With this policy FORCROWD Srl (hereinafter the ” Company”) defines (i) the terms and methods with which customers, whether they are subjects qualifying as applicants in compliance with art. 2, paragraph 1, lett. c) of the CONSOB Regulation n. 18592 of 26 June 2013, as subsequently amended (hereinafter the ” CONSOB Regulation”) or as investors, may submit complaints to the Company relating to the service offered and (ii) the procedures established by the Company for dealing with and handling complaints received in compliance with the obligations pursuant to art. 14, paragraph 1, lett. h) of the CONSOB Regulation. If the Customer discovers an omission or behaviour by the Company other than the expected level of service, a written complaint can be submitted to the Company in the following ways:
- by ordinary mail to the following address: “FORCROWD S.r.L. “, Via Vincenzo Monti n. 52 , 20125 – Milan (MI);
- by e-mail to the following email address: firstname.lastname@example.org.
In the interest of the customer, the complaint must contain at least the following information:
- identification of the CUSTOMER;
- transaction or service to which the complaint refers;
- telephone number at which the customer can be contacted, and the e-mail address;
- clear description of the subject of the complaint, the reasons underlying it and the requests made;
- any documentation supporting the complaint;
- express authorization to the processing of personal data pursuant to current legislation on privacy;
- only in case of a complaint by mail, date and signature of the CUSTOMER.
The Company guarantees that personal data will be processed in compliance with the privacy statement available in the specific area of the portal.
The Company undertakes to notify the customer of the outcome of the complaint by e-mail within 10 (ten) working days from its receipt, provided that it contains all the information necessary for its assessment. In this regard, the Company reserves the right, within the same 10 (ten) working days from receipt of the complaint, to ask for clarifications about the content of the complaint. The answer will, in this case, be provided within 7 (seven) working days from the date of receipt of the requested clarifications.
The Company also ensures that the complaints received are evaluated in the chronological order in which they are received.
The manager of the procedure for handling complaints is Mr. Antonio Forte (the ” Manager “).
In detail, the procedure for handling complaints is as follows:
– the Manager, together with all the supporting documentation, registers every complaint. A specific identification code is attributed to each claim and it is then classified under one of the following areas:
- a. legal and compliance complaints;
- complaints related to the evaluation of the applicant’s project;
- technical complaints, related to the operation of the portal and the IT structure;
- complaints related to the investor’s identification, evaluation of appropriateness and the execution of the investment or to the activities placed under the control of the banking partners;
- e. problems not included in the previous categories.
– based on the classification, the Manager identifies any resources to be involved in the analysis and handling of the complaint.
– the whole procedure takes place by email, unless otherwise explicitly requested by the complainant;
– within 3 (three) working days from receipt of the complaint, the Manager notifies the complainant of the opening of the complaint analysis phase and starts the preliminary investigation;
– within the following 7 (seven) working days, except in the case of requests for clarifications, the Manager notifies the complainant of the outcome of the complaint, which is kept in the relative file and the electronic record.
The content of the final outcome varies depending on the decision made regarding the complaint. In particular, if the complaint is considered:
- a) founded, the Company indicates to the complainant the initiatives that will be undertaken to solve the reported issue and timing established to implement them.
- b) unfounded, the text contains, in a clear and comprehensive form, the reasons which led the Company to reject the complaint and the information necessary to advance proceedings, where the claimant deems it appropriate, for the court dispute settlement schemes.
The manager defines the “complaint terminated” if:
- the reason for the complaint is no longer applicable;
- once the period for mediation or conciliation procedures out of court (for total inactivity by the applicant) have expired;
- The appellant made use of the conciliation and arbitration procedures provided for by current legislation (the applicant’s activity landed at another execution venue).
Without prejudice to the specific provisions relating to the resolution of disputes contained in the ” General terms and conditions of use ” section of the Company’s portal applicable to investors and applicants, where requested by the complainant, on a voluntary and non-mandatory basis, the proceeding may take place before the Arbitrator for Financial Disputes (ACF), established by the CONSOB regulation n. 19602/2016. More information on the proceedings before the ACF is available at the following link: https://www.acf.consob.it .
Data relating to complaints received in writing, together with the measures adopted as a result of them, any shortcomings found, as well as planned activities will be indicated, pursuant to Article 21, paragraph 3, letter d) of the CONSOB Regulation, in the annual report that the company will send to CONSOB.
To this end, the Company has created a Complaints Register, held by the Compliance Department, which records, in chronological order, the essential elements of each complaint and the measures taken to solve the problem raised.