July 2024

1. INTRODUCTION

As a MiFID investment firm authorised and regulated by the Financial Conduct Authority (the “FCA”), Marathon Capital Ltd (the “Firm”) is required to demonstrate compliance with the relevant regulations and, specifically, article 26 of the MiFID Org Regulation and the FCA rules in the DISP sourcebook. 

The Firm has developed this Complaints Management Policy (the “Policy”) to set out the Firm's policy, procedures and controls in place to ensure that eligible complaints from a complainant are handled fairly, consistently and promptly.

2. ELIGIBLE COMPLAINTS

An eligible “complaint” is defined by the FCA as meaning “any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, or failure to provide, a financial service which (a) alleges that the complainant has suffered (or may suffer) financial loss, material distress of material inconvenience; and (b) relates to an activity of that respondent, or any other respondent with whom that respondent has some connection in marketing or providing financial services or products, which comes under the jurisdiction of the Financial Ombudsman Service (“FOS”)”.

An eligible “MiFID complaint” is defined as “any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, or failure to provide, a financial service or a redress determination which alleges that the complainant has suffered or may suffer financial loss, material distress or material inconvenience”. This does not come under the jurisdiction of FOS.

The Firm may receive both eligible complaints as defined by the FCA as well as MiFID complaints. In relation to the Firm’s MiFID business, complainants could include professional clients and eligible counterparties.

3. HOW TO RAISE A COMPLAINT

Should a complaint arise, the Firm would appreciate the opportunity to resolve any problems or difficulties for you directly.

Complaints should be addressed to UK Compliance and can be made in writing as set out below:

By email:
UKCompliance@marathoncapital.com

By post:
UK Compliance Marathon Capital Ltd
25 Upper Brook Street, Ground Floor London, England, W1K 7QD

To help us deal with your complaint quickly and efficiently, please include your contact details and clear and detailed description of your complaint, including any former communications you have had concerning the issues you are raising.

4. COMPLAINT HANDLING PROCES

The Firm is dedicated to investigating your complaint fully and impartially, taking account of all relevant information. We may contact you in writing or by telephone to ask you for further information to help us with our investigations.

If the Firm is able to resolve your complaint by the close of business on the third business day after it was received, we will send you a written detailing the complaint raised and why we consider it resolved together with details of how you can refer your complaint to the FOS if you are dissatisfied with the resolution of the complaint.

If the Firm is not able to close your complaint by close of business on the third business day after it was received, we will promptly acknowledge your complaint in writing. This written acknowledgment will describe our understanding of your complaint, tell you who your point of contact will be and inform you that the matter will be investigated and that a final response will be provided in writing within eight weeks of the complaint being received (although the Firm aims to resolve all matters sooner than this where possible). Where the complaint is still open or being investigated after four weeks, we will send you an update on progress.

Once the matter has been investigated and the Firm has made a decision regarding the complaint, you will receive a written final response that explains the outcome of our investigations, the reasons for the decisions we have made and if we are upholding your complaint, an explanation of the steps we will take to resolve the complaint, and inform you that if you are not satisfied with our response, your complaint may be referred to the FOS.

In exceptional circumstances, the Firm may not be able to provide you with a final response within eight weeks. In these instances, a holding communication will be sent to you in writing. This holding communication will inform you of the delay, outline the reasons for the delay, provide an expected response time for sending the final response and inform you of your FOS referral rights.

Referral of a complaint to the FOS is free of charge, but you must log your compliant with them within six months of the date of our response letter to you.

The contact details for the FOS are:
Financial Ombudsman Service Exchange Tower
London E14 9SR
+44 (0)800 023 4567 or +44 (0)300 123 9123
complaint.info@financialombudsman.co.uk
www.financial-ombudsman.org.uk

5. RECORD KEEPING

The Firm maintains detailed records of all complaints and maintains complaints register. The complaints register is maintained by UK Compliance and reviewed regularly.

6. FCA REPORTING AND COOPERATION

The Firm submits regular returns to the FCA and will cooperate fully with any requests for complaint information from the FCA.