Complaints Handling Policy

1. Purpose

Rest is committed to handling complaints fairly, promptly, consistently, and transparently in accordance with:

The FCA's Dispute Resolution rules (DISP)
The complaints handling standards of our Principal Firm, RiskSave Technologies Ltd
Our obligations as an Appointed Representative

This policy sets out:

What constitutes a complaint
Who is eligible to complain
How complaints are handled and escalated
Customers' rights to refer complaints to the Financial Ombudsman Service (FOS)
Record-keeping, reporting, and governance arrangements

2. Scope

This policy applies to:

All customers of Rest Capital Ltd
All complaints relating to services provided by or on behalf of Rest
All team members involved in customer interactions or complaint handling
All regulated activities carried out under our Appointed Representative arrangement with RiskSave Technologies Ltd

3. Definition of a Complaint

In line with FCA DISP rules, a complaint is:

Any expression of dissatisfaction, whether oral or written, whether justified or not, about the provision of, or failure to provide, a service by Rest, which alleges that the complainant has suffered (or may suffer) financial loss, material distress, or material inconvenience.

4. Eligible Complainants

For the purposes of FCA complaints handling and FOS referral rights, an Eligible Complainant includes:

A consumer
A micro-enterprise (fewer than 10 employees and annual turnover or balance sheet not exceeding €2 million)
A small charity (annual income under £6.5 million)
A small trust (net asset value under £5 million)

Only Eligible Complainants have the right to refer complaints to the Financial Ombudsman Service.

5. How to Make a Complaint

Customers may submit a complaint via:

Email: complaints@rest.capital
Customer Support: where a complaint will be logged on the customer's behalf

Customers are encouraged to provide:

Name and contact details
Description of the complaint
Relevant dates and supporting information

Rest publishes this complaints procedure and FOS information on its website to ensure customer awareness.

6. Complaints Handling Standards

Rest will ensure all complaints are handled:

Fairly
Impartially
Competently
Diligently
Consistently

Rest does not charge any fees in relation to the assessment or handling of complaints.

All communications with complainants must be in plain language that is clear and easily understood. Technical, legal, or regulatory terminology should be explained where its use is unavoidable.

7. Complaints Handling Process

7.1 Acknowledgement

All complaints will be acknowledged promptly and in any event within three (3) business days of receipt.

7.2 Logging and Notification

All complaints must:

Be logged in RiskSave's complaints management system (Symbiant) without delay
Be notified to RiskSave Compliance

Rest will not issue any substantive complaint response — including Summary Resolution Communications for complaints resolved within three business days — without RiskSave's review and approval.

7.3 Investigation

Rest will:

Investigate the complaint thoroughly
Gather all relevant evidence and information
Cooperate fully with RiskSave Compliance

7.4 Quick Resolution (within 3 business days)

Where a complaint is resolved within three business days, Rest may issue a Summary Resolution Communication in line with DISP requirements and RiskSave guidance. RiskSave approval is required before any response is issued to the complainant, including for complaints resolved within three business days. The complaint must still be logged in Symbiant and notified to RiskSave in accordance with Section 7.2.

7.5 Ongoing Updates

Where a complaint is not resolved promptly, customers will receive:

Regular updates at least every three weeks on progress

7.6 Final Decision Notice (FDN)

A Final Decision Notice must be issued within eight (8) weeks of receipt of the complaint. The sequencing is as follows:

Rest prepares the draft FDN, including the proposed outcome and any redress
The draft FDN is submitted to RiskSave Compliance for review and approval
Rest does not issue the FDN to the customer until RiskSave has given written approval
Once approved, the FDN is sent to the customer

Rest must allow sufficient time within the 8-week window for RiskSave's review. Draft FDNs should be submitted to RiskSave no later than 5 business days before the 8-week deadline.

The FDN will:

Clearly state Rest's position and any redress offered
Include the Financial Ombudsman Service leaflet or link
Provide FOS contact details
Explain the six-month time limit for referral to FOS
Include any regulatory waiver statements where applicable

If the 8-week deadline will be exceeded (for example, due to the complexity of the investigation), Rest must issue a holding letter before the deadline explaining the delay and informing the customer of their right to refer the complaint to FOS.

7.7 Redress

When assessing the appropriate outcome of a complaint, the person investigating the complaint must consider whether a fair response requires redress. In particular, the following factors must be considered:

Whether there has been any financial disadvantage to the customer
Whether the customer has suffered stress or inconvenience
Whether, in light of the above and the customer's individual circumstances, any form of redress is appropriate — whether to remediate a financial loss and/or to compensate for inconvenience and distress

Any proposed redress must be included in the draft FDN submitted to RiskSave for approval.

8. Complaints Involving Regulated Activities

Where a complaint relates to regulated activities carried out under Rest's Appointed Representative arrangement — including but not limited to:

Custody of assets
Safeguarding of client money
Execution of transactions
Any activity undertaken by or through WealthKernel

The complaint will:

Be escalated immediately to RiskSave Compliance
Be handled in accordance with RiskSave's complaints procedures
Remain subject to RiskSave's approval and oversight

Rest may liaise with WealthKernel where relevant but remains accountable to RiskSave as Principal Firm.

9. Financial Ombudsman Service (FOS)

If an Eligible Complainant is dissatisfied with the Final Decision Notice, or if eight weeks have passed without resolution, they may refer the complaint to:

Financial Ombudsman Service Website: www.financial-ombudsman.org.uk Telephone: 0800 023 4567

The right to refer and applicable time limits will be clearly communicated in the Final Decision Notice.

10. Record Keeping

Rest will:

Maintain complete records of all complaints, investigations, correspondence, and outcomes
Log all complaints in Symbiant
Retain records for a minimum of six (6) years, consistent with RiskSave's record retention obligations (STOB clause 12.3)

Records will be made available to RiskSave and for regulatory reporting purposes.

11. Reporting Requirements

Rest will support RiskSave in meeting FCA reporting obligations by:

Ensuring accurate and timely complaint logging
Maintaining complete complaint records
Providing any information required for the FCA biannual complaints return

12. Monitoring, Governance, and Improvement

Complaints data will be reviewed by Rest management and RiskSave Compliance for:

Trends
Root causes
Conduct risks
Customer outcomes

Findings will be used to drive service improvements and risk mitigation.

13. Breaches, Risk Escalation, and Waivers

Where a complaint identifies:

A regulatory breach
A material risk
Issues outside RiskSave's risk appetite

Rest will:

Escalate the matter to RiskSave Compliance within 24 hours
Log the issue in line with RiskSave's breach and risk management processes

Any DISP waivers or exceptional handling will follow RiskSave's formal waiver process.

14. Roles and Responsibilities

14.1 CEO

Ultimate accountability for complaints handling
Approval of this policy
Oversight of complaints trends and root cause analysis

14.2 All Team Members

Identify and log complaints promptly
Escalate complaints to management
Cooperate with complaint investigations
Maintain professional standards in customer interactions

14.3 RiskSave Compliance

Review and approve Final Decision Notices
Oversight of complaints handling procedures
Support with regulatory reporting

15. Contact Details

For complaints or questions about this policy:

Email: complaints@rest.capital

Document Control

Version	Date	Author	Changes
1.0	2025-01-XX	Joe Kemsley	Initial version
2.0	10 February 2026	Joe Kemsley	Standardized format, updated effective date
2.1	6 March 2026	Joe Kemsley	Aligned retention to 6 years (STOB 12.3), clarified FDN/RiskSave approval sequencing
2.2	25 March 2026	Joe Kemsley	Added RiskSave approval for 3-day resolutions, redress factors, no-fees statement, plain language requirement, FDN template annex

Approval

Role	Name	Signature	Date
CEO	Joe Kemsley

Appendix A: FCA Regulatory Mapping

This policy addresses the following FCA requirements:

Requirement	Source	Section
Complaint definition	DISP 1.2	3
Eligible complainants	DISP 2.7	4
Complaint acknowledgement	DISP 1.5	7.1
Three-day resolution	DISP 1.6	7.4
Eight-week response	DISP 1.6	7.6
FOS referral rights	DISP 1.9	9
Record keeping	DISP 1.9	10
Complaints reporting	DISP 1.10	11
AR oversight	SUP 12.6	7.2, 8

Appendix B: Complaints Handling Flowchart

Complaint Received
       ↓
Acknowledge within 3 business days
       ↓
Log in Symbiant + Notify RiskSave
       ↓
Can resolve within 3 business days?
   YES → Draft Summary Resolution → Submit to RiskSave for approval → Issue to customer → Close
   NO  ↓
       ↓
Investigation (regular updates every 3 weeks)
       ↓
Prepare draft FDN
       ↓
Submit draft FDN to RiskSave (no later than 5 days before 8-week deadline)
       ↓
RiskSave approves FDN?
   YES → Issue FDN to customer (within 8 weeks of receipt)
   NO  → Amend and resubmit
       ↓
8-week deadline at risk?
   YES → Issue holding letter + inform customer of FOS referral right
       ↓
Customer satisfied with FDN?
   YES → Close complaint
   NO  → Customer may refer to FOS (within 6 months)

Appendix C: Final Decision Notice (FDN) Template

The following template should be used when preparing a Final Decision Notice for RiskSave approval.

Dear [Customer Name],

Final Decision Notice — Your Complaint of [DATE]

Summary of Your Complaint

[Include a summary of the complaint received and the timeline of events.]

Our Assessment

[Include how you have come to a conclusion and why. Set out the evidence considered and the reasoning applied.]

Conclusion

[In clear, plain language, state whether the complaint is accepted (wholly or partially) or rejected, and confirm that this is Rest's final response.]

[Where redress is offered, state the amount and basis — whether for financial disadvantage, stress and inconvenience, or both.]

Your Right to Refer to the Financial Ombudsman Service

If you are not satisfied with this response, you have the right to refer your complaint to the Financial Ombudsman Service, free of charge. You must do so within six months of the date of this letter.

Financial Ombudsman Service Website: www.financial-ombudsman.org.uk Telephone: 0800 023 4567

Yours sincerely,

[Name] [Role] Rest Capital Ltd