Our clients are important to us, and we try to always provide the highest quality service. We recognise that if our service does not meet your expectations, you may wish to make a complaint. Our complaints procedure is set out below.

This document sets out the complaints handling procedures that we will follow if you make a complaint.

Definition of a complaint

For the purpose of FCA requirements on complaints procedures (FCA Handbook) a complaint is any expression of dissatisfaction, whether oral or written, and whether justified or not, from or on behalf of an eligible complainant about the firm’s provision of, or failure to provide, a financial services activity.

A complaint must involve an allegation that the complainant has suffered, or may suffer, financial loss, material inconvenience or material distress.

Does this policy apply to you?

As part of its statutory obligation, the FCA has established the Financial Ombudsman Service (FOS) which has the power to consider, arbitrate and settle complaints between FCA authorised firms and an 'eligible complainant' where the parties have been unable to resolve the matter themselves, or a client is not satisfied with the way in which a firm has dealt with the client’s complaint.

The services products and services Marsham provides are available to persons who are ‘consumers’, as well as individuals, businesses and organisations that may not be consumers. The definition of a consumer for regulatory purposes also refers to any natural person acting outside of his trade, business, or profession. If you fall within such categories, you are likely to be an ‘eligible complainant’.

Whilst Marsham will treat all complainants equally, please note that only eligible complainants will be able to refer complaints to the Financial Ombudsman Service (“FOS”) if you are not satisfied with the way that we have handled your complaint.

How can you make a complaint?

You can make a complaint by any reasonable means – for example, letter, fax, email, telephone or in person.

Complaints can be sent to Marsham Investment Management LLP, 28 Bolton Street, London W1J 8BP UK, or emailing: or by telephoning: 4402076299933.

To enable us to resolve your complaint as quickly as possible, please provide us with the following information:

• Your name, address, contact phone number and email address, or

• if you are making a complaint on behalf of another eligible complainant; both their details and the name and address of the organisation you represent;

• the account number or other reference for the account that the complaint relates to; and

• details of the complaint, including relevant references and dates.

Investigating and Resolving your complaint

Your complaint will be referred to our Compliance Manager department, as soon as possible. If the Compliance Manager is involved in the subject matter of the complaint, your complaint will be referred to another Partner of the firm.

We will promptly acknowledge your complaint in writing. This acknowledgement will provide the name and title of the person that is handling your complaint. This individual will have the authority necessary to investigate and settle the complaint. We will also include a copy of this policy.

We will investigate your complaint fairly, consistently, and promptly, determine whether the complaint should be upheld, and (if appropriate) determine remedial action and / or redress

Our timetable for responding to you

Once we have acknowledged your complaint, we will keep you informed of the progress of our investigation.

If we can informally resolve your complaint within three business days of the complaint being received, we will do so. In that event, we will issue a Summary Resolution Communication (SRC) which will include the following content which has been prescribed by the FCA:

• A statement that Marsham considers the complaint to be resolved;

• A statement that the complainant may refer the complaint to the FOS if they subsequently decide that they are dissatisfied;

• The website address for the FOS and comment that further information is available there; and

• Whether Marsham consents to waive the six-month time limit for referring the complaint to the FOS.

Where we are unable to resolve the complaint informally, within eight weeks of us receiving your complaint we will send you either a final response which closes the complaint or a written response which:

• explains why we are not able to make a final response to you and when we might be expected to provide one;

• informs you whether you are now entitled to refer the complaint to the Financial Ombudsman Service (“FOS”); and if so

• encloses a copy of the FOS standard explanatory leaflet. Financial Ombudsman Service (“FOS”) If you are an eligible complainant, you can refer a complaint to the FOS if you are not satisfied with the outcome of your complaint.

Your rights are set out in the FOS’s leaflet “Your Complaint and the Ombudsman” which we will provide to you as part of the Complaints process.

Please remember that if you wish to refer a complaint to the FOS, you must do so within six months of receiving our final response. You should allow us to complete our internal Complaints Procedure before you refer your concerns to FOS. Closing complaints

Closing Complaints

We will set out our conclusions of our investigation in a final response letter to you.

We will regard your complaint as closed in the following circumstances:

• once we have sent you a final response; or

• where you have told us in writing that you accept an earlier response that we have sent to you; or

• if you refer your complaint to FOS, when FOS informs us in writing that the complaint has been closed.

Marsham is committed to ensuring that all complaints received are handled fairly, consistently, and promptly and that the firm identifies and remedies any recurring or systematic problems, as well as any specific problems identified by a complainant. We will continue to do all we can to learn from the complaints we receive to improve our level of service to you in the future.