This manual sets out the steps and processes that must be followed in receiving and resolving complaints concerning Serala Capital (“the Company”) from clients and other stakeholders. The Company shall always endeavour to resolve all complaints amicably to the satisfaction of all parties involved in the shortest time possible.

• The Company shall maintain a complaint register that shall be used to record all complaints received by the Company for record-keeping purposes. The Company shall also use the complaints register to review the level of service and responsiveness to stakeholders who lodge complaints (“complainants”) against the Company and its employees.
• The Company shall also maintain a complaints procedure detailing all the steps and individuals involved in the complaint resolution process.
• The complaints procedure shall be disclosed to the complainant and displayed in a public area.
• The Company shall inform the Non-Bank Financial Institutions Regulatory Authority (“NBFIRA”) of any unresolved complaints lasting more than three months.
• The steps that must be followed in resolving complaints are outlined below.

1. The first step shall be to officially receive the complaint from the complainant, whether in person, by phone or by email. The complaint should clearly be recorded in the complaints register, including the particulars of the complainant, the date, time and place of complaint as well as the details of the person receiving and recording the complaint.

2. Responsibility for the complaint, where possible, will be allocated to a person other than whom a complaint is about or who was responsible for the actions that led to the complaint.

3. After a complaint has been received, the Company shall write to the complainant acknowledging receipt of the complaint and explaining the process to be followed in resolving the complaint. The Company aims for all complaints to be acknowledged within five working days of receipt. This acknowledgement will comprise:

i) The Company’s interpretation of the complaint;

ii) Name the member of staff who will handle the complaint “Investigating Officer”.

4. The complaint shall immediately be given to the relevant Investigating Officer, who will inform any employee(s) who is the subject of the complaint. The Compliance Officer shall also be notified in writing of any complaints.

5. The Investigating Officer and the employee or employees who are an integral part of or affected by the complaint shall hold a meeting to discuss the details of the complaint.

6. The complainant should be informed of the progress in resolving the complaint within a maximum period of four weeks.

7. The Investigating Officer should seek to resolve the complaint based on the information in the complaint register and the information received from relevant employees, and communicate the resolution of the complaint to the complainant in writing.

8. If the complainant is content with the resolution of the complaint, the complaint is marked as closed in the complaints register.

9. Should the complainant not be satisfied with the resolution, the complainant may appeal to the CEO or another appropriate person nominated by the CEO.

10. Following the appeal, if the complainant is satisfied with the resolution proposed, the complaint is marked as closed in the complaints register.

11. Should the complainant not be satisfied with the proposed resolution after appeal, the complainant may appeal to a mediator agreed to by both parties.

12. Following mediation, if the complainant is satisfied with the resolution of the complaint, the complaint is marked as closed in the complaints register.

13. Should the complainant not be satisfied with the proposed resolution, the complainant may take any steps it deems necessary action outside of the ambit of Serala Capital.

14. In all cases, the Compliance Officer should report to the NBFIRA if the complaint is not resolved within three months.