iTrust121 Limited & iTrust121 Pro Limited

Client Complaints and Concerns Procedure

Effective date: 10 August 2026
Version: 2.0
Applies to: iTrust121 Limited and iTrust121 Pro Limited

1. Our commitment

iTrust121 Limited and iTrust121 Pro Limited are committed to providing professional, accurate and timely services.

We recognise that concerns can arise and that clients should have a clear and fair means of raising them. This procedure explains:

• what we treat as a complaint;
• how to raise a complaint;
• how complaints are investigated;
• how delay, cancellation and refund issues are assessed;
• the possible outcomes; and
• what further review may be available.

We will consider complaints impartially and on the available evidence. Raising a complaint will not result in a client being treated less favourably.

Nothing in this procedure limits any statutory or contractual rights available to a client.

2. Services covered by this procedure

This procedure applies to complaints about services provided by or on behalf of iTrust121 Limited or iTrust121 Pro Limited, including:

• will drafting and associated estate-planning services;
• trust advice, trust drafting and trust documentation;
• Lasting Power of Attorney preparation and related administration;
• professional trustee services;
• document storage and administration;
• client onboarding, identity verification and data collection;
• work undertaken by an authorised iTrust121 Licensed Adviser within the iTrust121 framework; and
• related client communication, administration and billing.

Where part of a matter has been undertaken by an independent solicitor, tax adviser or other professional, we will determine which aspects fall within this procedure and which should be referred to the separate provider.

3. What we mean by a complaint

A complaint is a clear expression of dissatisfaction about an act, omission, decision, service or standard of conduct for which the complainant expects a response or remedy.

A complaint may concern, for example:

• an alleged drafting error or omission;
• failure to follow instructions;
• the quality or accuracy of information provided;
• unreasonable delay attributable to iTrust121;
• inadequate communication;
• conduct by an employee or Licensed Adviser;
• fees or charges that the client says were not properly disclosed;
• failure to perform an agreed service;
• handling of personal information; or
• the administration or exercise of professional trustee responsibilities.

A complaint does not have to use the word “complaint” to be treated as one.

The fact that a complaint is recorded and investigated does not mean that it is accepted as justified.

4. Initial classification of the issue

When we receive correspondence expressing concern or dissatisfaction, we will determine whether it is:

• a service complaint;
• a request for clarification or further information;
• a change of instructions;
• a cancellation request;
• a request for a refund or fee review;
• a complaint about a separate third-party provider; or
• a combination of the above.

This initial classification is intended to ensure that the issue is handled under the correct process. It does not predetermine whether any complaint will be upheld.

Where a client raises both a complaint and a cancellation request, the two issues may be considered separately and at the same time.

5. Matters that do not, by themselves, establish service failure

The following matters do not automatically mean that iTrust121 has provided a defective service:

• a client changing their mind after giving instructions;
• a client deciding that they no longer wish to proceed;
• a client finding an alternative provider or a lower price;
• dissatisfaction with a legal, tax or practical consequence that was accurately explained;
• disagreement with advice merely because it was not the answer the client hoped to receive;
• dissatisfaction with a fee that was clearly disclosed and agreed;
• a delay caused by outstanding client instructions, identification documents or information;
• a delay caused by a third party outside iTrust121’s reasonable control;
• refusal by iTrust121 to undertake an unlawful, inappropriate, uninsurable or out-of-scope activity;
• a trustee decision with which a beneficiary disagrees, where the decision was made lawfully and in accordance with the trust deed; or
• a request for a refund where substantive work has already been completed.

A client may still raise a complaint about any of these matters. We will consider whether there is an identifiable service failure, rather than assuming that dissatisfaction alone establishes fault.

6. Cancellation, refunds and complaints

A complaint is not the same as a cancellation request.

A client who wishes to stop work must state this clearly. Unless cancellation is expressly requested, we may continue progressing the matter where it is reasonable to do so.

Cancellation and refund rights will be considered under:

• the client’s engagement terms;
• any applicable statutory cancellation rights;
• the stage reached in the work;
• work already undertaken;
• third-party costs already incurred or committed; and
• any service failure established through the complaint investigation.

Making a complaint does not automatically:

• cancel the engagement;
• create an entitlement to a full refund;
• extinguish fees for work already properly undertaken;
• waive third-party costs; or
• suspend outstanding payment obligations.

Where appropriate, we may agree to pause work or payment collection while a relevant dispute is investigated. Any such pause must be confirmed by us in writing.

A decision by a client not to proceed after work has begun is not, without further evidence, proof of negligence, breach of contract or poor service.

7. Complaints alleging delay

Where a complaint alleges delay, we will prepare and assess a chronology of the matter.

We will distinguish between:

• active time during which iTrust121 was responsible for progressing the work;
• time during which information or instructions were awaited from the client;
• time awaiting identification, KYC, anti-money laundering or source-of-funds information;
• time awaiting signed documents, corrections or client approval;
• time awaiting property information, title documents, valuations or other evidence;
• time awaiting a response from a solicitor, HM Land Registry, HMRC, the Office of the Public Guardian or another third party;
• periods during which the matter was placed on hold at the client’s request; and
• periods during which progress was prevented by a material change in instructions.

Delivery estimates normally depend on the client providing complete and accurate information promptly. Unless a fixed deadline has been expressly guaranteed in writing, an estimated timescale is not an unconditional guarantee.

Where progress has been delayed because required information has not been supplied, that period will not ordinarily be treated as delay attributable to iTrust121.

We will nevertheless consider whether reminders were reasonable, whether the position was communicated adequately and whether iTrust121 took appropriate steps once the required information was received.

8. Who may make a complaint

A complaint may be made by:

• a current or former client;
• a person authorised in writing to act for the client;
• an attorney, deputy, executor or personal representative with appropriate authority;
• a settlor, testator or donor;
• a trustee or beneficiary directly affected by the relevant service; or
• another person with a demonstrable and legitimate interest.

We may require evidence of identity, authority or legal standing before disclosing confidential information or investigating a complaint made by a third party.

Our acceptance of a complaint from a beneficiary or other third party does not necessarily mean that the person is entitled to receive all information held on the relevant file.

9. How to make a complaint

Complaints should preferably be made in writing so that the issues and requested outcome are clear.

They may be sent to:

The Compliance Director
iTrust121 Limited / iTrust121 Pro Limited

167-169 Great Portland Street
Fifth Floor
London
W1W 5PF

Email: complaints@itrust121.com

A client who is unable reasonably to make a written complaint may raise it by telephone or during a meeting. We will make a written record of the complaint and may send that record to the client for confirmation.

Reasonable adjustments will be considered where a client has a disability, vulnerability, communication difficulty or other accessibility requirement.

10. Information that should be provided

To help us investigate efficiently, the complaint should identify:

• the client’s full name and contact details;
• the relevant client or matter reference;
• the product or service concerned;
• the individual or Licensed Adviser involved, if known;
• what the client says happened;
• the relevant dates;
• the particular act, omission, delay or communication complained about;
• why the client believes the service was below the required standard;
• any actual financial loss said to have been suffered;
• the outcome being requested; and
• any relevant documents or correspondence.

A client does not have to complete a particular form, but insufficiently particularised complaints may take longer to investigate.

11. Acknowledgement

We will normally acknowledge a complaint in writing within five business days of receipt.

The acknowledgement will normally:

• confirm that the complaint has been recorded;
• provide a complaint reference;
• identify the person responsible for reviewing it;
• summarise the issues as we understand them;
• request any further information required; and
• explain the anticipated next steps.

The client should tell us promptly if our summary does not accurately reflect the complaint.

12. Investigation process

Where reasonably practicable, the complaint will be reviewed by a senior person who was not directly responsible for the matter complained about.

The investigation may include:

• reviewing the engagement letter and client terms;
• reviewing the agreed scope of work;
• examining fact-finds, instructions and client approvals;
• reviewing CRM records, file notes, emails, letters and call recordings;
• reviewing KYC, identity and information requests;
• preparing a chronology of the matter;
• reviewing documents drafted or supplied;
• obtaining comments from relevant employees, Licensed Advisers or third-party professionals;
• assessing the work against internal procedures and professional standards;
• identifying whether any delay was caused by iTrust121, the client or a third party;
• considering whether the alleged failing caused any actual loss; and
• determining whether immediate corrective or protective action is required.

We may notify our professional indemnity insurer, legal advisers or other relevant professional advisers where the complaint indicates a possible claim or circumstance requiring notification.

Doing so does not mean that liability is admitted.

13. Cooperation and requests for information

A fair investigation may require further information from the complainant.

Where we request material information, we will normally specify a reasonable response period. If the requested information is not provided:

• we may send a reminder;
• we may determine the complaint using the records and evidence already available; or
• where the complaint cannot reasonably be investigated, we may place it on hold or close it as inactive.

If a complaint is closed because the complainant has not cooperated, we will explain this in writing.

We may reopen the matter where relevant information is later supplied, provided that doing so remains reasonably practicable.

14. Timescale for a substantive response

We aim to provide a substantive written response within 28 calendar days of acknowledging the complaint.

Where this is not reasonably possible because of complexity, missing information, third-party involvement or another material reason, we will write to the complainant explaining:

• why more time is required;
• what remains under investigation; and
• when the response is expected.

We will not delay a response merely because the complaint appears weak or is likely not to be upheld.

15. Decision and possible outcomes

The written outcome will normally state whether the complaint is:

• upheld;
• partially upheld;
• not upheld;
• outside the scope of this procedure; or
• unable to be determined on the evidence available.

The response will summarise:

• the issues investigated;
• the relevant factual findings;
• the material evidence relied upon;
• the reasons for the decision; and
• any action proposed.

Where appropriate, action may include:

• an explanation or clarification;
• an apology;
• correction or replacement of documentation;
• completion or re-performance of part of the service;
• expedited handling;
• referral to a suitable independent professional;
• review of a fee;
• a partial or full refund where legally or contractually appropriate;
• a discretionary goodwill payment;
• staff training or process improvement; or
• no further action where no service failure is established.

A goodwill gesture does not necessarily amount to an admission of negligence or legal liability.

Nothing in this procedure requires iTrust121 to provide compensation or a refund where there is no legal, contractual or evidenced basis for doing so.

16. Licensed Adviser complaints

Where a complaint concerns an iTrust121 Licensed Adviser acting within the iTrust121 framework:

• the complaint should be submitted to iTrust121;
• iTrust121 will coordinate the investigation;
• the Licensed Adviser may be required to provide their records and comments;
• central client records, terms, invoices and fulfilment records will be reviewed; and
• the outcome will be communicated by or on behalf of iTrust121.

Where the adviser undertook separate work outside the iTrust121 engagement, the client may be directed to the adviser or their separate business in relation to that work.

17. Complaints concerning third-party professionals

Where a solicitor, tax adviser, financial adviser or other independent professional has been separately instructed, that provider remains responsible for their own work.

We may:

• investigate the aspects for which iTrust121 is responsible;
• assist in identifying the separate provider;
• provide relevant information where lawful and authorised; and
• direct the complainant to the provider’s own complaints procedure.

Where a complaint concerns reserved legal work undertaken by an SRA-regulated solicitor, the solicitor’s complaints process and any external redress route applicable to that solicitor will apply.

18. Internal review

A complainant who remains dissatisfied may request one further internal review.

The request should ordinarily be made within 14 calendar days of the substantive response and should identify one or more of the following:

• a material factual error;
• relevant evidence that was not considered;
• a significant procedural failing;
• a material misunderstanding of the complaint; or
• a proposed outcome said to be unreasonable.

The review will be undertaken by a director, Board member or other senior person not previously responsible for the decision, where reasonably practicable.

The review is not intended simply to repeat the original investigation. It will focus on the grounds raised and any new material evidence.

Following completion of the review, iTrust121 will issue its final internal response.

19. Repeated complaints and unreasonable conduct

We understand that complainants may be frustrated, upset or persistent. A complaint will not be treated as unreasonable merely because:

• it is expressed firmly;
• the complainant contacts us more than once;
• the complaint is not ultimately upheld; or
• the complainant disagrees with our decision.

However, we may take proportionate steps where conduct becomes unreasonable, including where a person:

• uses threatening, abusive, discriminatory or seriously offensive language;
• makes threats against employees, advisers or other persons;
• submits knowingly false, altered or fabricated evidence;
• repeatedly raises the same issue after a final response without new material evidence;
• contacts numerous employees about the same matter in an attempt to bypass the process;
• makes excessive or disproportionate demands that prevent reasonable investigation;
• refuses to identify the substance of the complaint while continuing repeated contact;
• records or publishes confidential material unlawfully; or
• seeks to use the complaints process to harass staff or interfere with unrelated work.

In those circumstances, we may:

• appoint a single point of contact;
• require future communication to be in writing;
• limit the frequency of responses;
• decline to answer repeated correspondence that raises no new issue;
• issue a final communication confirming that the matter is closed;
• suspend or terminate the engagement where permitted by the client terms; or
• report threats, harassment or suspected criminal conduct to the appropriate authority.

Where possible, the substantive complaint will still be considered and a reasoned outcome provided.

20. Confidentiality and personal information

Complaints will be handled with appropriate confidentiality.

Information may be shared where reasonably necessary with:

• relevant employees or Licensed Advisers;
• directors or Board members;
• professional indemnity insurers;
• legal or professional advisers;
• relevant outsourced service providers;
• regulatory, law-enforcement or public authorities where legally required; or
• a third-party professional whose work forms part of the complaint.

Personal information will be handled in accordance with the applicable privacy notice and data protection requirements.

21. External options

iTrust121 Limited and iTrust121 Pro Limited are not SRA-regulated law firms and do not provide FCA-regulated financial advice.

The availability of any external complaints or ombudsman route will depend on:

• the particular service;
• the entity or professional that provided it;
• any applicable trade-body or contractual arrangement; and
• the complainant’s jurisdiction.

Where an external ADR, mediation or other dispute-resolution arrangement is available or appropriate, our final response will provide relevant information and state whether iTrust121 is willing or required to participate.

A complainant may also obtain independent legal advice or consumer advice.

Complaints concerning personal data may be raised with the Information Commissioner’s Office after the concern has first been brought to our attention.

Nothing in this procedure prevents either party from exercising any right to bring legal proceedings.

22. No admission of liability

Acknowledging, investigating or responding to a complaint does not constitute:

• an admission of negligence;
• an admission of breach of contract;
• an acceptance that loss has been caused;
• a waiver of any legal or contractual right; or
• an agreement to provide compensation or a refund.

The purpose of the process is to establish the facts, determine whether the service met the appropriate standard and seek a fair resolution where reasonably possible.

23. Review and publication

This procedure will be reviewed annually or following any material change to:

• iTrust121’s services;
• consumer law;
• insurance requirements;
• the Licensed Adviser model; or
• complaints-handling arrangements.

Changes to the procedure will not be used to prejudice a complaint already under investigation.