Complaints Handling Policy

GTC Global SA (Pty) Ltd ("GTC Global SA", "we", "us" or "our") is a licensed financial services provider ("FSP") duly authorised and regulated by the Financial Sector Conduct Authority ("FSCA") in terms of the Financial Advisory and Intermediary Services Act, 2002 ("FAIS Act"), under FSP number 51545, to render intermediary services in respect of derivative instruments.

GTC Global SA renders intermediary services in respect of the products of GTC Global Trading LTD (the "Broker"), a company incorporated in the Autonomous Island of Anjouan, Union of Comoros (Company No. 16283) and licensed by the Anjouan Offshore Finance Authority under International Brokerage and Clearing House Licence No. L16283/GTC.

The General Code of Conduct for Authorised Financial Services Providers and Representatives ("FAIS Code of Conduct") requires GTC Global SA to maintain an internal complaint resolution system and procedures. This Complaints Handling Policy ("Policy") sets out that system, and explains how complaints by South African clients about the Broker are received, referred and followed up.

We are committed to treating our clients fairly. We regard every complaint as an opportunity to put things right for the client and to improve our services.

Complaints should be made in writing. If a Client is unable to put a Complaint in writing, a member of our staff will record it, send the written record to the Client to confirm, and treat the date on which the Complaint was first raised as the date of receipt.

A Complaint may be lodged on a Client's behalf by a person with the Client's written authority. We may ask for proof of that authority before disclosing any information about the Client.

Full postal and hand delivery details are also set out in our FAIS Disclosure.

Acknowledgement. We will acknowledge the Complaint in writing within two business days of receipt, giving a reference number.

Investigation. The Complaint will be investigated by a person who was not involved in the matter complained about, under the oversight of the Compliance Officer. We may contact the Client for further information, and will keep the Client informed of progress.

Final Response. We will provide a Final Response within six weeks of receiving the Complaint. If the Complaint is upheld, the Final Response will set out the redress offered and how it will be provided.

Rejection or delay. If we reject the Complaint, in whole or in part, the Final Response will give our reasons in writing. If we reject the Complaint, or if it is not resolved within six weeks, we will inform the Client in writing that the Client may refer the Complaint to the FAIS Ombud within six months of receiving our Final Response, and will provide the FAIS Ombud's contact details.

FAIS Ombud. The FAIS Ombud is an independent body that resolves disputes between clients and financial services providers. A Client must first give GTC Global SA the opportunity to resolve the Complaint. The FAIS Ombud does not consider monetary claims exceeding R3 500 000, unless the FSP agrees in writing.

A South African Client may lodge a Complaint about the Broker either directly with the Broker, by email to support@gtcfx.com from the Client's registered email address, or through GTC Global SA using any of the means set out in section 05.

Where a Complaint about the Broker is lodged through GTC Global SA, we will record it in our complaints register and acknowledge it within two business days; refer it to the Broker within two business days of receipt, together with all information the Client has provided; give the Client the Broker's reference number and follow up with the Broker until it issues its Final Response; and record the outcome in our complaints register.

The Broker will acknowledge the Complaint within 48 hours of receipt, investigate it and aim to resolve it within four weeks. If that is not possible, the Broker will write to the Client to explain why. The Broker will provide its Final Response no later than eight weeks after receiving the Complaint.

If a Client is dissatisfied with the Broker's Final Response, the Client may pursue the remedies available under Part C of the Customer Terms Agreement, which is governed by the laws of the Autonomous Island of Anjouan, Union of Comoros. To the extent that a Complaint also concerns the conduct of GTC Global SA, for example information provided by GTC Global SA, that part of the Complaint may be referred to the FAIS Ombud in accordance with section 06.

The Compliance Officer reviews the Broker's handling of Complaints from South African Clients as part of the annual review of the Broker described in our Conflict of Interest Management Policy.

The Compliance Officer maintains a complaints register recording the required particulars of every Complaint received.

Complaint records, including correspondence and the evidence considered, are kept for at least five years after the Complaint is resolved, in accordance with the FAIS Act.