Complaint Handling Guide June 2025

Gravis (“Gravis Capital Management Ltd”, Gravis Advisory Ltd, “we”, “our”) takes care to maintain high standards of service. If we become aware of client or investor concerns or unease we seek to resolve the matter as quickly as possible. We have procedures in place to ensure complaints are handled fairly and within reasonable timescales. These are summarised below.

Upon receipt of a complaint, a senior person (you will be given the name and contact details) will investigate the complaint. Our aim will be to resolve the complaint as quickly as possible. The person investigating your complaint will:

• initiate a record and file of your complaint; and

• acknowledge your complaint as soon as is reasonably practicable. This will generally be within five working days.

The acknowledgement may, especially in the case of an oral complaint, set out the nature of the complaint and may request further clarification if necessary. Your complaint will be investigated using our files together with reports from other parties if relevant. We may write to you if further information is required. We will keep you informed of the progress of the investigation.

After eight weeks: If a final response letter has not already been sent to you, you will receive;

• A final response letter detailing our conclusions and proposal for resolution. This letter will also confirm that should you remain dissatisfied with the final response you may, within six months of the letter refer your complaint to the Financial Ombudsman Service, otherwise you would lose this referral right. A copy of the Financial Ombudsman Service leaflet ‘your complaint and the Ombudsman’ will be enclosed, if not already supplied.

OR

• A response that we are still not in a position to make a final response, giving the reasons for the further delay and indicating when we expect to be able to provide a final response;

AND

• Informing you that you may refer your case to the Financial Ombudsman Service if you are dissatisfied with the delay. A copy of the Financial Ombudsman Service leaflet ‘your complaint and the Ombudsman’ will be enclosed, if not already supplied.

If your complaint involves information from third parties delays may be beyond our control.

In the event that we receive a complaint that is not about us, or our services, and assuming that we can identify the firm to whom the complaint should be addressed, we will write to you, giving contact details of the firm, and invite you to get in touch with them. We will not forward personal information without your permission.

Please refer to www.financial-ombudsman.org.uk for more information.