Last updated August 2026
1. Overview
Capel Asset Management (“Capel”) takes complaints seriously and has measures in place to ensure they are handled promptly and fairly.
This Policy should be read alongside Capel’s Complaints Procedures. Together, these documents ensure fair and prompt handling of complaints in line with the FCA’s DISP rules, and support compliance with Article 26 of MiFID II and related ESMA guidance on complaints handling.
2. Scope
This Policy applies to all eligible complainants. Capel is, however, committed to treating all complaints equally, regardless of whether the complainant meets the FCA’s definition of an eligible complainant.
The FCA defines an eligible complainant as:
• A consumer — any natural person acting for purposes outside their trade, business or profession. This includes professional clients and eligible counterparties where the individual is acting outside their trade, business, craft or profession.
• A micro-enterprise — a business with fewer than 10 employees (full-time equivalent) and a turnover or balance sheet not exceeding €2 million (approximately £1.6 million).
• A charity with an annual income of less than £6.5 million.
• A trustee of a trust with a net asset value of less than £5 million.
• A guarantor — a person providing a guarantee or security (and who is not themselves a consumer, as defined under the FCA’s Dispute Resolution rules) in respect of an obligation or liability of a person that was a micro-enterprise or small business at the date the guarantee or security was given; or
• A small business — a business that is not a micro-enterprise, has an annual turnover of less than £6.5 million, and either employs fewer than 50 people or has a balance sheet total of less than £5 million.
3. What is a Complaint?
The FCA defines a complaint as any expression of dissatisfaction, spoken or written, whether justified or not, where a person says they are unhappy with the provision of, or failure to provide, a financial service — typically because they feel they have lost money, may suffer a loss, or have been seriously upset or inconvenienced.
A complaint may be made by any client, through any reasonable means — including letter, telephone, email, social media, or in person — and can always be submitted free of charge.
Complaints are dealt with quickly and fairly. Where a complaint cannot be resolved to the complainant’s satisfaction, an eligible complainant may refer the matter to the Financial Ombudsman Service (FOS).
4. Complaint Management Function
Capel’s Chief Operational Officer & Head of Portfolio Management as the Complaint Management Function (CMF) and oversees all investigations into complaints raised, ensuring that each investigation is carried out in line with Capel’s Complaints Procedures.
The CMF is responsible for identifying and remedying any recurring or systemic issues through root cause analysis and remedial action reporting. The CMF and Compliance both report complaints data to the Executive Board on a quarterly basis.
5. Training
Teams who deal directly with customers and/or advisers are required to undertake complaints-handling training on an annual basis.
6. Complaint Procedures
On receipt of a complaint, Capel sends an acknowledgement to the complainant within three working days, confirming that the complaint is being handled. Where the complaint can be resolved within three working days, Capel issues a summary resolution communication explaining that it considers the matter resolved.
As part of its investigation, Capel will:
• assess the evidence available and the specific circumstances of the complaint;
• review relevant records and speak to the individuals involved;
• consider similarities with other complaints raised with Capel; and
• take account of any relevant guidance published by the applicable regulatory bodies.
During the investigation, Capel provides regular updates on progress and realistic timeframes for issuing its “Final Response”. Capel aims to issue a final response as soon as possible, and no later than eight weeks from receipt of the complaint. Depending on the outcome, Capel may offer redress and/or take remedial action.
7. Compliance Monitoring
Compliance conducts regular monitoring of complaints to identify and address risks or issues, including any deviation from Capel’s procedures, and implements adjustments or additional staff training where required.
8. Record Keeping
The CMF records every complaint in the complaints register, including details of each stage of the process, the individual who dealt with the complaint, the location of evidence used to assess it, whether the complainant is an eligible complainant, whether the complaint is upheld, any remedial action or redress required, and confirmation that this has been completed.
The CMF is responsible for ensuring that complaint records are retained for at least five years from the date the complaint was received.
How to contact us to make a complaint?
To make a complaint, please email us at: complaints@capelasset.com and a member of the team will respond within 1-3 working days.
Whistleblowing concerns
If you believe that you have witnessed something which contravenes our standards of personal or business conduct, we will support you in raising a whistleblowing concern. All concerns raised are taken seriously and fully investigated. The identity of staff, suppliers, members from the public or clients who raise a concern will be kept confidential and will not be discriminated against in any way because of raising their concern.
We are committed to taking all reasonable steps to maintain the confidentiality of the whistle blower unless required by law. Any abuse towards the individual making the disclosure will result in disciplinary action, including, in appropriate circumstances, dismissal.
Please send your concerns to: complaints@capelasset.com (same email address as complaints).