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Background

Global Finance Capital have a fiduciary duty to customers and complaints are taken very seriously. This policy details key steps that are taken regarding any such complaints.

Definitions

A customer complaint is a request by a customer for corrective action or any written statement of a customer or person representing a customer alleging a grievance related to the management of the Global Finance Capital or client’s account.

Policy

It is Global Finance Capital policy to monitor, review and promptly address all customer related complaints and concerns.

Procedure

The Global Finance Capital customer relationship officers are responsible for identifying customer complaints in accordance with the foregoing definition. Upon identification, the relationship officer is responsible for forwarding the information detailed below to the Managing Director of Customer Service and/or the Director of Customer Service International who will share the information with the Chief Compliance Officer and guide the conflict resolution process. The Managing Director of Customer Service International and/or the Director of Customer Service International will notify other members of Senior Management as appropriate and maintain a written record of the customer complaint in a customer complaint log.

The customer complaint log should contain the following information:

Complaint details, circumstances and background;

Notations regarding correspondence to/from the customer per the complaint;

Escalation of the issue to senior management and others, as warranted; and

Resolution of the complaint or actions taken to address the concerns.

Global Finance Capital Chief Compliance Officer (CCO) will determine if customer complaints should be further communicated to C & F Group Ethics Office. Customer complaint information will be addressed with Global Finance Capital Board of Directors on a bi-annual basis through the Key Risk Indicator reporting mechanism, unless more frequent communication is determined to be appropriate by the Chief Compliance Officer.

On a monthly basis, the Global Finance Capital Compliance Department will contact the Managing Director of Customer Service International and the Director of Customer Service International to determine if there have been any customer correspondence that may be deemed a complaint and that the concerns have been brought to the attention of the appropriate personnel within the firm, in accordance with this Customer Complaint Policy.

Customer complaint documentation will be retained in accordance with Global Finance Capital Record Retention Policy (RRP).

Contact Information

For International customer complaint handling, please contact:

Email: complaints@globalfinancecapital.com

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