In force from 2020-07-03

Complaints Handling Procedure

This procedure applies to CFD Trading service. You can access and download a copy of this document at any time from

This is a specific procedure that will apply when you use CFD Trading Service i.e. trade CFDs directly with Indexa B.V. using Change Apps and lodged a Complaint. In this procedure:

  • “Apps” mean the web, Android and iOS mobile apps of Change, which give access to the Services;
  • “Change” means third party xChange AS, an Estonian public limited company registered under registry code 14428150, Rävala pst 4, 10143 Tallinn to whom Indexa B.V. relies on to comply with requirements included in the Dutch Wet ter voorkoming van witwassen en financieren van terrorisme and the Santiewet 1977, namely the application of due diligence measures, identification of politically exposed persons and customer data retention, but also customer support;
  • “Company” means Indexa B.V. (Chamber of Commerce no. 50755854, previously B.V.), De Hooge Krocht 2, 2201 TX Noordwijk, the Netherlands, who provides CFD Trading service on a cross-border basis and is authorised and regulated by the Dutch Authority for the Financial Markets (AFM);
  • Complaint” means a statement or an expression of dissatisfaction addressed to the Company by a Complainant regarding the provision of investment and/or ancillary services provided by the Company to the Complainant;
  • Complaint Form” means electronic document available on the Website that must be filled out by you to lodge a Complaint;
  • Complainant” or “you” means the named natural person account holder, who has read, agreed with and accepted all the Terms and Conditions, being the authorised user of CFD Trading and owner of the Margin Account and Open CFD Positions, and has lodged a Complaint.

If you have any questions you can contact the Company by:

All of the terms and definitions not stipulated in this document are stipulated in the various chapters of the Terms and Conditions available on the Website.

1. Scope and purpose of the procedure

1.1. Under the law the Company is required to establish, implement and maintain effective and transparent procedures for the reasonable and prompt handling of Complaints or grievances received from Complainants and keep records of each Complaint as well as any actions taken by the Company to remedy the situation in accordance with the provisions of the competent authorities. 

1.2. This procedure sets out the method for the submission of Complaints with the Company from its clients and the processes followed by the Company when dealing with such Complaints.

1.3. The Company considers having a Complaint when the Complainant has filled out the relevant Complaint Form, available on the Website, and submitted it to the Company via the following methods:

1.3.1. by email at or; or

1.3.2. by post De Hooge Krocht 2, 2201 TX Noordwijk, the Netherlands.

1.4. In case the Company receives a notification through the line of communication established by the Company, but which does not fall within the definition of clause 1.3 and can be characterised not as Complaint, this shall be categorised as an enquiry and will be forwarded to the relevant contact within Company to be handled accordingly. The Complainant maintains the right to request for the reclassification of the enquiry as a Complaint.

2. Addressee of the Complaint

2.1. The customer support and if necessary, member of the compliance staff, shall efficiently handle any Complaint received by a Complainant. In the case that the Complaint is against the compliance staff, the Complaint shall be handled by a director of the Company. 

3. Procedure to be followed for verbal Complaint

3.1. It is the Company’s policy not to accept any verbal complaints or grievances. Should any of the Company’s employees (regardless of department) receive a verbal Complaint or grievance, the procedure stipulated in the following clauses 3.2-3.3 must be followed.

3.2. The member of the staff receiving the verbal complaint or grievance shall take all the necessary actions so that the Complaint or grievance is properly addressed. The person will inform the Complainant that all the Complaints or grievances must be made in writing by completing the relevant Complaint Form as stipulated in clause 1.3. Once the Complainant completes and submits the Complaint Form the procedure for written Complaints shall be followed as described in section 4.

3.3. The member of the staff, in addition to the above, should make all best efforts to ensure that in the case of the Complaint or grievance being of such nature that can be resolved immediately, to do so that the Complainant will not have to fill out the Complaint Form. The member of staff in such a case shall not do the following:

3.3.1. commit on behalf of the Company in taking any action prior to examining the issues in a formal manner;

3.3.2. commit in any way to the Complainant;

3.3.3. address any issues in relation to best execution; nor

3.3.4. address any issues relating to legal, compliance or regulatory issues.

4. Procedure to be followed for written Complaint

4.1. If the complaint was received in the manner not fulfilling the conditions stipulated in section 1, i.e. the complaint was received through internal channels of communication such as chat, client correspondence, on other Company’s email addresses, or by any other Company’s member of the staff, then the complaint, in the form that has been received, must be forwarded, in the form it has been received to within the same working day.

4.2. Once the Complainant submits a written complaint, customer support will send an electronic acknowledgment of receipt to the Complainant’s registered email address within five (5) working days following receipt, to verify that the Company has received the written Complaint and will request the Complainant to complete the relevant Complaint Form.

4.3. Upon completion and submission of the Complaint Form, customer support will investigate the grounds of the Complaint and if, based on the information provided, the grievance does not fall within the definition of Complaint or is not considered to be a Complaint it will be categorised as an enquiry and will be forwarded to the relevant member of the staff to be handled appropriately.

4.4. If the grievance falls within the definition of Complaint or is considered to be a Complaint, then the member of the staff will register the Complaint to an internal registry by giving it a unique reference number and by categorising it accordingly (e.g. technical, operational, compliance, legal) for the purpose of handling the Complaint most effectively.

4.5. In addition, within five (5) working days customer support shall inform the Complainant of the following:

4.5.1. that the Complainant must use the given reference number in all future correspondence with the Company regarding the submitted Complaint;

4.5.2. the process which is followed when handling a Complaint;

4.5.3. who is the member of the staff that is dealing with the Complaint and their contact details;

4.5.4. what is the indicative handling time (as a standard 20 working days); and

4.5.5. that the Complaint handling procedure is free of charge.

4.6. Moreover, the customer support must make sure that the following information is obtained from the Complainant, to the extent possible on the Complaint Form, and recorded:

4.6.1. full name and surname;

4.6.2. email address;

4.6.3. affected transactions (if applicable);

4.6.4. the date that the issue arose and a description of the issue;

4.6.5. the Service provided by the Company related to the Complaint;

4.6.6. member of the staff responsible for the provision of this Service (if applicable);

4.6.7. Complainant’s own description of the facts related to the Complaint, i.e. the content; and

4.6.8. reference of any correspondence exchanged between the Company and the Complainant (if applicable).

4.7. The Company will thoroughly examine and assess the facts and the information provided by the Complainant and the relevant members of the staff. Compare these facts with the information and data which have been retrieved from the Company’s archive (i.e. the Complainant’s transactions, trading history, correspondence, other electronic records). This investigation will also include the events preceding or leading to the Complaint.

4.8. The Company will not handle or investigate a Complaint if the Complainant does not complete the Complaint Form or does not provide the information requested in clause 4.6. of this procedure. In such an event the Company shall revert back to the Complainant and request to send any additional information. In any event, a member of senior management may contact the Complainant directly in order to obtain further clarifications and information relating to the Complaint. The Company shall need the Complainant’s cooperation in order to handle the Complaint. 

4.9. The Company upon examining the complaint and reaching a decision to this respect shall inform the Complainant about the Company’s decision, in writing and in plain language which is clearly understood, together with the reasoning of the Company’s decision and any remedial measures it intends to take.

4.10. The Company shall make every effort to resolve the complaint within fifteen (15) working days. When deemed necessary, customer support or a member of the compliance staff shall convey the complaint to the senior management for further investigation. In this case, the Company might take additional five (5) working days to finalise the reply. The senior management shall investigate further and coordinate with relevant members of the staff to attend to the subject of the Complaint.

4.11. In the event that the Company cannot provide a response to the Complainant within the handling time given to the complainant, it will keep the Complainant informed about reasons of delay and indicate when the investigation is expected to be completed. This period of time cannot exceed two (2) months from the submission of the Complaint.

4.12. Once the Complaint is concluded and Company has reached final decision customer support will be responsible of keeping an full electronic record of the Complaint received, detailing the course of action which was taken, including what information, data and evidence were gathered, what measures were taken for the resolution, whether any conflicts of interest between the Company and its clients and between other clients were identified, what was the outcome and how that outcome was reached.

4.13. The Company shall maintain record of all complaints for a minimum period of five years after the closure of the Customer’s Margin Account.

5. Alternative ways to resolve a Complaint

5.1. If the Complainant is not fully satisfied with the Company’s final decision the case can be referred to the Dutch Financial Services Complaints Tribunal (Kifid) using Company’s relevant registration number 400.000422. The Kifid consists of the Financial Services Ombudsman and the Financial Services Disputes Committee.

5.2. Ultimately the Complainant may turn to the Dutch Authority for the Financial Markets (AFM) or to relevant courts.

6. Follow-up measures

6.1. Customer support will analyse, on an on-going basis, Complaints handling data, in order to identify and address the causes of the individual Complaints and/or any recurring or systematic problems and/or any potential legal and operational risks. Subsequently the relevant member of the staff or senior management should be informed and if necessary, take corrective action.

6.2. This Complaints Handling Procedure will be made available on the Website.

6.3. The Complaints Handling Procedure is available to all the members of the staff through email and an internal folder in the Company’s channels of communication which can be accessed at any time without any restrictions.