Have any Questions?0700-AVAGROUP

Client Complaint Management Policy





Competent Authority

Any institution that regulates AVA Group or any of its subsidiaries. This includes the NGX, SEC, FMAN, ASHON, ACT, AIHN etc.

AVA Group

This refers to AVA Group and its subsidiaries,which include but are not limited to AVA Securities Limited, AVA Trustees Limited, AVA Capital Partners Limited, and AVA Global

Asset Managers Limited.


Nigerian Exchange Group.


Securities and Exchange Commission



AVA Group is committed to providing excellent customer service to its clients in accordance with global best practices. Our aim is to continuously improve our services by encouraging honest feedback from clients who are satisfied or dissatisfied with our service delivery.

We recognize that complaints from clients are inevitable and they reflect badly on us if not properly handled; hence, we have designed this group client complaint management policy to show our commitment to ensuring that complaints received from our clients are dealt with in a responsive, efficient and effective manner.


The policy primarily aims at providing an avenue for effective client communication and feedback, and offering a fair and accessible platform for managing and promptly resolving our clients’ complaints and monitoring feedback in order to improve our performance and service delivery.


For the purpose of this policy, a complaint is defined as the expression of dissatisfaction by a client in relation to the provision of our services, quality of our product, our processes or the misconduct of a member of staff. It also involves a situation where a client alleges that he/she has suffered or is likely to suffer financial prejudice, material distress or inconvenience as a result of AVA Group –

  1. contravening or failing to comply with an instruction/mandate given by the client, or the provisions of an agreement entered into with the client;
  2. contravening or failing to comply with applicable laws, directives, rules and regulations governing its operations;
  3. acting dishonestly, negligently or recklessly; or
  4. treating the client unreasonably and


  1. The following principles govern our complaints management process:
  2. All complaints received will be treated with the highest level of
  3. All identifiable information will be protected from disclosure unless the complainant expressly consents to the disclosure of such
  4. All clients are encouraged to voice their concerns at the point of service or as soon as they feel
  5. Receipt of each complaint will be acknowledged Complaints will be handled in an efficient and effective manner. Complainants will be treated courteously and kept informed of the progress of their complaint throughout the complaint handling process.
  6. All complaints will be attended to promptly and treated in a timely manner;
  7. All clients will have access to our complaints management policy, which will be made available on our website or given to clients during the account opening stage;
  8. All complaints will be handled objectively;
  9. We will collect all available information and ensure there is a balanced consideration of all information and evidence before proceeding to resolve a complaint;
  10. All parties involved in a complaint handling process will be treated equally and fairly;
  11. AVA Group will pay due attention to individual differences and needs to ensure each case is considered on its merits;

Clients’ complaints can be categorized into the following:

  1. Negligible/Minor: These complaints pose zero to minimal financial or legal risk to the client or the company and can be promptly resolved at the point of receipt by any member of
  2. Moderate: These complaints also pose minimal financial or legal risk to the client or the company and may require minor assessment of or investigation into the facts of the complaint before it can be
  3. Major: These are complaints that have high potential financial or legal implications and require further Investigation (includes a breach of applicable laws, rules or regulation, negligence, breach of an obligation, conflict of interest, fraud, unauthorized transactions on a client’s account ).

A complaint may be orally communicated by a client over the phone or during a visit to our office or in writing via e-mail or hand written text.


When lodging a complaint, the Complainant is advised to use the Client Complaint Management form. However, if the Complainant is unable to access the form, the following details must be provided by the Complainant:


Full address Date

Mobile number/email address/home address Details of complaint Supporting Document (if any) 

Complaints can be lodged through any of the following channels:

Verbally: Complaints can be made verbally through any employee of AVA Group or any individual acting on behalf of AVA Group or at any of our offices. However, oral complaints bordering on issues which fall between the moderate and major categories must be reduced to writing by the Complainant or the member of staff who receives the complaint. The Complainant should be asked to fill the complaint form or provide the details listed above

Emails: Complaints can be reported via email though the dedicated email address; info@avacapitalgroup.com , our contact form on all our websites or through the email of any member of staff or individual acting on behalf of AVA Group, with info@avacapitalgroup.com in copy at all times.

Letters: Complaints can be lodged via letters addressed to us.

  1. Our employees are expected to educate themselves on the content of this policy and its procedures; and inform clients about the existence of this policy, and provide clients with copies of the policy at the point of creating an account for them or whenever they request for
  2. All complaints are expected to be dealt with in a timely manner in line with the timelines contained in this policy;
  3. All complaints must be consistently tracked;
  4. Progress reports must be sent out to clients regularly;
  5. Complaints are to be immediately assessed once they are logged and if possible categorized;
  6. Privacy and confidentiality should always be observed;
  7. Anonymous complaints should be treated on their merits like any other

The firm’s complaint handling procedure is outlined below;

  1. Acknowledgement

We will acknowledge all complaints in writing within two (2) working days for complaints received by email and five (5) working days for complaints received by post.

  1. Entry in the complaints register

Upon receipt of a complaint, we will record the following details in our complaints register:

  • Name of the client and/or complainant
  • Contact details
  • Date received
  • Nature and description of the complaint
  • Contact person at the firm
  1. Investigation and Resolution

Upon receipt of the complaint, we will ensure that the complaint is investigated promptly by the compliance officer and any member of the firm who is not involved in the subject of the complaint. The Compliance Officer shall ensure that the complaint is resolved within ten (10) business days of receipt of the complaint by the Complaint.

Complaints that are not resolved within ten (10) working days will be referred to a competent authority (e.g., NGX, SEC, FMAN) depending on the applicable authority, within two (2) working days after the end of the ten (10) working days resolution period. A summary of the complaint,  resolution  attempts  and  supporting  documents  would  be  included.  The Complainant will also be advised of his/her right to refer a complaint to the competent authority if dissatisfied with our resolution.

  1. Communication
    • The firm will provide a copy of the complaints handling procedure to new clients during the onboarding process;
    • The complaints handling procedures will also be displayed on AVA Group’
    • AVA Group shall provide information on complaints received on a quarterly basis to its
  1. Monitoring

The Compliance function will at intervals review all complaints recorded in the Company’s complaint register to confirm that there are no unresolved complaints and/or that the complaints handling procedure had been adhered to.


Upon receipt of a compliant, Complaint Review Officers (CRO) will be appointed by the Compliance unit to handle the complaints management process from the receipt of a complaint to its resolution. When appointing CROs, the Chief Compliance Officer will ensure that the employee appointed as a CRO:

  1. is independent in his/her decision making;
  2. has the necessary expertise in the area under which a complaint falls;
  3. has easy access to relevant material, personnel and full cooperation within the company

Our complaints process provides two avenues for the prompt resolution of complaints internally; which are the Frontline Complaint point and the internal complaint point. The Chief Compliance Officer is responsible for appointing officers to handle clients’ complaints at the frontline (if necessary) and internal complaints points.

  1. Frontline Complaints Point

Negligible or Minor complaints will be handled at this stage.

Frontline resolution is for the prompt resolution of basic and uncomplicated client complaints that require little or no investigation. Any employee may deal with complaints at this stage.

The main purpose of Frontline resolution is to resolve complaints within the earliest possible time and as close to the point of service delivery as possible. This may mean a face-to-face discussion with the customer by the member of staff receiving the complaint, or asking an appropriate member of staff to deal directly with the complaint.

In either case, the complaint is resolved by providing an on-the-spot apology where appropriate, or explaining why the issue occurred and, where possible, what will be done to prevent a reoccurrence.

Upon resolution of the complaint, the decision taken must be officially communicated to the compliance unit so it can be logged into the Client Complaint Register. The report sent to compliance must include details of the complaint and the Complainant.

A frontline complaint may be escalated to the internal complaints point where;

  1. the client remains dissatisfied and requests for further investigation into the complaint.
  2. the issues raised, after discussions with the client, may require detailed
  3. the complaint relates to serious or high-risk issues which were not previously envisaged.
  4. Internal Complaints Point

Complaint review officers appointed at this stage are in charge of addressing complaints unresolved at the frontline, and all other complaints that do not fall under the Negligible or Minor category.

Thorough investigations will be carried out at this stage both internally and externally (if necessary), and any employee whose name comes up during investigation will be called upon to give more information.

Depending on the sensitivity of the complaint, the CRO may suggest that a panel or committee be set up to look into the complaint to avoid any bias.

Upon resolution of the complaint, the decision taken must be communicated to the compliance unit in the form of a comprehensive report, so it can be logged into the Client Complaint Register.

  1. Where a complaint is not resolved within ten (10) working days or the complainant is unsatisfied with the outcome, AVA Group or the complainant shall refer the complaint to a competent authority within two (2) working days after the expiration of ten (10) working days from the date the complaint was
  2. The referral shall be accompanied by a summary of the sequence of events leading to the referral and copies of any relevant document that might aid the competent authority in addressing the
  3. Complaints referred to the competent authority will be resolved within twenty (20) working days, however, where a complainant is not satisfied with the competent authority’s decision; the complainant shall have a right to refer the matter to the SEC within two (2) working
  4. Complaints referred to SEC shall be resolved within twenty (20) working days or for an extended time as the commission deems
  5. Complainants still not satisfied with the decision or outcome of the commission reserve the right to proceed to the Investment and Securities Tribunal (IST).
    1. Complainants should be given regular progress
    2. Complainants should be advised of outcomes as soon as possible after a decision is
    3. Complainants should be given reasons for negative decisions if
    4. Complainants should be advised on any internal review options or any external statutory appeal referred to in this

An electronic complaints register will at all times be maintained in our office; and will include the following details:

  1. Name of the complainant
  2. Date of the complaint
  3. Nature and details of the complaint
  4. Category of the complaint
  5. Remarks/comments
  6. Follow-up actions

The complaints register shall be updated regularly, and status reports of complaints filed with us shall be forwarded to both the NGX and the SEC on a quarterly basis.


The effective implementation of this policy shall be the primary responsibility of all employees of AVA Group. The policy will be reviewed annually or as often as is required to be in compliance with regulatory, statutory and industry changes.


AVA Group will regard any violation of this policy as a serious breach of an employee’s

obligations towards the Company and its Clients.