Should a subscriber to our service feel that the methodology for a given proprietary price assessment has been applied incorrectly or inconsistently, a formal complaint may be submitted to Expana’s General Counsel.
Expana defines a formal complaint as a written expression of dissatisfaction with our proprietary price reporting service that has been submitted in line with this complaints policy.
Examples could include a complaint about whether a specific price assessment is representative of the market, how the methodology has been applied in relation to the price assessment process, or proposed changes to the methodology. Complaints regarding our subscription fees are not covered by this complaints policy and should be addressed as part of normal commercial negotiations.
All formal complaints should be clearly labelled as such and should be submitted in writing to [email protected] or to our registered company address. Communications should include as much relevant information as possible, in particular:
- Name(s) of the party or parties involved and their contact information;
- The nature of the complaint, together with details of the relevant reports, text or data;
- An explanation of how Expana market reporters have failed to adhere to the methodology;
- Details of failure in any other aspect of our service;
- Copies of any documents in support of the complaint;
- Previous correspondence with Expana market reporters that is relevant to the complaint.
Expana will acknowledge receipt of any complaint within two working days and will provide the contact details of the individual responsible for investigating the complaint.
The designated person will provide at least an initial written response within five working days of receipt. If more time is needed to prepare a detailed written response, this will be indicated in the initial response. A detailed response will be provided within 28 days of receipt of the original complaint, although this may not be enough time to conduct a full investigation.
We encourage complainants to provide as much information as possible in order to avoid delays while we request any further information needed to progress the complaint.
Complaints will be investigated fairly, promptly and confidentially. In all cases, investigations will be conducted independently of any personnel who may be the subject of the complaint.
All complaints will be treated in the strictest confidence, but in some circumstances we may need to verify details of transactions or trade negotiations with counterparties.
Expana policy is not to disclose sources of information without the agreement of those sources or disclose information passed to market reporters in confidence. This includes any such information that may be the subject of a formal complaint.
Once the investigation is complete and a decision has been taken on any appropriate follow-up action, the designated person will inform the complainant of the outcome of the investigation and the actions to be taken (if any).
Should the complainant choose to refer the decision to an independent third party for further review, Expana will engage with the process but will not consider any recommendations resulting from such a referral to be binding.
When a complaint about a proprietary price assessment is upheld, a correction will be issued in line with our corrections procedure.
Where a complaint indicates the need for a review of the methodology, the standard methodology consultation process will apply.
All correspondence relating to complaints, including with any independent third party, will be archived for a minimum period of five years.
