Complaints Handling and Internal Dispute Resolution Policy

Purpose. This policy sets out how the firm receives, records, investigates and resolves complaints from clients and others so that every complaint is handled fairly, promptly and in line with the regulator's standards for internal dispute resolution.

1.What is a complaint

A complaint is any expression of dissatisfaction made to the firm about its services, staff, representatives or the handling of a complaint, where a response is expected or would reasonably be expected. Complaints will be accepted in person, by phone, in writing, through the client portal and through social media. Staff must not screen out a complaint because it seems minor or the client has not used the word complaint.

2.Recording and acknowledgement

Every complaint must be recorded in the Complaints, Breaches and Compliance Register on the day it is received and acknowledged within one business day. The acknowledgement must tell the complainant who is handling the matter, how long it will take and how to contact the Australian Financial Complaints Authority if they are not satisfied.

3.Investigation and response

The complaint will be investigated by a person not involved in the matter wherever possible. The investigation must look at the file, the relevant policy and procedure and the complainant's account. A written response must be given within 30 calendar days, or within 21 days for a complaint about a credit matter involving financial hardship or a default notice. The response must explain the decision, the reasons and any remedy.

• Acknowledge within 1 business day
• Respond within 30 calendar days
• Credit hardship or default notice complaints within 21 days
• Explain reasons and remedies in plain language
• Refer to the external dispute resolution scheme in every final response

4.Remedies

Where the firm has made an error the response must say so, apologise, correct the error and, where the client has suffered loss, offer a remedy that puts the client back in the position they would have been in. Remedies over 5,000 dollars must be approved by the Managing Director.

5.Systemic issues and breaches

The Compliance Manager will review complaints monthly to identify systemic issues and will assess whether a complaint reveals a breach that must be reported to the regulator. Root causes must be recorded and actions assigned in the register.

6.Vulnerable clients

Staff must recognise when a complainant is experiencing vulnerability, including financial hardship, illness, family violence or language barriers, and must adjust the process, offer support and prioritise the matter.