This page is a draft. It has not been settled with counsel and it is not final. Items shown in brackets are outstanding.

Complaints

A complaint about this firm, or about anyone working for it, is made in writing to the risk and compliance committee. That committee is responsible for the regulatory perimeter, anti-money-laundering procedure, data protection and the firm's conflicts register, and it has the authority to halt a live transaction without the agreement of the deal team.

How to complain

Write to the risk and compliance committee at [complaints address]. Set out what happened and when, the mandate or the correspondence it concerns, and what you are asking the firm to do. A complaint may be made by a client, by a counterparty to a transaction we have worked on, or by anyone else affected by the firm's conduct.

What happens next

We acknowledge a complaint in writing within two business days of receiving it and tell you who is handling it. It is entered in the firm's complaints register and referred to the risk and compliance committee. A complaint is not examined by the person it concerns, nor by anyone who reports to that person.

We write with our findings, and with what we propose to do about them, within [investigation period] of the acknowledgement. Where the matter cannot be settled within that period we write at that point stating what has been established, what remains outstanding, and the date by which we will report again.

If our answer does not settle it

A complaint about our handling of personal data may be taken to the Nigeria Data Protection Commission at any stage, whether or not you have raised it with us first; the basis on which we hold data is set out in our privacy notice. For any other matter the route beyond the firm is [external escalation route], which will be stated here once the firm's registration status with the Securities and Exchange Commission is determined. That status is recorded at Regulatory information.

The register

Every complaint and its outcome is recorded in a register kept and reviewed by the risk and compliance committee. The committee structure, and what each committee decides, is set out at Governance.