy serves to show our unyielding commitment to customer services on all fronts.
In this, it is the policy of Berg to respond to participant complaints, disputes, and issues swiftly and to take each complaint seriously. Berg promotes a quick, decisive, and accurate response to all inquiries, questions and concerns brought to our attention. Not all these situations are in the form of a written complaint presented by a participant (collectively “Party” or “Parties”).
Berg has delegated the responsibility of monitoring and responding to (a) complaints of participants to the Customer Support Manager (b) complaints of clients to the dedicated Client Relations Managers. All written complaints will be directed to the corresponding department. The appropriate personnel will draft responses to Party and confirm the response with the appropriate supervisor. Every response is assigned a priority level and follow-up instructions.
Client-related complaints can often concern any number of business-related issues and therefore require a certain amount of flexibility in the handling of them. As such, this Complaint resolution policy document serves specifically to cover the guidelines surrounding the resolution of participant related complaints only.
3. Definition of a complaint
For the purposes of this Policy document, Complaints are defined as any expression of dissatisfaction or grievance made to staff by a participant.
4. RSS feed
4.1 You may access our RSS feed using an RSS reader or aggregator.
4.2 By accessing our RSS feed, you accept these terms and conditions.
4.3 Subject to your acceptance of these terms and conditions, we grant to you a non-exclusive, non-transferable, non-sub-licensable license to display content from our RSS feed in unmodified form on any non-commercial website owned and operated by you, providing that you must not aggregate our RSS feed with any other feed when displaying it in accordance with this Section 4.3.
4.4 It is a condition of this license that you include a credit for us and hyperlink to our website on each web page where the RSS feed is published (in such form as we may specify from time to time, or if we do not specify any particular form, in a reasonable form).
4.5 We may revoke any license set out in this Section 4 at any time, with or without notice or explanation.
4. Complaint Processing Guidelines
Unless otherwise prescribed by regulations, such as PSD2, the following general guidelines are followed regarding responses to complaints:
Complaints should be acknowledged within 1 business days after receipt, which includes correspondence, verbal, telephonic, or electronic notification of a complaint.
Inquiries, comments, or objections should be answered, or information provided within 5 business days after receipt.
5. Complaint File
Berg will keep all documentation regarding participant complaints for five years from the date of the first written or oral notification of an error from a participant. The complaint file will contain:
Notice of error will be logged within the specified account
All correspondence to and from the participant
All documentation used in the investigation
6. Timeliness of action
Delay by Berg beyond any time limits is excused if the delay is caused by:
Interruption of communication or computer facilities
War or acts of terrorism
Failure of equipment
Other circumstances beyond the control of Berg, as long as Berg uses diligence as the circumstances require
7. Corrective Action
If Berg determines that an error has occurred, it will address the participant’s account accordingly and will send a notice to the participant that corrective action has been taken. The corrective notice will be sent to the participant and filed for future reference. If Berg has determined that a participant owes all or part of a disputed amount, including related finance or other charges, it will:
Promptly notify the participant in writing of the portion of the disputed amount and related finance or other charges that the participant still owes and when payment is due.
8. Recording complaints
All complaints made, verbal or written, will be recorded at the time the complaint is made, or as soon as possible afterwards. The complaint must be recorded by the staff member who took the details.
When taking a complaint, staff will record details of the complaint. Details of all communication with the customer and any actions to resolve the complaint will be recorded in the same place.
Recorded complaints will also be monitored for any ongoing trends by management and efforts made to resolve any ongoing issues.
9. Informing customers of progress
We strive to resolve all complaints within 1-5 business days. Written complaints will be acknowledged promptly. All complaints will be addressed in accordance with PSD2.
Participants will be given an approximate timeframe at the time they make their complaint. Participants will be informed of the progress of their complaint regularly, especially if there are any delays or changes to what has been agreed.
Where appropriate, participants who have had a complaint resolved will be contacted at a later date to see if they are happy with how their complaint was handled.
10. Responding to complaints
All people making a complaint will be treated with courtesy. Where possible, complaints will be resolved at the first point of contact. If appropriate to the complaint, frontline staff can offer reimbursement for any fees associated with delayed or uncompleted transactions, monthly fees, and fees incurred with return of transfer to resolve a complaint immediately. Complaints will still be recorded.
If the complaint can’t be resolved immediately, the customer will be given a timeframe and details of our complaint handling process. Where possible, the staff member taking the complaint details will be the contact person.
11. Escalation of complaints
If a complaint cannot be resolved by the usual complaint process, it should be referred to Operations and the customer will be informed and given an amended timeframe for resolution.
Management can resolve a complaint by:
Authorizing additional credit to account
Contacting Client as may be applicable
12. Management reporting of complaints
Berg operations shall report to Management on weekly basis on all issues raised during the applicable time period, any unresolved issues, and unexpected delays with standard processes. Generic access issues shall be addressed at this time to establish whether additional training or changes to current user experience need to be made.
13. Ongoing Review of complaint handling policy and procedures
Berg is committed to continuous improvement and this policy will be reviewed regularly (at least annually) for effectiveness and be updated as needed.
This complaint handling policy is supported by management. We commit to adhering to this policy by providing appropriate training and adequate information to all staff.