Disclosure to Complainants

Who are you and why is this policy needed?

Start Codon Ltd (AR FRN: 829823) (“Start Codon”) is an appointed representative of Enterprise Investment Partners LLP (FRN: 604439) (“Enterprise Investment Partners”). Enterprise Investment Partners is a firm which is authorised and regulated by the Financial Conduct Authority (“FCA”) in the United Kingdom to provide investment intermediation.

Start Codon and Enterprise Investment Partners are required to have in place effective and transparent procedures for the reasonable and prompt handling of complaints in relation to the services of Start Codon.

Accordingly, this document sets out the complaints handling procedures that Start Codon and Enterprise Investment Partners will follow in the event that you make a complaint.

Does this policy apply to you?

The services Start Codon provide 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 Start Codon and Enterprise Investment Partners 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 Start Codon and Enterprise Investment Partners have handled your complaint.

How can you make a complaint?

You can make a complaint about Start Codon’s services by any reasonable means – for example, letter, email, telephone or in person. It is free of charge to complain.

To make a complaint, please contact:

Name: Joseph Lazaris
Entity: Enterprise Investment Partners
Address: 1-6 Speedy Place, London, WC1H 8BU
Email Address: jlazaris@enterprise-ic.com
Phone Number: 07453 322508

What will happen once you have made your complaint?

Your complaint will be acknowledged, the name and title of the person handling your complaint confirmed, and a copy of this policy will be provided, in each case in writing promptly upon receipt. As a default, your complaint will be reviewed by Joseph Lazaris, the Compliance Officer of Enterprise Investment Partners unless Joseph Lazaris is involved in the subject matter of the complaint, in which case your complaint will be referred to another member of Enterprise Investment Partners’ senior management team.

Joseph Lazaris and/or each other member of Enterprise Investment Partners’ senior management team has the authority necessary to investigate and settle each complaint.

Investigating and resolving your complaint

Start Codon and Enterprise Investment Partners will investigate within a reasonable period of time your complaint competently, diligently and impartially with a view to deciding whether the complaint should be upheld and whether any remedial action and / or redress may be appropriate. The conclusions of this investigation will be confirmed in a final written response to you.

If it is decided that redress is appropriate, Start Codon will aim to provide you with fair offer of compensation for any acts or omissions for which Start Codon is responsible. If you accept that offer, Start Codon will provide within a reasonable period of time such compensation to you.

Timetable for responses

Once your complaint has been acknowledged, as set out in the section “What will happen once you have made your complaint?” above, Enterprise Investment Partners will keep you reasonably informed of the progress of your complaint. If either Start Codon or Enterprise Investment Partners can quickly resolve your complaint, you will be sent a summary resolution communication which will:

  • acknowledge your complaint and confirm that it is now considered to have been resolved;
  • explain that you may still be able to refer your complaint to the FOS if you subsequently disagree with any decision made, and the timescales you have for doing this; and
  • provide information about how to contact the FOS.

If it is not possible to resolve your complaint within a reasonable period of time, Enterprise Investment Partners will, within eight weeks of receiving your complaint, send you either a final response or a written response that explains why it is not possible to make a final response to you and when you can expect to be provided with one.

Such response will also:

  • inform you that, if you remain dissatisfied, you may refer the complaint to the FOS; and
  • enclose a copy of, or an electronic link to, the FOS standard explanatory leaflet.

Financial Ombudsman Service

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 entitled “Your Complaint and the Ombudsman” which Enterprise Investment Partners 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 the date of our final response.

Alternatively, if you are based outside of the UK you can register your complaint on the Online Dispute Resolution (ODR) Platform using the link http://ec.europa.eu/consumers/odr/.

Closing complaints

Your complaint will be determined to be closed in the following circumstances:

  • once Enterprise Investment Partners have sent you a final response; or
  • where you have told Enterprise Investment Partners and/or Start Codon in writing that you accept an earlier response that Enterprise Investment Partners have sent to you; or
  • if you refer your complaint to the FOS, when the FOS informs Enterprise Investment Partners and/or Start Codon that the complaint has been closed.

Questions

If you have any questions about our complaints process, please contact Joseph Lazaris via any of the contact methods listed above.