HSS Luxembourg AIFM – Complaints Handling Policy

Updated Date: April 18, 2025

Harrison Street Services S.à.r.l maintains a Policy for the full and complete acknowledgement and handling of complaints, in line with regulatory standards, notably Regulation 16-07 issued by the Luxembourg Financial Regulator the Commission de Surveillance du Secteur Financier (‘The CSSF’).

Please refer to the link for further details: CSSF.

We have outlined below, in summary form, how to register a complaint with us and how, subsequent to receipt, all complaints will be logged, acknowledged, investigated and treated.

How to Address a Complaint to Us:

Complaints can be made in writing or by email as follows:

By email to: complaintsluxembourg@harrisonst.com

In writing / by Post to:

Harrison Street Services S.à.r.l

Attention Complaint Handling

53 Boulevard Royal

L-2449

Luxembourg

Complaint Handling: A Summary of the Process:

Any complaint received will be acknowledgement in writing to the complainant within ten business days from the date on which the original complaint was received, (as per Article 15.4.ii of the CSSF Regulation 16-07) unless a complaint has been otherwise resolved within this timeframe.

The acknowledgement letter or email will address the following points:

  • Confirmation that we have received the complaint and that we are investigating it.
  • The name and contact details of the person in charge of the file throughout the internal complaint resolution process for the complaint.
  • A summary of the details of the complaint being investigated.
  • We will request that if the summary is incorrect in any way, that the complainant should revert back to us to clarify or correct any missing or incomplete details or any other relevant information that they may have.
  • An explanation of the complaint management process and that we aim to resolve any complaints received within a timeframe of 4 weeks from the date on which the complaint was fist received by us.
  • If a complaint has been received verbally, the acknowledgement letter/email will also set out our understanding of the issue, inviting a response from the complainant to confirm the accuracy.

We will log all complaints in our internal complaints register, recording the full details of the complaint and who, within our firm, is handling it, up to and including investigation, the dates and details of each response, the expected timeframes to resolve any complaint including any changes in expected timelines, up to the eventual resolution. If we are unable to resolve a complaint within the expected 4 week timeframe, we will keep the complainant informed in writing or by email outlining the reasons for the delay and we will provide further updated estimates of the time that we believe will be required to fully investigate and respond.

Once a complaint has been fully investigated, we will issue a final letter outlining the original complaint received, how we have investigated the matter, how we have assessed and dealt with the matter and any details or remedial actions to be followed up and with an estimate of when we aim this to be completed by.

Where compensation is due, we will aim to ensure that this is done within a timely manner.

Complaint details will be stored, in line with applicable regulatory and data processing requirements, currently for a period of 5 years for the date on which a complaint has been resolved.

Further Referral to the Financial Regulator

Where a complainant has not received an acknowledgement from us within the required timeframe or remains dissatisfied with the outcome of our review and proposed resolution or assessment, the complainant retains the right to revert to the Luxembourg Financial Regulator, the Commission de Surveillance du Secteur Financier (‘The CSSF’),directly. Please refer to the link below for further details: Customer Complaints

All complaints received will be treated impartially and in strictest confidence at all times.

Other Policies

Harrison Street Services S.à.r.l maintains a Conflicts of Interest Policy, a Remuneration Policy and a Best Execution Policy in line with regulatory requirements and market best practice.