US Complaints Policy

PART 1

Scope and Purpose

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, remote intelligence services, or actions of Imperial PI or any of its analysts and investigators. It forms part of Imperial PI's wider commitment to professional accountability and client care — extended to all US clients we serve remotely from the United Kingdom.

1.2 Who This Policy Applies To

This policy applies to:

• All current and former US-based clients of Imperial PI (whether Consumer Clients or Business/Corporate Clients as defined in Imperial PI's Terms and Conditions of Engagement);
• Any individual or entity that has engaged Imperial PI's remote intelligence, OSINT, or investigative research services for matters connected to the United States;
• Any individual who believes they have been directly and materially affected by the conduct of Imperial PI in carrying out a remote investigation on behalf of a US client.

1.3 Relationship to Terms and Conditions

This policy supplements the Complaints and Dispute Resolution provisions of Imperial PI's US 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.

1.4 Scope of US Services

Imperial PI's services for US clients are conducted entirely remotely from the United Kingdom. We do not conduct physical surveillance in the United States, do not operate as a US-licensed private investigator, and do not engage in any activities requiring a US state PI licence. Our work is intelligence-led, OSINT-based, and data-research-focused. This policy applies to all such remote intelligence and investigative research services.

PART 2

How to Make a Complaint

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 (email and/or phone);
• 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 email 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. We recognise the sensitivity of the matters US clients bring to us and treat all communications accordingly.

PART 3

Acknowledgement and Response Timelines

3.1 Acknowledgement

Imperial PI will acknowledge receipt of your complaint in writing within 2 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. Given that US clients are served remotely, all communications are conducted by email unless otherwise agreed.

PART 4

How We Investigate Complaints

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 analyst or investigator, that individual 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, intelligence reports, and evidence;
• Discussion with the analyst(s) or 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;
• A review of the agreed scope of work and whether deliverables were met;
• Where appropriate, a request for additional information from the complainant.

4.3 Professional Standards

Imperial PI voluntarily conducts all remote intelligence operations to the standard set out in the Association of British Investigators (ABI) Code of Conduct for Investigative and Litigation Support Services — an ICO-approved code of practice. Complaints will be assessed against the principles of this Code as part of the investigation process. We hold ourselves to these formal professional standards on every engagement, including those conducted remotely for US clients.

PART 5

Possible Outcomes

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:

• A formal written apology;
• A full or partial refund of fees paid (in USD where applicable);
• A reduction in any outstanding fees;
• Supplementary investigative work at no additional charge;
• Corrective action in relation to the conduct, methodology, or processes involved;
• 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.

PART 6

Escalation and Deadlock

6.1 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.

PART 7

Alternative Dispute Resolution

7.1 Mediation

In accordance with the Disputes provisions 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. Given Imperial PI's UK base and remote delivery to US clients, mediation may be conducted by video conference or written exchange.

7.2 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, which is formally approved by the Information Commissioner's Office (ICO). While Imperial PI is not a formal member of the ABI, we voluntarily operate to the standards set out in that Code on every engagement. Complaints may be assessed against the ABI Code as part of our internal investigation process.

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, regardless of your location. Further information is available at ico.org.uk. This right applies to US-based complainants whose personal data has been processed by Imperial PI as part of a remote engagement.

7.4 US Client Rights

PART 8

Governing Law and US Clients

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. This reflects the fact that Imperial PI is a UK-incorporated firm and all services are delivered from the United Kingdom.

8.2 US Clients — Remote Engagement

Imperial PI serves US clients remotely across all 50 states. All investigative research, OSINT, and intelligence reporting is conducted from the United Kingdom. Imperial PI does not maintain a physical presence in the United States, does not hold a US private investigator licence in any state, and does not conduct in-person operations within US territory. The governing law of England and Wales applies to the engagement and this complaints process in its entirety.

8.3 Cross-Border Client Support

Where a US-based complainant requires legal proceedings or enforcement in the United States, Imperial PI will provide reasonable cooperation including provision of evidence, sworn declarations (where applicable), and liaison with appointed US legal counsel. We maintain correspondence records to evidential standards and can provide full case documentation in support of any legitimate legal process.

PART 9

Contact Details

9.1 Complaints Contact

All formal complaints from US clients should be directed to: