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Complaints Handling Procedure

Objective And General Policy

We aim to ensure that we treat our customers fairly at all times. Any complaints will be investigated competently, diligently and impartially, assessed fairly and promptly with respect to the subject matter of the complaint, and whether the complaint should be upheld and what remedial action or redress may be appropriate.

The FCA’s Dispute Resolution (“DISP”) handbook sets out the rules relating to the handling of complaints from eligible complainants and MiFID clients.

In the limited circumstances in which the FCA requirements with respect to eligible complainants apply to us, we expect such complaints will only relate to certain investors in our AIF(s) who can be categorised as a ‘consumer’ in relation to our regulated activities as the AIFM. The FCA has defined ‘consumer’ as a natural person acting for purposes outside their trade, business or profession (e.g. a high net worth individual could fall within this definition).

Complaints Handling Procedure

We define complaints as follows with respect to the two categories of complainants:

Eligible complaint – 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”).

MiFID complaint – 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.

Upon receipt of a Complaint, as defined above, the Compliance Officer will ensure that complainants are provided a copy of this document, which constitutes our complaints handling policy, when acknowledging a complaint.

We will endeavour to communicate with you clearly and in plain language that is easy to understand and reply to your complaint without undue delay. As soon as we have made the relevant enquiries and reviewed your complaint, we will write to you. If we have reasonable grounds to be satisfied that another respondent may be solely or jointly responsible for the matter alleged in your complaint, we may promptly forward the complaint, or the relevant part of it, in writing to that other respondent. We will inform you promptly in a final response of the reason for forwarding the complaint, including the other respondent’s contact details. Where jointly responsible for the fault alleged in the complaint, we will comply with own obligations under the DISP rules in respect of that part of the complaint we have not forwarded.

We will endeavour to write to you within eight weeks.

All complainants should contact the Compliance Officer

Contact: Stuart McKay

Address: 50 Great Marlborough Street, London W1F 7JS, UK

Telephone: 020 7531 2460

Email: sm@broadreachllp.com


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Broad Reach UK

50 Great Marlborough Street
+44 20 7531 2460

Broad Reach US

1185 Avenue of the Americas
New York
NY 10036