Complaints Handling Policy

01Our commitment

If something has gone wrong, we want to know. A complaint is not a nuisance to us — it is the fastest way we find out that a process, a system or a person has failed, and it is the only way we can put your particular case right.

This policy explains what counts as a complaint, how to raise one, who looks at it, how long it takes, and what happens if our answer does not satisfy you.

Raising a complaint is free. It will not affect your trading conditions, your access to your account, or the speed at which your withdrawals are processed. We will not close an account, restrict it, or worsen its terms because a client has complained.

02What this policy covers

A complaint is any expression of dissatisfaction, whether or not justified, about our services, our conduct, or a decision we have taken — including, for example:

A question, a request for an explanation, or a technical support issue is not a complaint, and is usually resolved faster through ordinary support. If you would rather it were treated as a complaint, say so and it will be. If in doubt, send it — we would rather log something that turns out to be a query than miss a complaint.

• the execution of an order: the price, the delay, the slippage, a rejection, or a stop-out;
• a charge, spread, commission or swap applied to your account;
• a deposit or withdrawal that has not been processed as expected;
• a restriction, suspension or measure applied to your account;
• the conduct of a member of our staff, or of an introducing partner who introduced you to us;
• the operation of our Copy Trading service, including the accuracy of a displayed statistic or the behaviour of the copying mechanism;
• the operation of a pooled (PAMM) account: the calculation of your share, the high-water mark applied to it, a fee charged against it, or the handling of a rollover;
• the operation of a programmatic interface, including a rate limit, a rejected request or a credential suspension;
• information given to you that you believe was wrong or misleading;
• the handling of your personal data.

03How to raise a complaint

Where to send it

Email [email protected], or use the complaints form in the Client Portal. Both reach the Compliance function directly.

You may also raise a complaint with any member of our staff, by any channel, and they are required to pass it on. But a complaint sent to trading, sales, support or a partner has to be forwarded first — the response clock in section 5 starts when Compliance receives it, so sending it to the address above is faster.

What to include

So that we can investigate without a round of follow-up questions, please tell us:

When to raise it

If your complaint is about a specific transaction, please raise it within five (5) business days of the event. That is not a deadline for accepting your complaint — we will not refuse to consider one solely because it was raised later — but trade records, price feed data and market conditions are far easier to reconstruct while they are fresh, and a long delay may limit what we can establish.

Language

We handle complaints in English. If you are more comfortable writing in another language, send it in that language and we will arrange translation. You will not be disadvantaged by it, and it will not delay the acknowledgement.

If someone is complaining on your behalf

A representative may complain for you provided we hold a valid authorisation from you, or you confirm the authorisation in writing from the email address registered on your account. We cannot discuss your account with anyone we have not verified as authorised.

• your full name and account number;
• the date and time of the events you are complaining about, and the time zone you are quoting;
• the ticket number of any order or position concerned;
• the channel you used, and the name of the person you dealt with if relevant;
• what happened, in your own words;
• what you would like us to do to put it right;
• any screenshots, statements or correspondence that support your account of events.

04Who reviews your complaint

Your complaint is investigated by our Compliance function, by a person who was not involved in the matter you are complaining about and who does not report to the person or team concerned.

The dealing desk and the client-facing teams do not decide the outcome of complaints about their own work. Where a complaint concerns Compliance itself, it is escalated to a senior officer outside that function.

05Timeframes

Business days are calculated by reference to Saint Lucia public holidays. If a deadline falls due while we are waiting on information from you, the clock pauses until you reply — and we will tell you when that happens rather than let it lapse silently.

06How we investigate

• We log it. Every complaint is entered in our complaints register with a reference, a category and an owner.
• We gather the evidence. This ordinarily includes the server log, your trading history, our price feed record for the relevant period, platform telemetry, call recordings and chat transcripts, and the internal records of any decision taken about your account.
• We reconstruct what happened against that evidence, rather than against recollection.
• We decide whether our conduct was correct, and separately whether — even if it was — the outcome for you was fair.
• We respond in writing, setting out the decision, the reasons, the evidence relied on, any remedy, and how to take the matter further if you disagree.
• We look for the cause. Where a complaint reveals a defect in a process or a system, it is recorded and fixed, not just settled for the individual client.

07The evidence we rely on

The server log is the primary record of what happened on your account: what was received, validated, executed, modified, rejected or cancelled, and when. All times are platform server time, UTC+3.

Where the server log conflicts with the log of your own terminal, the server log ordinarily prevails, because a terminal log can be incomplete if your connection was interrupted. Where the server log contains no entry for an instruction you say you gave, that is strong evidence it did not reach us — but it is not conclusive, and we will weigh whatever else is available, including your own screenshots and correspondence.

If your complaint concerns a measure taken under the prohibited practices and toxic order flow provisions of the Client Agreement, we will provide you with the trade-level data underlying the finding, so that you can see exactly what was measured and over what period.

If your complaint concerns a pooled account, we will provide the calculation of your share, its high-water mark and any fee charged against it, derived from the records of the pooled account itself.

08Possible outcomes

If we uphold your complaint, we will put you, so far as reasonably possible, in the position you would have been in had the matter not occurred. Depending on the case, that may mean:

We do not compensate for a profit you say you would have made on a transaction you did not in fact place, for indirect or consequential loss, or for distress or inconvenience, save where the law requires otherwise.

If we do not uphold your complaint, we will tell you plainly why, and identify the evidence that led us there.

• a credit to your trading account, applied within one business day of the decision;
• the reversal or re-pricing of a transaction;
• the refund of a charge, or the recalculation of a share or a fee;
• the restoration of a position or of account conditions;
• the lifting of a restriction;
• a correction to your records, and an apology.

09What we will not uphold

To be straightforward with you, the following are unlikely to succeed on their own:

That said, none of these is automatically excluded. If you believe your case is different, tell us why and we will look at it.

• the time taken to process an order, where that time was consistent with the market conditions prevailing at the moment;
• an order not processed during scheduled maintenance that was notified in advance, whether or not you saw the notice;
• a difference between our price and a price published by another broker, a charting service or an information vendor;
• slippage, gapping or a stop-out that occurred as the platform is designed to operate and as the Client Agreement describes;
• the loss made by a strategy you chose to copy, or by a pooled account you chose to invest in, where the mechanism operated as described;
• the inability to withdraw from a pooled account between rollover points, which is how the allocation mechanism works and is disclosed before you invest;
• a refusal to delete verification records that we are required to retain. Our Privacy Policy explains the obligation and the seven-year period. We will always explain how it applies to your file, and we will close or suspend your account on request — but the retention itself is not a decision we are able to reverse;
• the outcome of a trading decision you took.

10If you are still not satisfied

Step one — internal review

You may ask for your complaint to be reviewed by a senior officer of the Company who was not previously involved. Reply to our final response asking for a review, and tell us which parts of the decision you disagree with and why. The review is completed within 20 business days.

Step two — legal remedies

You may pursue the matter under the governing law and jurisdiction provisions of the Client Agreement, which apply the law of Saint Lucia and the jurisdiction of its courts. Using this policy first is not a precondition to doing so, and nothing here limits any right you have under the law of the country in which you are habitually resident.

An honest word about external escalation

NPE Market Limited is an International Business Company registered in Saint Lucia (registration number 2024-00497), and is registered with the United States Financial Crimes Enforcement Network as a Money Services Business (number 31000317305002). It is not licensed or supervised as an investment firm by a financial services regulator.

Neither registration gives you an external complaints route. FinCEN is a financial-intelligence bureau: it does not supervise conduct and does not adjudicate disputes between a registered business and its clients. There is therefore no financial ombudsman service, statutory dispute-resolution scheme or investor compensation scheme available to you in respect of the Company, and we will not suggest otherwise.

The parties may agree to refer a dispute to mediation or to arbitration in Saint Lucia before commencing proceedings. Neither is compulsory, and neither removes your right to go to court.

We set this out plainly because it matters: with no external adjudicator behind us, the quality and independence of our own process is the protection you have. We take that seriously, and this policy is the standard we expect to be held to.

11Complaints about a partner, provider, manager or third party

An introducing partner is not our agent and has no authority to advise you, to make representations about our services, to vary your agreement with us, or to handle your money. If a partner has done any of those things, tell us — we will investigate their conduct and act on it, including by ending the relationship.

A strategy provider on our Copy Trading service, and a manager of a pooled account, are clients of ours rather than employees or agents. We will investigate anything within our control — whether the figures we displayed or calculated were correct, whether the mechanism performed as described, and whether the provider or manager breached the Client Agreement — and we will act on what we find, including by delisting a strategy or suspending a manager. We cannot compensate you for the trading result of a strategy or a pool you chose.

Where the substance of your complaint concerns a third-party account manager or signal service operating outside our platform that you authorised, we will investigate anything within our control, but we cannot resolve a dispute between you and a person we neither appointed nor supervise.

12Records and oversight

Every complaint, its investigation and its outcome are recorded and retained for at least seven years. The complaints register is reviewed periodically by senior management for patterns and root causes, so that recurring issues are corrected at source rather than settled one client at a time.

Complaint records are personal data and are handled in accordance with our Privacy Policy.

13Review of this policy

This policy is reviewed at least annually, and on any material change to our business or to applicable law. The version published on this page is the current version.

To raise a complaint: [email protected] | General enquiries: [email protected]