Complaints policy

Scope

This policy applies to all staff processes and systems across our business that might give rise to a complaint. Any complaint from any party on a matter concerning any aspect of our business including those complaints which may not meet the FCA definition as set out in DISP sourcebook.

Purpose

To set minimum standards to ensure that complaints are handled in a way that ensures compliance with all regulatory standards, acts in the customers best interests by treating them fairly and supporting improved performance.

Definitions

Complaint:

A complaint is any expression of dissatisfaction, whether oral or written, and whether justified or not, from or on behalf of an eligible complainant which alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience and relates to an activity of the firm or any other firm with whom it has some connection in marketing or providing financial services or products which comes under the jurisdiction of the Financial Ombudsman Service.

Eligible Complainant:

• A Consumer – as defined in the FCA Handbook glossary
• Professional Clients and eligible counterparties where the person is an individual acting for purposes wholly or mainly outside his trade, business, craft or profession
• Charities with annual income of less than £6.5million
• Trustee of a trust which has a net asset value of less than £5million
• Businesses which employ fewer than 50 persons and have an annual turnover of under £6.5 million or an annual balance sheet of under £5million
• A Guarantor

Compensation limits:

• Financial Ombudsman compensation limits – click here.

Requirements

1. All complaints will be identified, categorised and managed based on the individual circumstances of the complainant and the root cause of the complaint

• All customers will be provided with clear, easy to understand details of our complaints handling procedures and will be offered a choice of channel by which to complain to suit their needs and will not experience any barriers to making a complaint. Complaint handling procedures are included in product literature, customer TOBA’s, scripts and websites.
• All relevant staff will complete mandatory online learning modules on complaints handling including refresher tests in accordance with our training and competency framework and the FCA requirement for a minimum of 15 hours CPD
• The complaints handling procedure provides a clear definition of a complaint to assist with consistent identification including the treatment of eligible complainants and vulnerable complainants
• We have in place appropriate and effective procedures for registering and responding to complaints from a person who is not an eligible complainant  
• An initial assessment by our nominated Complaints Manager will be made of the individual circumstances of all complainants assessing their eligibility and vulnerability and direct/indirect relationship and managed in accordance with the complaints handling procedures.

2. All complaints will be fully recorded on a timely basis

• Complaints will be logged within 1 day of identification and reportable complaints managed by our Complaints Manager or designated person
• Where complaints relate to a third party rather than us this will be recorded and forwarded to the Third Party within 1 business day advising the client in writing on the same day as to action taken
• A fit and proper system will be used to log and track all complaints, the system will have fields to capture all required data, record of communication with complainant, settlement date, settlement cost, and a menu for nature of complaint/root cause.

3. All complaints will be actioned on a timely and consistent basis

• Wherever possible complaints will be acknowledged promptly
• Where complaints are resolved by the close of business on the third business day we will issue the complainant with a summary resolution communication in a case where it meets the FCA definition
• Complaints that cannot be resolved by close of business on the third day following notification will be resolved no later than 8 weeks after notification
• Clear easy to understand complaints handling guidance is set out in the Guide to Best Practice and will be supported by staff training material covering investigating, record keeping, escalation, time limits, redress and financial response.

4. Complainants will be regularly informed of progress about their complaint

• Written acknowledgement will be made to the complainant for all reportable complaints (i.e. those not already resolved within the three days) no later than 5 working days after notification
• Where complaints have not been resolved within 8 weeks, a written response will be sent to the complainant explaining why we are not in a position to make a final response indicating when we expect to be able to provide one. Eligible Complainants will be informed of their right to refer the complaint to the Financial Ombudsman Service (FOS) and provided with a FOS leaflet.

5. The root causes of complaints will be identified and remedial action taken where necessary to prevent recurrence

• Root cause analysis will be undertaken by our Complaints Manager to identify systematic issues raised by complaints and remedial actions will be taken to mitigate the causes from recurring
• Our Management will ensure that we hold PI insurance sufficient to cover the compensation limits. 

6. The level root cause and cost of complaints will be measured, analysed and reported on a regular basis to our management team. Complaints reports will include:

• Complaints volume and value
• Age analysis of complaints
• Percentage escalated to FOS and percentage upheld
• Resolution satisfaction and post complaint behaviour
• Trend analysis
• Root cause analysis and associated management actions
• Quality Assurance activity and results.

7. Regulatory Reporting

• Complaints data is reported to the FCA via RMAR on a 6 monthly basis
• We do not report to the regulator complaints redirected to third parties or made by non-eligible complainants.

8. Record Keeping

• It is our policy to maintain complaints correspondence for a period of six years from the date the complaint is closed.

Other documents relevant to this policy

• Complaints Handling Flowchart
• Complaints Record
• Complaints Register
• Fair Treatment of Customers Policy
• Guide to Best Practice – Complaints
• Guide to Best Practice – Fair Treatment of Customers
• Record Keeping & Retention Period Policy
• Responsibility Table