Complaints Handling Policy

Effective Date: April 2026

Ladd & Co. ("the firm") takes all complaints seriously. This Policy explains how to raise a concern, how the firm will respond, and the steps available to a complainant who is not satisfied with the firm's response.

This Policy is intended for clients, prospective clients, professional intermediaries, counterparties, and any other person who has a concern regarding the conduct of the firm or its personnel.

1. Scope

This Policy applies to complaints regarding:

  • the firm's services, conduct, or personnel;
  • the firm's handling of personal information (privacy complaints);
  • accessibility of the firm's website or communications;
  • the conduct of any individual purporting to act for or on behalf of the firm;
  • any other matter relating to the firm's interaction with the complainant.

2. How to Make a Complaint

The firm encourages complainants to raise concerns directly and at the earliest opportunity, so that they can be addressed and resolved.

Step 1 — Contact the Firm

In the first instance, please contact the firm in writing:

When raising a complaint, please include:

  • your name and contact details;
  • the nature of the complaint and the conduct or matter complained of;
  • the name of any individual involved (if known);
  • any relevant dates, communications, or documents;
  • the outcome you are seeking.

The firm acknowledges that some complainants may prefer to raise concerns through their existing professional advisor, intermediary, or counsel. Complaints raised through such intermediaries are treated in the same manner as complaints raised directly.

Step 2 — Acknowledgment

The firm will acknowledge receipt of a complaint promptly, and in any event within five business days of receipt.

Step 3 — Investigation and Response

The firm will investigate the complaint and respond substantively as soon as reasonably practicable, having regard to the nature and complexity of the matter. The firm will endeavour to provide a substantive response within 30 calendar days of acknowledgement. Where the matter is complex or requires additional time, the firm will keep the complainant informed of progress and provide an estimated timeframe for response.

The investigation will be conducted by a person of appropriate seniority who is independent of the matter complained of, where reasonably practicable.

Step 4 — Outcome

The firm will provide a written response setting out:

  • the outcome of the investigation;
  • the steps (if any) the firm proposes to take in response;
  • the reasons for the firm's conclusions; and
  • the steps available to the complainant if they are not satisfied with the response.

3. Confidentiality

Complaints are handled with discretion. Information regarding a complaint is shared internally only with personnel who need to be aware of it for the purpose of investigating and responding to the complaint, or for the firm's risk, regulatory, or legal management.

4. No Retaliation

The firm prohibits any form of retaliation against a complainant who raises a concern in good faith. This applies whether the complainant is a client, a professional contact, a personnel member, or any other person.

5. Escalation Where the Complainant is Not Satisfied

If the complainant is not satisfied with the firm's response, they may pursue the matter through one or more of the avenues set out below, depending on the nature of the complaint and the complainant's jurisdiction.

5.1 Privacy Complaints

If the complaint relates to the firm's handling of personal information and the complainant is not satisfied with the firm's response, the complainant may refer the matter to the relevant supervisory authority, including:

  • Australia — Office of the Australian Information Commissioner (OAIC) at oaic.gov.au;
  • United Kingdom — Information Commissioner's Office (ICO) at ico.org.uk;
  • European Economic Area — the supervisory authority of the complainant's member state of residence;
  • Singapore — Personal Data Protection Commission (PDPC);
  • Hong Kong — Office of the Privacy Commissioner for Personal Data (PCPD);
  • United Arab Emirates — UAE Data Office, or the relevant free zone authority.

5.2 General Complaints

For complaints that are not capable of resolution between the complainant and the firm, the complainant may pursue any other remedy available to them under applicable law, including through the courts of competent jurisdiction.

The firm's services are not regulated financial services in the jurisdictions in which the firm operates, and the firm is not a member of any external dispute resolution scheme of the kind applicable to licensed financial service providers. The firm's regulatory status is set out in the Legal Entity Disclosure.

6. Records

The firm maintains records of complaints received, the actions taken in response, and the outcomes. These records are used for the firm's internal review and improvement of its services.

7. Continuous Improvement

The firm reviews complaints in aggregate to identify trends, root causes, and opportunities to improve its services, processes, and personnel training. Where appropriate, lessons identified through complaints are reflected in updates to the firm's policies and procedures.

8. Contact

Ladd & Co. General Complaints: office@laddco.com Privacy Complaints: privacy@laddco.com Website: laddco.com


© 2026 Ladd & Co. All rights reserved.

© 2026 Ladd & Co. All rights reserved.