Complaints Procedure APF International

APF International gears the quality of its services to the wishes of its investors. As an investor, you are entitled to the best possible service and information. It may occasionally be the case that you are less than satisfied – or not at all – with the service and/or information provided, or with the way in which you have been treated by one of our staff. Please let us know in any event if you are in any way dissatisfied. Only in this way can we ensure that our service and information continue to be the best they can be.

In the paragraphs below, you can read what to do should you have a complaint, as well as what we will do with your complaint. You can also download the complaints procedure in full:

pdf Complaints procedure of APF International (Dutch version)

1. Responsibility and complaints file
The directors of APF International are responsible for the processing of complaints (hereinafter referred to in this document as ‘the party responsible for complaints’). A complaint file will be initiated for each complaint, containing at least the following data:
- the complainant’s name and address details;
- the name of the Fund concerned;
- the date of submission of the complaint;
- the name of the representative of the party responsible for complaints;
- a description of the complaint;
- the date and manner of resolving the complaint;
- the correspondence entered into in relation to the complaint;
- the status of the complaint (being processed/resolved).
The party responsible for complaints will manage the file relating to the complaint.

2. Procedure for submitting complaints
The following procedure must be followed when submitting a complaint:
- complaints must be submitted to APF International by telephone, in writing or through electronic communication;
- the complainant may at all times view the minimum prescribed data in the complaint file; viewing data other than the minimum prescribed data is at the discretion of the party responsible for complaints;
- the party responsible for complaints will confirm to the complainant in writing within 10 working days that the complaint has been accepted for processing and that a written response will be provided within six weeks (in the case of simple complaints) or within three months (in the case of complex complaints) of submission of the complaint. Should this term turn out not to be realistic, the complainant will be informed of this in good time (well before expiry of this term), stating the reason for the delay and the term within which a response can be expected.

3. Complaints processing procedure
For the processing of a complaint, the party responsible for complaints will follow the following procedure:
- study of the file concerned and collation of all further relevant information, including obtaining additional information from the complainant if necessary;
- assessment of the file and the further information obtained and review of this in relation to the arguments put forward by the complainant;
- discussion of the file with the management within the Fund as a check on the own interpretation;
- taking a position;
- informing the complainant of this position, in writing and with grounds;
- recording the position in the complaint file;
- informing the complainant about the possibility to appeal and pointing out to the complainant that a complaint may be submitted within 6 weeks to the Board of the Investment Custodian / Registrar of the fund in which the complainant participates and which the complaint concerns.

4. Appeal options
In the event that the complainant does not accept the position taken by the party responsible for complaints, an appeal may be made to the Board of the Investment Custodian / Registrar of the fund in which the complainant participates and which the complaint concerns.

Follow-up procedure, the Board:
- will study the file concerned by the complaint and collate all relevant information and obtain any further information from the complainant;
- will assess the file and the further information obtained and review this in relation to the arguments put forward by the complainant;
- discuss the file with the person responsible within the party responsible for complaints as a check on the own interpretation;
- take a position;
- inform the complainant of this position, in writing and with grounds;
- record the position in the complaint file;
- in the event of a continuing dispute, point out to the complainant the option of submitting a complaint within three months to the Klachteninstituut Financiële Dienstverlening (Ombudsman en Geschillencommissie) [Financial Services Complaints Institute (Ombudsman and Disputes Committee), KiFiD]. A continuing dispute is considered to be a dispute that has still not been resolved, having been through the internal follow-up procedure.

5. Adjudication of disputes
Complainants who are not in agreement with the position adopted by the party responsible for complaints and the Board have the opportunity to give a response. The moment of ‘closing the exchange of viewpoints’ is not a static moment. This may, for example, take place only after responses have been passed back and forth two or three times. The aim of this part of the abovementioned stipulation is to provide an opportunity to resolve the complaint amicably, naturally within limits, and to prevent an (overly) quick submission to the KiFiD.

6. Retention
The data from the complaint file will be kept for a period of at least one year after the complaint has been processed by the company.