I. INTRODUCTION

The Financial Advisory and Intermediary Services Act (FAIS) and the General Code of Conduct require that all authorised financial services providers (FSP’s) implement an internal complaint resolution system and framework. These procedures provide for the handling of client complaints in a timely and fair manner. The FSP undertakes to maintain and operate an adequate and effective complaints management framework to ensure the effective resolution of all complaints and the fair treatment of complainants that:

• Is proportionate to the nature, scale and complexity of the business and risks of the FSP;
• Is appropriate for the business model, policies, services, and clients of the FSP;
• Enables complaints to be considered after taking reasonable steps to gather and investigate all relevant and appropriate information and circumstances, with due regard to the fair treatment of complainants; and
• Does not impose unreasonable barriers to complainants;

The FSP understands and values the importance of its relationship with clients and places a strong emphasis on the maintenance of such relationships.

The FSP will always strive to ensure that complaints are avoided and where possible, that complaints are used as a method to improve the business and service to its clients. Should the complaint turn out to be not of a serious nature, it will still be investigated and the merits of the complaint will be considered and addressed to ensure more effective service to clients and to assist the client in redirecting the complaint, if possible.

“The FSP commits itself to resolving complaints from clients in a timeous, efficient and fair manner”

II. PURPOSE OF THE POLICY

In terms of the General Code of Conduct, an FSP must maintain an internal complaints resolution procedure in the event that a client complains about a financial service rendered by the FSP or a Representative of the FSP. The complaints policy is written in plain language and is aimed at providing a clear and easily understood procedure which takes into account the reasonably assumed level of knowledge of persons to whom the communication is targeted. This document aims to ensure that complainants are not confronted with unreasonable barriers in the complaints process.

The complaints procedure is based on the following TCF (Treating Customers Fairly) outcomes:

• TRANSPARENCY AND VISIBILITY - Ensuring that complainants have full knowledge of the procedures that will be followed when submitting a complaint
• ACCESSIBILITY OF FACILITIES - Ensuring that clients are provided with an easily accessible facility in order to submit a complaint
• FAIRNESS - Ensuring that the complaint resolution process is fair to both a complainant and the FSP. In order to achieve these outcomes, the FSP has adopted a complaints policy outlining our commitment towards the fair resolution of complaints.

III. DEFINITIONS AS PER GENERAL CODE OF CONDUCT

“Complaint” means an expression of dissatisfaction by a person to a provider or, to the knowledge of the provider, to the provider's service supplier relating to a financial product or financial service provided or offered by that provider which indicates or alleges, regardless of whether such an expression of dissatisfaction is submitted together with or in relation to a client query, that:

• (a) The provider or its service supplier has contravened or failed to comply with an agreement, a law, a rule, or a code of conduct which is binding on the provider or to which it subscribes;
• (b) The provider or its service supplier's maladministration or wilful or negligent action or failure to act, has caused the person harm, prejudice, distress or substantial inconvenience; or
• (c) The provider or its service suppliers has treated the person unfairly;

“Complainant” means a person who submits a complaint and includes a:

• (a) Client;
• (b) Person nominated as the person in respect of whom a product supplier should meet financial product benefits or that person's successor in title;
• (c) Person whose life is insured under a financial product that is an insurance policy;
• (d) Person that pays a premium or an investment amount in respect of a financial product;
• (e) Member;
• (f) Person whose dissatisfaction relates to the approach, solicitation marketing or advertising material or an advertisement in respect of a financial product, financial service or related service of the provider, who has a direct interest in the agreement, financial product or financial service to which the complaint relates, or a person acting on behalf of a person referred to in (a) to (f);

“Client” means a specific person or group of persons, excluding the general public, who is or may become the subject to whom a financial service is rendered intentionally, or is the successor in title of such person or the beneficiary of such service.

IV. THE FSP’S COMMITMENT TOWARDS THE FAIR RESOLUTION OF COMPLAINTS

The FSP is committed towards rendering financial services with proper due skill and diligence and in the best interests of clients and the integrity of the financial services industry. Despite our high service standards, there may be instances where a client nevertheless prefers to submit a formal complaint against the FSP. In such instances the FSP will follow the complaints procedure as outlined herein.

The FSP is committed to transparent and accessible complaints resolution processes that is fair to all parties involved. In order to achieve these outcomes, the FSP commits to the following:

• We will openly disclose and make readily available in writing the appropriate procedures in order to submit a complaint.
• We will resolve client complaints by means of a practical resolution process that is managed effectively.
• We will train and empower all relevant staff members to facilitate and resolve complaints.
• We will deal with complaints in a timely, transparent, objective and fair manner, with each complaint receiving proper due consideration.
• We will take the necessary steps to investigate and respond promptly to a complainant.
• Where deemed necessary, we will appoint an independent mediator in order to resolve the complaint.
• Where the complaint is resolved in favour of the complainant, we will offer the appropriate level of redress to the complainant without delay.
• Where the complaint is not resolved in favour of the complainant, we will provide written reasons for our decision and inform the complainant of any rights afforded to the complainant to escalate the complaint to another forum.
• We will maintain a record of all complaints for a period of five years together with an indication of whether or not the complaint has been resolved.
• We will investigate and, where necessary, take appropriate action in order to avoid and prevent similar circumstances that gave rise to the complaint.
• We will keep accurate, efficient and secure recording of complaints and complaints-related information, which will include all relevant information of the complainant and the subject matter of the complaint, copies of all relevant evidence, correspondence, decisions and complaint categorisation.
• We will keep record of all progress made and the status of the complaint, including whether such progress is within or outside any set timelines.
• We will scrutinize and analyse on an ongoing basis all complaints received and we will use all complaints received to manage conduct risks and effectively improve outcomes and processes for our clients.
• We will use our best efforts to prevent recurrences of poor outcomes and errors.

V. INTERNAL COMPLAINTS RESOLUTION PROCEDURE & FLOWCHART

Where a complaint has been received, or where a client has indicated his, her or its intention to submit a formal complaint to the FSP, the following procedure will be followed:

• We will review the Complaint form submitted to the FSP and as provided for in Annexure A herein. All written complaints to be directed to the appointed Key Individual, which contact details are provided on the Complaints form.
• We will furnish the complainant with a copy of the Complaints resolution procedure of the FSP.
• A copy of this procedure is also available on our client facing website.
• Where the complainant has previously communicated the grievance verbally, we will instruct the complainant to resubmit the complaint in writing to the FSP.
• As soon as the complaint is received in writing, we will proceed to record the complaint in FSP’s Client Complaints Register within 1 working day of receipt.
• The FSP will acknowledge receipt of the complaint in writing within 1 business day.
• Once the complaint has been acknowledged, it will be reviewed to determine if further investigation or corrective action is required.
• If the complaint is found to be valid, the FSP will take appropriate steps to resolve it. If the complaint is not found to be valid, the FSP will provide the complainant with written reasons for the decision.
• If necessary, the FSP will offer the complainant an opportunity to escalate the complaint to an independent mediator or ombudsman.
• All decisions and actions taken will be documented and maintained in the Client Complaints Register for a minimum period of five years.

VI. ESCALATION PROCEDURE

If the complainant is not satisfied with the outcome of the FSP’s internal complaint resolution process, the complainant may escalate the complaint to one of the following external bodies:

• The Ombudsman for Financial Services Providers (Ombud) – For complaints that involve financial services and products.
• The Financial Services Board (FSB) – For regulatory matters involving financial services providers.

The FSP will inform the complainant of the escalation procedure and provide the necessary contact details for the relevant external body.

VII. RECORD KEEPING

The FSP will maintain a comprehensive record of all complaints, including the following details:

• The complainant’s name and contact details;
• The date the complaint was received;
• The nature of the complaint;
• The actions taken to investigate and resolve the complaint;
• The final outcome and reasons for the decision;
• Any escalation actions taken by the complainant;
• Any follow-up actions or corrective measures implemented.

These records will be kept for a minimum of five years, after which they will be securely archived or destroyed, as appropriate.

VIII. POLICY REVIEW

This policy will be reviewed annually to ensure it remains aligned with regulatory requirements, industry best practices, and the FSP’s operational needs. Any necessary updates or changes will be made to maintain an effective complaints resolution process.