Overview
Fi360 takes all complaints seriously and shall investigate any legitimate complaint against a candidate, designee, Fi360, Inc., the designation program, a specific policy or an Fi360 employee. This article provides the official complaints procedure. In summary, complainants shall submit the form attached to this article to Fi360support@broadridge.com to initiate the process.
Submitting a Complaint
Fi360 shall maintain on its website a facility for the filing of complaints against a designee. Complaints may be filed by clients, by other designees, or by third parties. Employees of Fi360 may file complaints based upon information that comes to their attention from a source that they deem reliable, whether publicly available or not.
Reviewing a Complaint
Fi360 shall review the complaint and have the power to request or obtain any information they deem necessary or desirable for the review. Fi360 shall notify any candidate or designee to whom the complaint has been made.
Initial Assessment
Fi360 shall make an assessment of the complaint. If Fi360 believes that a violation of the Conduct Standards may exist, Fi360 shall conduct further investigation as shall be deemed necessary to determine the existence and gravity of the violation(s).
Recommendation
When Fi360 has determined the existence and gravity of a violation of the conduct standards, they shall make a recommendation stating both the conclusion as to the existence and gravity of the violation and whether revocation of the designation is appropriate. Fi360 may conclude that, while a violation did occur, the gravity of the violation was so slight that it does not merit immediate revocation, but instead a period of monitoring to verify continued good regulatory standing and adherence to the Code of Ethics and Conduct Standard. Likewise, if the incident is ongoing, Fi360 may recommend a period of monitoring with no immediate action taken. This recommendation shall be delivered to the complainant, the designee, and the Appeals Board (if applicable).
Opportunity to Answer
The designee shall have a reasonable opportunity to review the recommendation and to file an answer to the recommendation. If the designee contests the decision, a live hearing of the Appeals Board will be conducted virtually. If the designee determines not to contest the recommendation, the recommended sanction shall be imposed. If the designee surrenders their designation, they will become ineligible for the designation, subject to the requirements of the Qualifications and Complaints Procedure.