Complaints Policy

GIFT, ENTERTAINMENT OR BENEFIT POLICY

Trex Global Ltd staff must not directly or indirectly solicit a gift, entertainment or benefit, from any Client or business related third party, for their benefit or for the benefit of others. Trex Global Ltd staff should not put themselves in a position where it could appear that their independence or judgment has been compromised by the acceptance of any such gift, entertainment or benefit. Any gift, entertainment or benefit received must not give rise to a conflict of interest.

Cash gifts should NOT be accepted in any circumstances. In principle, gifts, entertainment or benefits of MUR 200 (Mauritian Rupees Two Hundred) or above must be disclosed to the Legal & Compliance Department by completing the Gift, Entertainment or Benefit Disclosure Form. The estimation of the gift, entertainment or benefit should be as per the current conversion rate.

RECORD KEEPING POLICY

Trex Global Ltd keeps all records in relation to its activities as required by the law. Records comprise of full and true written details of every transaction that the company conducts:

The records are kept:

In physical form or electronic data storage in the computers’ hard disc;
For a period of at least 7 years after the completion of the transaction to which it relates;
At the registered office of Trex Global Ltd or such other place as may be agreed; and
For identification purposes as per the index of each file.

Pursuant to section 17F of FIAMLA 2002, Trex Global Ltd must keep such records, registers and documents as prescribed in Regulation 17F(2) of the FIAML Regulations 2018.Furthermore section 29 of the Financial Services Act 2007 requires Trex Global Ltd to keep and maintain internal records of the identity of each Customer as well as full and true written records of all transactions relating to his business activities.

Trex Global Ltd is also required to maintain the following records on the suspicious reports being filed:

The internal suspicion reports received by the MLRO;

Records of action taken under the internal and external reporting requirements;
When the MLRO has considered information or other material concerning the reports, but has not made a disclosure of suspicion to the FIU, a record of the information or material that was considered and the reason for the decision; and
All reports made by the MLRO to the FIU.

Trex Global Ltd is also required to maintain records of all AML/CFT training delivered to employees. Records should include:

The dates AML/CFT training was provided;
The nature of the training, including details of contents and mode of delivery; and
The names of the employees who received training

CONFLICT OF INTEREST POLICY

a conflict of interest arises when any director, shareholder or employee of the Company unfairly places his/her interests above those of the client. The Company should place the client’s interests above its own, thus meeting the reasonable expectation of a properly informed client.

Trex Global Ltd ensures to take reasonable steps to avoid a conflict of interest arising or, where conflicts arise, shall ensure fair treatment for all its clients by full disclosure of material facts, internal rules of confidentiality, declining to act or otherwise.

ADDRESSING CONFLICTS OF INTEREST

In order to gain the confidence of the authorities as to its objectivity and impartiality, rules and procedures is established by the Company to guarantee that:

Conflicts of interest are treated in a lawful and ethical way;
In the conduct of their duties, directors and employees of the Company:

will arrange their private affairs in a manner that will prevent real, apparent or potential conflicts of interest from arising;
will not solicit or accept transfers of economic benefit;
will not step out of their roles to assist other outside entities or third parties in their dealings where this would result in a preferential treatment to the latter;
will not knowingly take advantage of, or benefit from, any information that is obtained in the course of their official duties;

Where Trex Global Ltd has a material interest in a transaction to be entered into with or for a client, or a relationship which gives rise to a conflict of interest in relation to such a transaction, Trex Global Ltd shall not knowingly either advise, deal or otherwise act in relation to that transaction or relationship unless it has:

fairly disclosed that material interest or relationship, as the case may be to the client; or
taken reasonable steps to ensure that neither the material interest nor relationship adversely affect the interests of the client.

In order to minimize potential conflicts of interests, Trex Global Ltd will clearly disclose all identified sources of conflicts to the client, before the latter enters into any contractual relationship with the company.

A conflict of interest register is maintained by the Legal & Compliance Department detailing all conflicts of interest including:

all conflicts of interest notification;
any reported cases of failure to disclose;
disclosure by others, such as colleagues or clients;
assessment of the matter and how it was considered;
any action taken; and
any reviews of the assessment process.

The information recorded in the register and documents evidencing the conflict of interest are kept for at least 7 years.

TRANSACTION MONITORING POLICY

Transactions will be rated as either of these:

1.Level 1 - Low Risk

Transactions below a threshold of USD 8,000 or its equivalent in foreign currency will be classified as Low Risk.

2.Level 2 - Medium Risk

Transactions exceeding a threshold of USD 8,000 or its equivalent, but below that of USD 50,000 or its equivalent will be classified as Medium Risk.

3.Level 3 - High Risk

Transactions exceeding a threshold of USD 50,000 or its equivalent will be classified as High Risk.

Irrespective of the above classifications and amount, transactions will be classified as high-risk if:
Transactions involving clients rated as ‘High Risk’
Transactions involving PEP clients
Transactions where transfer instructions and other communications were
received from an email address different from that initially provided by the client.

PROCEDURE FOR TRANSACTION MONITORING

After client onboarding, the client will deposit funds into the client account of the company.
The Transaction Monitoring Executive will ensure that all CDD documents and evidence of source of funds are on file.
The Transaction Monitoring Executive will go through the bank statement/ any platform set up by the Company on a daily basis regarding inflow and outflow of funds.
If need be, additional documentations will be requested or client will be queried.

How can you make a complaint?

You can make a complaint by any reasonable means - for example by letter, email, telephone or in person. Written complaints can be sent to:

Trex Global Ltd

C/o Legacy Capital Co Ltd,

Suite 201, 2nd Floor,

The Catalyst, 40 Silicon Avenue,

Cybercity

Ebene, 72201,

Republic of Mauritius

Email: cs@trexglobals.com.

Response

If no response has been communicated to confirm the receipt of the complaint, please use another method of sending that is listed above.

What will we do once we have received your complaint? Your complaint will be referred to our Compliance Manager, as soon as possible. In the event that the Compliance Manager is involved in the subject matter of the complaint, your complaint will be referred to another Director/Manager of Trex Global Ltd. We will promptly acknowledge your complaint in writing. In this acknowledgement we will provide the name and title of the person that is handling your complaint. This individual will have the authority necessary to investigate and settle the complaint. We will also include a copy of this policy.

Investigating and resolving your complaint We will investigate your complaint fairly, consistently and promptly, determine whether the complaint should be upheld, and (if appropriate) determine remedial action and/or redress. We will set out our conclusions in a final response to you. If we decide that redress is appropriate, we will aim to provide you with fair compensation for any acts or omissions for which we are responsible. If you accept our offer, we will promptly provide a compensation to you.

Our timetable for responding to you Once we have acknowledged your complaint, we will keep you informed of our progress. Within fifteen (15) days of us receiving your complaint we will send you either a final response or a written response which:

explains why we are not in a position to make a final response to you and when we might be expected to provide one;
informs you whether you are now entitled to refer the complaint to the "Office of Ombudsperson for Financial Service and if so
encloses a copy of the FOS standard explanatory leaflet.

Financial Ombudsman Service (“FOS”) If you are an eligible complainant you are able to refer a complaint to the FOS if you are not satisfied with the outcome of your complaint. Your rights are set out in the FOS’s leaflet “Your Complaint and the Ombudsman” which we will provide to you as part of the Complaints process. Please remember that if you wish to refer a complaint to the FOS, you must do so within six months of receiving our final response. You should allow us to complete our internal Complaints Procedure before you refer your concerns to FOS.

Closing complaints We will regard your complaint as closed in the following circumstances:

once we have sent you a final response; or
where you have told us in writing that you accept an earlier response that we have sent to you; or
if you refer your complaint to FOS, when FOS informs us in writing that the complaint has been closed.

Trex Global Ltd is committed to ensuring that all complaints received are handled fairly, consistently and promptly and that the firm identifies and remedies any recurring or systematic problems, as well as any specific problems identified by a complainant. We will continue to do all we can to learn from the complaints we receive to improve our level of service to you in the future.

Questions

If you have any questions about our complaints process, please contact us at cs@trexglobals.com, we are always happy to assist