Policy Statement

Our complaint handling
policy has been created to meet general standards and requirements. We take all
concerns and issues seriously and use our robust and structured complaint
processes to ensure a satisfactory resolution is reached.

The aim of this policy is to ensure that all customer complaints, either
written or verbal, are handled in a consistent and regulated manner and that
further complaint incidents are mitigated and where possible, prevented. Where
a customer has cause to complain, the complaints handling procedure will be
followed in every instance and a record will be made of the complaint nature
and details to help improve our services and reduce the occurrence of similar
complaints.

Purpose

The Company are committed to
delivering a fair, open and clear process for complaints and ensure a
satisfactory outcome for all customers who raise a complaint. We provide
thorough staff training in our internal complaint handling procedures and
support our staff in how to handle complaint situations in a face-to-face,
written and/or telephone environment.

This policy sets out our intent and objectives for how we handle
complaints, from offering a clear and approachable system for customers to
complain, through to conducting root cause analysis on all complaints received
to identify the cause, issues and corrective actions regarding the complaint,
and to implement measures to prevent reoccurrences where applicable.

Objectives

The Company's objectives are
set out below regarding customer complaint handling. For the purposes of this
policy, a complaint is defined as any customer contact whereby a negative
communication or outcome has occurred. The customer does not have to formally
address their communication as an official complaint or to request a response
for the Company to treat the incident as a complaint and to follow the related
procedures.

The
Company’s objectives for internal complaint handling are:

To
provide a fair complaints procedure which is clear and easy to use for
anyone wishing to make a complaint

To
ensure that our complaints procedure is fully accessible so that people
know how to contact us to make a complaint

To
make sure everyone in the Company knows what to do if a complaint is
received

To
make sure all complaints are investigated fairly and in a timely manner

To
gather information which helps us to improve what we do and how we do it

To
ensure that the Data Protection Officer (or appointed person) is involved
in any complaints relating to personal data

To comply with any obligations for
complaint handling rules as applicable to our industry

The
Company’s objectives for our customer complaint procedures are:

Complaints
will be investigated and responded to within 8 weeks from the initial
customer contact

Customers
will be sent a copy of our complaint procedures with the initial
acknowledgement

We
will enclose any relevant information or mandatory leaflets to the
customer with the initial acknowledgement in accordance with any industry
requirements or codes of conduct that apply to us (i.e. Financial
Ombudsman Service (FOS)

Complaint
responses will always be provided in writing (unless the complainant makes
a specific request for an alternate form of communication, which will be
provided in addition to the written format)

Complaint
procedures and forms will be available via the company website as well as
upon written and/or verbal request

All
complaints will be investigated by a trained member of staff and a full
outcome summary provided to the Senior Manager

Complaint
records will be used to gain valuable management information to revise
company procedures and to improve communication and business practices
where applicable

Complainants are advised of their rights
and provided with any relevant right to refer/lodge the complaint and the
applicable contact details (i.e. FOS, FCA, the ICO)

Procedures and Guidelines

RAISING A
COMPLAINT

Customers who request the
Company’s complaint handling procedure will be provided a copy of the procedure
and form either by email, in a PDF format or in the post, and will be asked to
raise their complaint in writing as soon as possible after the incident.

NOTE: Complaints are to be raised in writing, however verbal
complaints will be accepted and dealt with as per the same procedures.

If a customer telephones the
Company and wishes to raise a complaint, they should be passed through to a
senior member of staff or the Complaints Officer who will try to resolve the
complaint then and there.

Even if the complaint is
resolved at the time, the customer must still be offered the option of
receiving the complaints handling procedure and form prior to ending the call
and the call recording must be retained and logged in the complaints record.

DATA
PROTECTION RELATED COMPLAINTS

Where a complaint is related
to the processing of personal data, this policy ensures that the Company
complies with the data protection laws and notification requirements.

Every individual has the
right to lodge a complaint with the supervisory authority where they consider
that the processing of personal data relating to them infringes GDPR/DPA18 or
we have breached data protection law. All individuals using our products or
services and those employed by us are notified of this right via our Privacy
Notice, in our complaint handling procedures and in our information
disclosures.

The supervisory authority
with which the complaint has been lodged is responsible for informing the
complainant on the progress and the outcome of the complaint, including the
possibility of a judicial remedy where the supervisory authority does not handle
a complaint or does not inform the data subject within three months on the
progress or outcome of the complaint lodged.

INFORMAL
COMPLAINT RESOLUTION

The Company considers and
responds to all complaints and issues, no matter how they are raised or what
hey refer to. Some issues and complaints we can resolve immediately or within a
3-working day timeframe and are referred to as informal complaints.

Such instances are where an
investigation is not required because the nature of the complaint is clear, and
a resolution can be obtained without further review of the facts. Where we
resolve a complaint within the timeframe, the details are still logged on our
complaint register, and the complainant is still informed of their rights.

The Company takes every
opportunity to resolve complaints at the first initial point of contact where
feasible and possible. Informal resolution is always attempted where the issues
raised are straightforward and potentially easily resolved, requiring little or
no investigation.

Most face to face and
telephone issues can be resolved in this manner, however the complainant is
always offered the option of making the complaint formal if the resolution is
not to their satisfaction.

Where an informal complaint
is received, it is acceptable for the point of contact or addressed employee to
attempt to resolve the issue without involving the Complaints Officer. However,
any issue relating to data protection infringes or breaches, no matter how
small or informal, are always brought to the attention of the DPO or appointed
person.

Frontline staff are trained
to deal with basic issues and informal complaint resolution and are aware if
their obligations and the subsequent reporting lines. Such employees are
equipped to attempt to resolve a complaint relevant to their area of service or
expertise, wherever possible.

TIMEFRAME
FOR INFORMAL RESOLUTION

It is the aim of the Company
to resolve informal complaints immediately, or at least within the first
24-hours. Such complaints and issues will have a quick, but informative
response and do not need to have an investigation or enter the formal complaint
process.

No matter how small or informal the complaint, if a satisfactory resolution has
not been achieved within 3 working days of the complaint being raised or
identified, the issue is passed to the Senior Manager to enter the formal
complaint process.

FORMAL
COMPLAINT RESOLUTION

We have specific procedures
in place for the receipt of a formal complaint, regardless of the medium in
which it was received. This includes the progression of an informal complaint
that we were unable to resolve during the initial point of contact.

For acknowledgements made by
post, the procedures are enclosed in a hard-copy letter format. Where the
customer has requested to correspond via email, we provide the complaint
procedures as a PDF attachment.

The Senior Manager is the
only staff member who respond to customers regarding their complaints. The have
been provided with the time, resources and training to communicate effectively
with customers regarding concerns and formal complaints.

RESPONSE
TIME FOR FORMAL RESPONSE

For all formal complaints, a
written acknowledgement is sent to the customer within 3 working days. We
provide approximate timelines and expectations for the investigation and future
responses within initial acknowledgement response.

All investigations take
place with 6-weeks of the initial complaint being received. We aim to send our
final response (decision letter) to the customer within our designated 8-week
period. Where this is not possible, the customer will be updated using our
8-Week Holding Letter response to provide them with an update and reason(s) for
the delay.

INVESTIGATING
THE COMPLAINT

The Senior Manager will be
assigned the role of investigating complaints and will gather all necessary
documents, recordings and information to make an independent review of the
incident.

If internal interviews are
to be conducted, a note taker will be present alongside the investigator and
interviewee and a copy of the interview notes will be written up and signed by
the interviewer and interviewee prior to them being added to the complaint
history.

All investigations must take
place with 6-weeks of the initial complaint being received so that a final
response (decision letter) can be sent to the customer within our designated
8-week period.

Investigations must utilise
all the facts and any previous, related information to produce an unbiased
outcome and an expected course of action. A complaint reference should be
assigned and all documents relevant to the complaint should have the reference
written on them for continuity.

The reference will also be
added to the Complaints Register so that complaint and document can be audited
and traced back in the future.

All employees are provided
with clear guidelines of when a complaint is formal and requires an appropriate
investigation.

DECISION
LETTER (FINAL RESPONSE)

After the complaint has been
investigated in full and an outcome decision has been reached, the Senior
Manager will draft a final response letter to the complainant with their
findings and decision regarding any action(s) to be taken or compensation awarded.

The final response will be
sent within 8 weeks of the initial complaint being raised and will also specify
the complainants right to refer to or lodge the complaint with the appropriate
body (where applicable) should the customer be unhappy with the final decision.

For
complaints to firms regulated by The Financial Ombudsman Service (FOS),
the final response will detail the FOS’s telephone number and address and
the ombudsman’s consumer leaflet will also accompany the final letter. The
complainant will be provided with the options for taking the matter
further and that they have only 6 months to log the complaint with the
FoS.

For complaints related to personal data
and/or breaches of the data protection laws and regulations, the final
response will reiterate the complainants right to lodge a complaint with
the supervisory authority (the Information Commissioners Office) and will
detail the ICO’s telephone number and address, along with the possibility
of seeking a judicial remedy.

Complaint Recording

All complaints, whether
formal or informal, are recorded on a Customer Complaint Register. The register
consists of the below information and is audited on a monthly basis to ensure
that incidents are not being repeated and improvements are being made.

Date

Nature
of Complaint

Department(s)
Involved

Complaint
Reference

Lead
Investigator

Decision
Letter Sent (Y/N)

Date Complaint Closed

The register is made
available to any relevant authority, ombudsman or body who relates to or
oversees the firms’ complaints, as well as being made available with the local
Trading Standards should a representative work alongside the organisation.

PATTERNS
AND ANALYSIS

The complaint register and
form are reviewed monthly by the Senior Manager to identify any patterns or
reoccurring issues. The Company are dedicated to improving our performance,
services and functions through the auditing of our complaint records and our
investigation process. Where gaps or patterns are identified, we put corrective
actions into place as soon as possible and keep the unction, process or person
under a weekly review until a satisfactory improvement is noted.

PUBLISHED
COMPLAINT PROCEDURES

The Company has a
user-friendly version of its complaint procedures that are made available to
customers. This provides them we easy to access and understand guidance on how
to raise a complaint and the process and timeframes for resolution. The
customer complaint procedures are published on our website.

We also provide a hard-copy complaint procedure letter and a PDF digital
version for responses by post and email.

Responsibilities

The Company will ensure that
all staff are provided with the time, resources and support to learn,
understand and deal with customer complaints and that full training will be
provided for new and existing employees on the complaint handling policy, procedures
and expectations.

The Senior Manager will be
appointed the role of overseeing, investigating and recording all customer
complaints and is responsible for regular monitoring of the complaint register
to ensure mitigating actions and improvements are put into place where required.

THE
COMPLAINT OFFICER

The Company has an appointed
Senior Manager who deals with all complaints and is provided with the training
and support to understand, investigate and respond to complaints of all types.
Where the complaint involves personal data, the Senior Manager is assisted by
the Data Protection Officer/Appointed Person to ensure that the relevant data
protection regulations and laws are adhered to, and the individuals’ rights are
exercised and complied with.

The Company ensures that the
person assigned to handle complaints can complete their duties independently
and without bias and is afforded adequate resources to review each complaint
effectively. In the absence of the assigned complaint officer, or if a conflict
of interest is identified (i.e. the complaint involves the investigating
person), we have a nominated deputy who is fully trained to handle complaints.

The Senior Manager has full authority and internal credibility to ask
questions, carry out investigations and interviews, obtain and analyse
evidence, recommend policy and process changes and be involved in department
functions for the purposes of complaint handling.