This summary provides an overview of the handling of complaints within/on behalf of Mediolanum International Funds Limited hereinafter “MIFL”.
MIFLs objective is to resolve complaints in an efficient, effective and professional manner. MIFL has endeavoured to align its complaints handling process with relevant legal requirements including current best practice.
Complaints may be received either directly by MIFL or via the representative of MIFLs appointed distributors, fund administrators, correspondent bank, transfer agents or Co-operation/Sales Agents.
As MIFL has agreements in place which grant the local Distributors mandate to proceed with the placement of its products, most complaints are routed through and handled by the distribution networks of MIFL in Spain, Italy, and Germany. MIFL also has an agreement in place with the transfer agent (Lux) in relation to complaints handling for the Luxembourg Funds where they handle complaints received in accordance with their own internal complaints handling procedure.
Handling of Complaints
The Designated Person with responsibility for Distribution (PCF 39E) is responsible for oversight of complaints relating to distribution where he/she must be satisfied that complaints are investigated fairly
The following is a high-level overview of the processes in place to handle complaints:
(a) Complaints brought directly against MIFL
Any complaints received by MIFL will be reviewed in line with its internal Complaints Handling Policy. Where you are not satisfied with response received to your complaint you may then file a complaint with the Irish Financial Services and Pensions Ombudsman, Lincoln House, Lincoln Place, Dublin 2 Ireland. Further information is located at https://www.fspo.ie/make-a-complaint/
(b) Complaints handled by the Group distributors/ transfer agent (complaints against the Product/Family Banker)
Complaints received from retail investors by the distributors/ transfer agent are handled in line with their local complaints handling policies/procedures. The timelines for responding to a complaint differ according to the jurisdiction where the complaint is brought. MIFL maintains oversight of the complaints handled on their behalf and maintains a separate Complaints Register.
Where you are not satisfied with response received to your complaint you may then file a complaint with the Regulator for handling complaints within your jurisdiction or with the Irish Financial Services and Pensions Ombudsman (“IFSPO”), Lincoln House, Lincoln Place, Dublin 2 Ireland. Further information on complaints handling within the IFSPO is located at https://www.fspo.ie/make-a-complaint/
The closure of a complaint may take place where one of the following has occurred:
- MIFL or the representative at the relevant distributor/ Transfer Agent (Lux)/ has sent a Formal Response letter and to the best of our knowledge no complaint has been made to the Irish Financial Services and Pensions Ombudsman; or
- the complainant has indicated acceptance of the response issued by MIFL or the representative at relevant distributor/ Transfer Agent (Lux); or
- the investor has contacted MIFL or the representative at the relevant distributor/Transfer Agent (Lux) and advised that they do not want the issue to be treated as a complaint. In this case a letter closing the complaint is issued to the complainant and the matter is then finalized; or
- Where a negotiated resolution has been reached with the complainant or the matter has been amicably resolved.
A complaint is re-opened when MIFL receives written notice that the complainant is not satisfied with the first reply that they received to original complaint. These complaints shall also be handled in line with the distributors/transfer agents’ local complaint handling procedures.
Where there is a delay in responding to a complaint the complainant shall be informed about the causes of the delay in receiving a reply to their complaint and advised when the investigation is likely to be completed. The complainant shall be kept updated on the further handling of the complaint.
Complaints handling at Banca Mediolanum (Distributor in Italy)
Banca Mediolanum is MIFL’s key Distributor in Italy. The Claims Department at Banca Mediolanum maintains a registry of client complaints. This Department investigates, seeks resolutions and prepares replies to the complainants and records closures of complaints in their complaints register in line with their local complaints handling procedure.
Further details on their complaint handling process is located at https://www.bancamediolanum.it/reclami-ricorsi-conciliazione
Copies of all correspondence issued or received, will be retained by the MIFL or its appointed Distributor/transfer agent in line with its own data protection and record retention policies.