Adopted: January 2024
Reviewed: October 2025 – No Changes
Next Review: October 2026
1. Introduction
TreasurX Limited (“the Company”) is committed to providing an ethical, efficient, and professional service. We aim to deliver prompt, courteous, transparent, and informative responses to all client or prospective client queries, feedback, and complaints. We actively welcome feedback—both positive and negative—as it enables us to improve our services continuously.The Company is not a regulated entity. It acts as an intermediary introducing business to regulated financial institutions. Accordingly, we operate in accordance with the Payment Services Regulations 2017 (PSRs), EBA Guidelines, the Financial Conduct Authority (FCA), the Information Commissioner’s Office (ICO), the Financial Ombudsman Service (FOS), and Treating Customers Fairly (TCF) principles.This policy sets out the procedures for monitoring, handling, and following up on complaints. All personnel must read and familiarise themselves with its contents.The Company will always abide by regulatory guidance regarding complaint management and ensure complainants are kept fully informed throughout the process.While our objective is to get things right first time, we recognise that mistakes can occur. In such cases, we treat complaints as an opportunity to put things right and learn from them.Issues arising from third-party partners (such as banks or payment providers) are managed under the terms of their contractual service-level agreements. Complainants will be kept informed of developments and proposed resolutions in these cases.Our approach is built on handling complaints quickly, fairly, and transparently to maintain positive relationships and continuously improve our service.When a complaint is received, whether in writing, by phone, or in person, the Company undertakes to:Treat the complaint seriously
• Deal with it promptly, courteously, and sympathetically
• Investigate it thoroughly and fairly
• Acknowledge any fault and issue an appropriate apology
• Explain the outcome clearly and outline any corrective actions taken
• Learn from the experience to prevent recurrence
2. Complaints Process
2.1 How a Complaint Can Be Made
A complaint may be submitted in writing (email or letter), by telephone, or in person.
If the complaint is sent by email, we will confirm whether an email reply is acceptable or, if not, request an alternative contact number or postal address.Complaints should first be directed to the member of staff or account manager handling the client relationship, allowing them the opportunity to explain and resolve the issue.If the complainant prefers, they may escalate the matter to the relevant line manager, who will oversee the investigation.1. IntroductionTreasurX Limited (“the Company”) is committed to providing an ethical, efficient, and professional service. We aim to deliver prompt, courteous, transparent, and informative responses to all client or prospective client queries, feedback, and complaints. We actively welcome feedback—both positive and negative—as it enables us to improve our services continuously.The Company is not a regulated entity. It acts as an intermediary introducing business to regulated financial institutions. Accordingly, we operate in accordance with the Payment Services Regulations 2017 (PSRs), EBA Guidelines, the Financial Conduct Authority (FCA), the Information Commissioner’s Office (ICO), the Financial Ombudsman Service (FOS), and Treating Customers Fairly (TCF) principles.This policy sets out the procedures for monitoring, handling, and following up on complaints. All personnel must read and familiarise themselves with its contents.The Company will always abide by regulatory guidance regarding complaint management and ensure complainants are kept fully informed throughout the process.While our objective is to get things right first time, we recognise that mistakes can occur. In such cases, we treat complaints as an opportunity to put things right and learn from them.Issues arising from third-party partners (such as banks or payment providers) are managed under the terms of their contractual service-level agreements. Complainants will be kept informed of developments and proposed resolutions in these cases.Our approach is built on handling complaints quickly, fairly, and transparently to maintain positive relationships and continuously improve our service.When a complaint is received, whether in writing, by phone, or in person, the Company undertakes to:Treat the complaint seriously
• Deal with it promptly, courteously, and sympathetically
• Investigate it thoroughly and fairly
• Acknowledge any fault and issue an appropriate apology
• Explain the outcome clearly and outline any corrective actions taken
• Learn from the experience to prevent recurrence
2.2 Timescale
The Company aims to resolve complaints within 15 business days of notification. If this is not possible, we will explain the reason for the delay and provide a revised completion date.If a complaint cannot be resolved to the client’s satisfaction within the stated timescale, the matter may be referred to the Financial Ombudsman Service (FOS).
2.3 Acknowledgement of a Complaint
We will acknowledge receipt of any complaint within 5 business days (Monday–Friday, excluding bank holidays).The acknowledgement will include:Details of the Company’s Complaints Procedure
• The complainant’s right to refer the matter to the FOS
• The name and contact details of the person handling the complaint
2.4 Initial Response
Within 10 business days of receipt, we will issue a further update outlining:
• Investigation steps taken so far
• Findings to date
• Any proposed redress or resolution
If unresolved, the complainant may contact the Company’s Compliance Manager, who will review the case independently to reach a fair outcome.We will acknowledge any follow-up communication within 5 business days.
2.5 Holding Response
If more time is required to complete the investigation, we will issue a Holding Response, explaining:
• Why the investigation cannot yet be concluded
• What additional actions are underway
• When the complainant can expect an update
At this stage, the complainant may request a discussion with the Managing Director to ensure the issue receives the highest priority.
2.6 Final Response
Once the investigation is complete, we will issue a Final Response Letter, summarising:
• The outcome of the investigation
• Any final offer of redress (if applicable)
• Details of how to contact the FOS if the complaint remains unresolved
We aim to send the final response within 15 business days of receiving the initial complaint, though complex cases may require additional time.
2.7 Ultimate Redress
If the complainant remains dissatisfied, they may refer the matter to the Financial Ombudsman Service (FOS) and, if necessary, pursue further redress through the courts.
The Company will record all relevant details and classify the complaint outcome accordingly (e.g. “Investigated but not resolved”). Relevant cases are reported to our regulated partners, who notify the FCA as appropriate.
2.8 Monitoring and Reporting of Complaints
All complaints are logged, reviewed, and reported to our regulated partners as part of our regular compliance reporting.
Complaint trends and statistics are reviewed during monthly management meetings to identify opportunities for service improvement.
The Company retains complaint documentation in compliance with data protection laws and will not share personal data with third parties without consent.
Each complaint record includes:
• Nature, date, and method of complaint
• Complainant’s details
• Description of the issue
• How and by whom it was handled
• Whether it was upheld or refuted
• Outcome and any redress offered
