by Daman Securities LLC

Complaints Management Policy

1. INTRODUCTION

1.1. This document (“Policy”) sets out the policies and procedures for the treatment and management for complaints by clients (“Client”) of Daman Securities LLC (“Daman”).

1.2. All directors, employees and consultants of Daman shall always comply with this Policy.

1.3. Daman shall make a copy of this Policy available on its website and shall provide promptly a free copy of this Policy, by email and/or hard copy, to any Client who requests it.

2. OBJECTIVE

The objective of this Policy is to ensure that every complaint made by Clients to Daman (“Complaint”) is dealt with fairly, efficiently, without delay and, incompliance with all applicable laws and regulations.

3. FAIRNESS & CONFIDENTIALITY

3.1. All Complaints will be handled in a prompt, efficient, and fair manner, with the aim of achieving a satisfactory resolution for the Client.

3.2. If a Complaint relates to the action(s) of one or more Daman employees those employees shall not be involved in any decision regarding the Complaint

3.3. All Complaints shall be kept confidential and shall be dealt with in accordance with all relevant privacy policies and laws.

4. WHAT IS A COMPLAINT

A complaint is any expression of dissatisfaction, written or oral, regarding the services provided by Daman, including but not limited to, the execution of trades, pricing, order handling, account management, or any other issue related to Daman’s Services.

5. RECEIVING A COMPLAINT

5.1. A Complaint may first be received by an employee (“Receiving Employee”) in person (face-to-face), over the phone, by messaging service (such as WhatsApp) or by email. If the initial complaint is not by email the person complaining (“Complainant”) should be asked to put their complaint in writing in an email sent to the “compliance@daman.ae” and the receiving Employee with the information set out in 5.2 below and sufficient other detail to enable investigation of the Complaint to take place.

5.2. On receiving the first complaint email, the Receiving Employee should satisfy themselves that the Complainant is a registered client of the Company. This should be done by requesting, reviewing and checking against Company client records:

(a) the Complainant’s full name and address.
(b) a copy of the Complainant’s Emirates ID; and
(c) the Complainant’s contact details including phone number and email address.

5.3. If the Complainant is not a Client of the Company, he or she should be informed by email from the Receiving Employee that Daman can only process complaints from registered Clients. The Complainant should be asked whether they are complaining on behalf of a Client and, if they are, they should be asked to provide a copy of a relevant power of attorney. The General Counsel should be asked to review any power of attorney that is produced.

5.4. If no power of attorney exists, then the Complainant should be asked to arrange for the Client to complain in person rather than through the Complainant. This will be the end of the process until this Complaint is received by email from the Client concerned (when the process outlined in this section should then also be gone through).

5.5. Receipt of a verified Complaint shall be acknowledged as soon as possible and, in any event, within 2 business days of receipt.

6. RECORDING THE COMPLAINT

6.1. After verification, the Receiving Employee must record the Complaint in the Complaint Management System and inform the Head of Department (“Complaints Manager”) of the Complaint.

6.2. Once the Complaint is registered in the Complaint Management System the Receiving Employee should email the Client and inform them of the following:

(a) that receipt of the Complaint is acknowledged;
(b) the name and contact details of the Complaint Manager as the person who will be handling the Complaint;
(c) that all communication regarding the Complaint from the Client should, from then on, be made to the Complaint Manager;
(d) details of the Compliant handling process by providing a copy of this Policy;
(e) the expected timeframe during which the complaint will be resolved; and
(f) that the Client can, at any time, communicate with the SCA regarding the Complaint.

7. RESOLVING THE COMPLAINT

7.1. The Complaints Manager has the authority to resolve any Complaint and to implement any appropriate procedures and compensation when resolving a complaint.

7.2. The Complaints Manager shall investigate the Complaint thoroughly, including gathering all relevant information, reviewing trading records, and speaking with all relevant Daman employees.

7.3. The Complaints Manager may obtain assistance and relevant information and/or evidence from any Daman employee to investigate and resolve a complaint. Requested assistance, information and/or evidence shall always be given promptly.

7.4. The Complaints Manager shall have discussions with the Client as he deems appropriate in the circumstances. If requested by the Client, the Complaints Manager shall meet with the client face-to-face at Daman’s premises to discuss the Complaint.

7.5. The Complaints Manager shall request relevant information and/or documentation from the Client to investigate and resolve a complaint. The Client shall be given at least 10 Business Days to provide such information and/or documentation. The Client shall not be required to provide any information and/or documentation, but a failure to do so may mean that the Complaints Manager is unable to resolve the Complaint to the satisfaction of the Client.

7.6. Once the Complaints Manager has finished his investigation and made a decision regarding the Complaint, the Complaints Manager shall advise the Client of the decision as soon as practicable after deciding the outcome. The Complaints Manager shall prepare and issue a written complaint resolution response (“Decision”). A draft Decision may be prepared by another Daman Employee under the supervision of the Complaints Manager. The Decision on the complaint must be approved by the Complaints Manager before it is issued to the Client.

7.7. The Decision must be sent to the Client within 15 Business Days from the date on which the Complaint was received (or if later within 10 Business Days of relevant information and/or documentation being received under 7.2 above) and within 2 business days after the final Decision was approved by the Complaints Manager. The Decision may be sent by email to the Client’s email address unless the Client has requested a hard copy of the Decision be sent to the Client address registered with Daman.

7.8. Each Decision issued to a Client shall

(a) state the Complaints Manager’s decision as regarding the Complaint;
(b) set out the reasoning for the decision;
(c) set out the compensation or restitution action (if any) to be undertaken by Daman; and
(d) state that the Client has the right to take their complaint to the SCA and set out the contacts of the relevant person at the SCA.

7.9. The Complaints Manager shall record the decision and the reasons for the decision on the Complaint Management System.

8. ESCALATION OF THE COMPLAINT

If the Client expresses dissatisfaction at the Decision, the Complaints Manager shall inform the Client of their rights to escalate the Complaint to the SCA or to a further body such as the UAE Court in accordance with the Client agreement between Daman and the Client.

9. RECORDS KEEPING AND MAINTAINING

Management shall keep and maintain all the related documents, communication, and correspondence to any complaint, for a period of 10 years.

10. COSTS

Complaints shall be handled free of charge to the Client.

11. REPORTING

11.1. The Complaints Manager shall give a copy of the Decision and the relevant entry in the Complaints Register to the Daman Head of Compliance at the same time that it is provided to the Client. If the Head of Compliance so requests, the Complaints Manager shall give a further copy to the CEO of Daman.

11.2. If a Complaint relates to a potential regulatory breach, Daman will report the matter to the SCA in accordance with it’s regulatory obligations.

12. UPDATING AND CUSTODIAN OF THIS POLICY

The Head of Operations shall be responsible for the custody and upkeep of this policy. The Head of Operations shall ensure that all Daman employees receive a copy of this Policy and receive training in this Policy. This Policy shall be reviewed as necessary and at least every 2 years.

Any notification, circular, report or any other form of communication from the SCA and/or any other regulator(s) affecting the contents of this Policy shall become effective when required by that communication and shall be incorporated in this document on its next review or, if significantly material, this Policy shall be amended and re-issued to include it without delay.

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