BIEASES Complaints Policy
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BIEASES Complaints Policy

For the United Kingdom and European Economic Area
Last Updated: August 25th, 2024

1. Overview

BIEASES Ltd. is incorporated in the United Kingdom (UK) under reference number 14323423 with a registered address of 288 Chase Road, London, United Kingdom, N14 6HF. BIEASES Ltd. also has the trading name of “BIEASES”.

BIEASES Wallet is a payment platform which serves both Private and Merchant customers by offering the functions of Recharge, Withdrawal, P2P transfer, P2B Transfer, International remittance as well as the online Payment. BIEASES Wallet provides a broad network of international transfers, and it brings our customers fast, secure, and simple payment solutions.

Therefore, this policy is applicable to all financial service operations of BIEASES, and the responsibilities thereof.
This document provides guidelines for resolution and the treatment of complaints made by our customers. Each employee is responsible for reviewing the elements of the policy.

This policy applies to all staff receiving or managing complaints from customer made to or about BIEASES, regarding the provision of products and services, or BIEASES’s employees and complaint handling procedure.

This Policy shall be deemed effective only upon approval by Senior Management. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

This document shall be subject to periodic reviews in accordance with changes in:

  • Local and international legislation.
  • Industry best practice.
  • Internal changes in the business that impact the products available and relevant revenue streams.

Senior Management review and approve all changes before they are implemented. Minor changes are reflected by incrementing the version number as 1.1, 1.2, 1.3, etc.

Where significant changes to the document are made, these are reflected in a new version number as 1.0, 2.0, 3.0, etc.

2. Approach

Where complaints arise BIEASES seeks to handle every occurrence promptly in line with the procedures detailed in this policy. The information in this policy is made available to all relevant BIEASES’s employees.

Where needed, further guidance can be sought from the Compliance Officer. This policy outlines the definitions, procedures, and resources that BIEASES employees must use in the handling of complaints.

The purpose of this policy is to ensure that complaints are handled properly and that all customer complaints or comments are taken seriously. BIEASES expects staff at all levels to be committed to fair, effective and efficient complaint handling.

In handling complaints BIEASES adheres to the following principles:

  • To ensure that the complaining customer’s complaint is handled with equal promptness and care as per the procedures outlined in this policy.
  • To consider the complaining customer’s needs and that they are treated fairly for the duration of the complaint handling procedure.
  • To consider whether the received complaint is symptomatic of a larger issue within BIEASES.
  • To ensure that all complaints are escalated and handled correctly as required on a case-by-case basis.
  • All complaints are handled with equal consideration no matter how frivolous or irrelevant them may seem.

All BIEASES’s employees are expected to be fully aware of their obligations in relation to complaints.

2.1 Definitions and Eligibility

BIEASES defines a complaint in line with the definition provided by the FCA. Therefore, the FCA, and BIEASES, define a complaint as:

  • Any oral or written expression of dissatisfaction from or on behalf of a client, whether justified or not, which includes an actual or potential financial loss, material distress or material inconvenience.

Additionally, an eligible complaint is one that is:

  • Made by, or on behalf of, an eligible complainant.
  • Relating to regulated activity only.
  • Involving an allegation that the complainant has suffered, or may suffer, financial loss, material distress or material inconvenience.

Eligible complaints relate to regulated activity only. But for clarity, this may include:

  • Mis-selling.
  • BIEASES terms and conditions.
  • Charges and fees.
  • BIEASES products and services.
  • Marketing.
  • Transactions.
  • Payment and/or administrative errors.

BIEASES does not consider statements of dissatisfaction to be an eligible complaint. Such statements may include, or be similar to, the following:

  • A complaint regarding the way an employee spoke to a customer.
  • The failure of an employee to contact a customer when requested.
  • A comment on the functionality of the products or services that does not impact regulated financial activity.
    Although BIEASES does not consider such complaints as eligible, BIEASES strives to deal with such statements in an appropriate and professional manner. This is because all complaints or statements of dissatisfaction may be linked to, or may escalate to be, an eligible complaint.

2.1.1 Formal Complaints

A formal complaint is any complaint that:

  • Is not able to be resolved at first instance by the receiving employee.
  • Is resolved at first instance by BIEASES but where the complainant has chosen to escalate the complaint.

2.1.2 Informal Complaints

An informal complaint is any complaint received by BIEASES which is:

  • Resolved at first instance by the receiving BIEASES employee.
  • Not escalated by the complainant.
  • A complaint made by a non-eligible complainant.

All non-anonymous complaints filed necessitate a response regardless of formality status.

2.1.3 All Complaints

Non-eligible complainants may still bring eligible complaints against BIEASES through escalation or mis-categorisation by BIEASES. Therefore, BIEASES considers all complaints or statements of dissatisfaction with equal promptness and consideration.

2.2 Responsibilities

The employee who receives a complaint will evaluate all information provided by the complainant and determine whether the issue can be resolved immediately or whether the complaint requires escalation.
In resolving complaints at first instance BIEASES’s employees may use any internal resource available to them or request further resources from the COMPLIANCE OFFICER. Where the employee is unable to provide a satisfactory resolution then the complaint is forwarded to be reviewed by the COMPLIANCE OFFICER.

BIEASES’s Senior Management ensures that all staff involved in resolving the complaint are aware of their responsibility to maintain the confidentiality of the matter and to respect the privacy rights of all parties involved, and that suitable training has been provided.

3. Complaint Handling Procedure

While BIEASES handles all complaints with the same level of care and promptness regardless of formality or eligibility, eligible complaints are legally defined and have additional rights in law which BIEASES acknowledges.

In doing so BIEASES applies the following procedure to complaint handling:

  • BIEASES receives a written or verbal complaint.
  • The complainant is provided with an acknowledgement of receipt of the complaint and informed of the next steps of BIEASES’s complaint handling procedure.
  • The receiving employee records the content of the complaint, and a complaint reference number is assigned.
  • The employee assesses whether the complaint can be resolved at first instance or whether it must be escalated to a formal complaint.
  • Where possible the complaint is resolved at first instance, if not the complaint is escalated to being formal.
  • Formal complaints are escalated to the COMPLIANCE OFFICER with all relevant notes.
  • The complainant is informed that their complaint has been escalated and are provided with the relevant contact details.
  • The COMPLIANCE OFFICER will provide an appropriate resolution to the complainant.
  • Where the complainant remains unsatisfied then they shall be informed of their options to escalate their complaint to Moorwand’s operations team or the Financial Ombudsman or Bank of Lithuania.
  • Where the complaint has been resolved, or a final resolution has been provided then the result will be recorded in BIEASES’s complaints log.
  • All complaints and their outcomes are reported to BIEASES’s Senior Management in monthly meetings via management information packs.

4. Procedural Requirements

The following outlines BIEASES’s procedural requirements regarding timings, reporting, handling, and escalation of complaints.

4.1 Timings

BIEASES is required to adhere to specific timings in relation to complaint handling. Where a customer submits a complaint then a notification email of acknowledgment is provided to the complainant.

This email outlines BIEASES’s complaints handling procedure and contains the following:

  • The date, time, and form of the complaint.
  • The name and title of the individual responsible for handling the complaint.
  • A complaint number.
  • Details of the next steps in BIEASES’s complaint handling procedure.
  • Approximate investigation timelines and expectations where applicable.
  • Confirmation of the complainant’s contact details and preferred method of contact.
  • Confirmation of the content and nature of the complainant’s complaint.

BIEASES will ensure that the customer is kept informed of the progress of the measures being taken for the resolution of the complaint.

BIEASES strives to resolve all complaints within three days of receipt. Where it is not possible to resolve a complaint within three days then Biases will issue a final resolution by close of the fifteenth business day from receipt of the complaint. BIEASES’s resolution will include the following:

  • The details of the final resolution offered by BIEASES.
  • BIEASES’s justification for resolution.
  • Whether BIEASES’s intends to offer compensation or corrective action and the details of such offers.
  • Options for the complainant to escalate their complaint to the Ombudsman Services.

If, under exceptional circumstances, a final response is not possible within fifteen business days, BIEASES must send out a holding notification explaining why it has not been able to issue a decision. It must also state that it expects to be able to provide a decision before the end of the thirty-fifth business day.

The holding notification must detail:

  • The reasoning why exceptional circumstances have occurred which means BIEASES is not able to provide a resolution within fifteen business days.
  • Timeframes for when BIEASES expect to have a resolution.
  • Communication schedule for updates regarding the outstanding complaint.
  • Steps to be taken by BIEASES to resolve the complaint.

It should however be noted that it is a legal requirement that a final response is issued to the complainant by the end of the thirty-fifth business day after receipt of the complaint.

It is a legal requirement that BIEASES issue a final response to the complainant by the end of the thirty-fifth business day after receipt of the complaint. Failure to do so will give rise to potential action by the Ombudsman.

4.2 Internal Reporting

Where complains are raised, BIEASES conducts root cause investigations to establish whether changes must be implemented by BIEASES’s Senior Management. All complaints are analysed for reoccurring patterns to better inform BIEASES’s methods of prevention, changes will be made to BIEASES’s employee training as necessary.

To assess the cause of complaints BIEASES records the details of all complaints in a complaints log, the following will be recorded:

  • The complainant’s personal details, including name and associated contact details.
  • The details of the complainant’s complaint.
  • The reference number applied to the complainant.
  • The substance of the complainant’s complaint.
  • Whether the complaint is formal or informal.
  • The results of any investigation undertaken.
  • Whether the complaint has been resolved or is ongoing.
  • Whether the complaint has been escalated to the Ombudsman if known.

The COMPLIANCE OFFICER is responsible for the handling and recording of BIEASES’s complaints log. The COMPLIANCE OFFICER will review all complaints and present any findings to Senior Management in monthly meetings. Upon request the COMPLIANCE OFFICER will provide Moorwand with BIEASES’s complaints log every month.

4.3 External Reporting and Complaints Forwarding

BIEASES may promptly forward the complaint in writing to another party if they have reasonable grounds to believe that the other party may be solely or jointly responsible for the matter alleged in the complaint.

In BIEASES customers case, if a customer is not satisfied with the resolution provided by BIEASES, they can also contact Moorwand directly. Complainants who wish to contact Moorwand may email [email protected]. Or write to Moorwand Ltd. at Fora, 3 Lloyds Avenue, London, EC3N 3DS, United Kingdom.

If a complaint is forwarded, BIEASES will inform the complainant in a final response of why the complaint has been forwarded to another party and provide the complainant with the other party’s contact details.

If BIEASES receives a forwarded complaint, the complaint will be treated as if BIEASES has received the complaint directly and the same time limits will apply from the date on which BIEASES has received the forwarded complaint.

BIEASES will co-operate fully with the FCA and/or Ombudsman Services in resolving any complaints made against it. BIEASES will also pay promptly any fees levied by the FCA should they occur.

Therefore, it is important to avoid complaint escalation, or where possible, prevent complaints from occurring.

4.4 Escalation Procedures

Where a complainant is unsatisfied with any final resolution provided by BIEASES, they have the option to refer the complaint directly to the Financial Ombudsman Service (FOS).

MW will not handle the FOS case management. Instead, MW will be notified by the FOS if the complainant chooses to address their complaint to the FOS.

In the event that a complaint is raised to the FOS, Moorwand will be responsible for the associated fee.

Such complainants are provided with the contact details of Financial Ombudsman as follows:

The Financial Ombudsman Service, Exchange Tower, London E14 9SR

[email protected]

www.financial-ombudsman.org.uk

Regarding timings, the Ombudsman Service will not consider a complaint eligible if:

  • It is more than six months after the complainant has received a final response.
  • It is more than six years after the event complained of.
  • It is more than three years from the date on which the customer became aware that they had cause for complaint.

If BIEASES receives a complaint which is outside the accepted time limits for a referral to the Ombudsman Service, it may reject the compliant without considering the merits but will explain this to the complainant upon receiving the complaint.
Complaints who are unsure about their eligibility to escalate a complaint to the Financial Ombudsman should seek advice from the Financial Ombudsman.

If the customer is from European Economic Area, they may contact the Bank of Lithuania.

Address: Totoriu str 4, 01121 Vilnius, Lithuania

Telephone: +370 800 50 500 or +370 525 127 63

Email: [email protected]

Website: https://www.lb.lt