Customer Complaints
Background
Investment managers have a fiduciary duty to clients and complaints are taken very seriously. This policy details key steps that are taken regarding any such complaints.
Definitions
A client complaint is a request by a client for corrective action or any written statement of a client or person representing a client alleging a grievance related to the management of the client’s account.
Policy
It is Mellon Capital’s policy to monitor, review and promptly address all client related complaints and concerns.
Procedure
The Mellon Capital client relationship officers are responsible for identifying client 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 Client Service North America and/or the Director of Client Service International who will share the information with the Chief Compliance Officer and guide the conflict resolution process. The Managing Director of Client Service North America and/or the Director of Client Service International will notify other members of Senior Management as appropriate and maintain a written record of the client complaint in a client complaint log.
The client complaint log should contain the following information:
- Complaint details, circumstances and background;
- Notations regarding correspondence to/from the client 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.
Mellon Capital’s Chief Compliance Officer (CCO) will determine if client complaints should be further communicated to Bank of New York Mellon Corporation’s Ethics Office. Client complaint information will be addressed with Mellon Capital’s 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 Mellon Capital Compliance Department will contact the Managing Director of Client Service North America and the Director of Client Service International to determine if there have been any client 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 Client Complaint Policy.
Client complaint documentation will be retained in accordance with Mellon Capital’s Record Retention policy.
Contact Information
For customer complaint handling, please contact:
In U.S. or Canada:
David Dirks
Managing Director, Client Service, North America
BNY Mellon Center
201 Washington Street
Boston, MA 02108
Email: davidd@mcm.com
Phone: 617-248-4562
Outside of U.S and Canada:
Keiko KaiDirector, International Client Service
50 Fremont Street, Suite 3900
San Francisco, CA 94105
Email: keikok@mcm.com
Phone: 415-975-3556
Fax: 415-777-5699

