Complaints Policy

Scope and Purpose

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1.1 Purpose

This Complaints Policy sets out the procedure by which Imperial PI receives, investigates, and resolves complaints from clients and third parties in relation to the conduct, services, or actions of Imperial PI or any of its investigators. It forms part of Imperial PI's wider commitment to professional accountability and client care.

1.2 Who This Policy Applies To

This policy applies to:

• All current and former clients of Imperial PI (whether Consumer Clients or Business Clients as defined in Imperial PI's Terms and Conditions of Engagement);
• Any individual who believes they have been directly and materially affected by the conduct of Imperial PI in carrying out an investigation.

1.3 Relationship to Terms and Conditions

This policy supplements Section 11 (Complaints and Dispute Resolution) of Imperial PI's Terms and Conditions of Engagement. In the event of any conflict between this policy and those Terms, this policy shall prevail in respect of the complaints process.

How to Make a Complaint

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2.1 Preferred Methods

Complaints should be submitted in writing wherever possible. Written complaints create a clear record and allow us to investigate thoroughly. You may raise a complaint by:

2.2 Information to Include

To help us investigate your complaint efficiently, please include the following where possible:

• Your full name and contact details;
• Your case or client reference number (if known);
• A clear description of the nature of your complaint;
• The date(s) on which the events giving rise to the complaint occurred;
• Copies of any relevant correspondence or documentation;
• What outcome you are seeking.

You do not need to provide all of this information to make a complaint. If you are unsure what to include, please call us and we will guide you through the process.

2.3 Confidentiality

All complaints will be handled in strict confidence. Information relating to your complaint will only be disclosed to those within Imperial PI who need to know in order to investigate and resolve it, or where disclosure is required by law or a regulatory authority.

Acknowledgement and Response Timelines

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3.1 Acknowledgement

Imperial PI will acknowledge receipt of your complaint in writing within 5 business days of receiving it. The acknowledgement will confirm that your complaint has been received and is being investigated, and will provide you with the name or title of the person handling it.

3.2 Full Written Response

A full written response to your complaint will be provided within 28 calendar days of the date on which Imperial PI received the complaint. If it is not possible to provide a final response within 28 days (for example, because the complaint is complex or requires further information), we will write to you before that deadline to explain the reason for the delay and provide an estimated date for the final response.

How We Investigate Complaints

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4.1 Independence and Impartiality

Complaints will be investigated by a person who was not directly involved in the matter being complained about, so far as is reasonably practicable. Where the complaint concerns the conduct of a specific investigator, that investigator will not be involved in investigating or determining the complaint.

4.2 Investigation Process

The investigation will typically involve:

• A review of all relevant case records, correspondence, and evidence;
• Discussion with the investigator(s) involved, where appropriate;
• An assessment of whether Imperial PI's conduct met the required professional standards, including compliance with the Association of British Investigators (ABI) Code of Conduct, UK GDPR, and applicable law;
• Where appropriate, a request for additional information from the complainant.

4.3 ABI Code of Conduct

Imperial PI conducts all investigations in accordance with the Association of British Investigators (ABI) Code of Conduct for Investigative and Litigation Support Services, formally approved by the Information Commissioner's Office (ICO) in October 2024. Complaints will be assessed against this Code as part of the investigation process.

Possible Outcomes

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5.1 Outcome Letter

Our full written response will set out:

• A summary of the complaint as we understand it;
• The findings of our investigation;
• Our conclusion as to whether the complaint is upheld, partially upheld, or not upheld, and our reasons;
• Any action we propose to take or have taken;
• Your right to escalate the matter if you are not satisfied with the outcome.

5.2 Where a Complaint Is Upheld

Where a complaint is upheld, Imperial PI will take appropriate remedial action, which may include one or more of the following depending on the nature and severity of the complaint:

• An apology;
• A full or partial refund of fees paid;
• A reduction in any outstanding fees;
• Corrective action in relation to the conduct of our investigators or processes;
• Other appropriate remedy as agreed in writing.

5.3 Where a Complaint Is Not Upheld

Where a complaint is not upheld, we will explain clearly why we have reached that conclusion. You retain the right to escalate the matter as described in Part 6 below.

Escalation and Deadlock

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6.1 Escalation Within Imperial PI

If you are not satisfied with the initial response to your complaint, you may request that the matter be escalated to a senior member of Imperial PI's management. Please state clearly in writing that you wish to escalate the complaint and explain why you are dissatisfied with the initial response. The escalated review will be conducted by a different person from the original handler.

6.2 Deadlock

If Imperial PI and the complainant are unable to reach a mutually satisfactory resolution through the internal complaints process, Imperial PI will issue a written "deadlock letter" confirming that internal options have been exhausted. This letter will set out your external escalation rights as described in Part 7 below.

Alternative Dispute Resolution

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7.1 Mediation

In accordance with Section 11.2 of Imperial PI's Terms and Conditions of Engagement, if a complaint cannot be resolved between the parties through the internal complaints process, both parties agree to attempt resolution through a mutually agreed mediator before commencing formal legal proceedings.

7.2 Association of British Investigators (ABI)

Imperial PI is a member of the Association of British Investigators (ABI) and is bound by its Code of Conduct. Complaints regarding compliance with the ABI Code may also be referred to the ABI for consideration under their own disciplinary procedures.

7.3 Information Commissioner's Office (ICO)

If your complaint relates to the handling of your personal data under UK GDPR or the Data Protection Act 2018, you have the right to complain directly to the Information Commissioner's Office (ICO) at any time. Further information is available at ico.org.uk.

7.4 Consumer Rights

Governing Law

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8.1 Governing Law and Jurisdiction

This policy and all complaints arising under it are governed by the laws of England and Wales. Both parties submit to the exclusive jurisdiction of the courts of England and Wales for the resolution of any dispute that cannot be settled through the complaints or ADR process described above.

8.2 International Clients

Where a complainant is based outside England and Wales, this policy continues to apply. Clients in the following jurisdictions — Canada, Australia, New Zealand, South Africa, Malta, and Cyprus — may note that Imperial PI can liaise directly with local lawyers, insurers, or corporate legal departments as appropriate to the nature of the complaint.

Contact Details

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9.1 Complaints Contact

All formal complaints should be directed to: