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Dispute Resolution Policy

Initium Investments Pty Ltd

PURPOSE

The purpose of the Initium Investments Pty Ltd’s Initium Investments Dispute Resolution Policy is to ensure client complaints are dealt with promptly, fairly and consistently.

This Policy represents Initium Investments’ commitment to fair and transparent dealings in the financial marketplace.

This Policy is drafted to comply with ASIC Regulatory Guide 165: Licensing: Internal and external dispute resolution and Initium Investments’ obligations under section 47(1)(h) of the National Consumer Credit Protection Act 2009 (Cth) (“the National Credit Act”) and Australian Standard AS ISO 10002-2006.

This Policy reflects Initium Investments’ obligation under the National Credit Act, to be a member of an ASIC External Dispute Resolution (“EDR Scheme”).



POLICY STATEMENT

The benefits of effectively resolving client complaints through an Internal Dispute Resolution (“IDR”) procedure with broad coverage include:

  • the opportunity to resolve complaints quickly and effectively;
  • the ability to identify and address recurring or systemic problems, which can lead to product and service improvements;
  • the capacity to provide fast solutions to problems rather than have remedies imposed by an external body; and
  • improved levels of client confidence and satisfaction.

Wherever possible, complaints should be resolved directly with clients through the IDR procedures. It is better, for all parties, to have a complaint dealt with at the earliest possible stage because it:

  • prevents complaints from becoming entrenched;
  • preserves client relations; and
  • is often the most efficient and cost-effective way for an organisation to deal with complaints.


AIMS

To resolve minor complaints during the client’s initial contact with Initium Investments.

To action all other complaints, written and telephone, within ten (10) calendar days of them being received.

To resolve all complaints and provide a final response within forty-five (45) calendar days of receipt.



DEFINITIONS


Complaint means any expression of dissatisfaction that:


  • is conveyed to Initium Investments in writing or by telephone; and
  • relates to the provision of a product or service provided by Initium Investments.

Initium Investments means Initium Investments Pty Ltd.


Final Response means a written response to the complainant informing them of:

  • the final outcome of their complaint or dispute;
  • their right to take their complaint or dispute to an EDR Scheme; and
  • the name and contact details of the relevant EDR Scheme to which they can take their complaint or dispute.


PROCEDURES


RECEIVING COMPLAINTS


Initium Investments’ employees must immediately refer clients wishing to make a complaint to the Compliance Manager. This ensures that wherever possible, the complaint will be investigated by a staff member not involved in the subject matter of the complaint.

On receiving a complaint, the following information must be recorded:

  • date of complaint
  • name of complainant;
  • contact details of complainant;
  • format of complaint (phone/email/letter/fax);
  • preferred contact method of complainant (phone/email/letter/fax);
  • details of the complaint; and
  • classification of the complaint (Refer to section 6).

Once the complaint is received, the Compliance Manager must immediately acknowledge receipt of the complaint using the preferred contact method of the complainant immediately and attempt to resolve the complaint within ten (10) calendar days of it being received.



CLASSIFICATION OF COMPLAINTS

Level 1 – the least serious complaints. The complaint could not be resolved at first contact with the client. Some complaints at this level will require the assistance of other employees at Initium Investments. The complaint can be resolved without escalating it to the Compliance Manager.

Level 2 – more serious complaints. The Compliance Manager must be informed of the complaint. The Compliance Manager may provide input where necessary to help resolve the complaint.

Level 3 – the most serious complaints. This type of complaint will require the involvement of both the Compliance Manager and the Director.



RESPONSIBILITY FOR AND INVESTIGATION OF COMPLAINTS

At first instance the Compliance Manager is responsible for dealing with complaints.

If the Compliance Manager is unable to resolve the complaint within ten (10) calendar days, the details of the complaint must be immediately forwarded to the Compliance Manager, who has overall responsibility for the Initium Investments’ IDR processes.

The Compliance Manager is to review the circumstances involving the complaint and attempt to provide the client with a written response to help resolve the complaint and provide a final response to the complainant, within forty-five (45) calendar days of receipt of the initial concern or complaint (except for a complaint or dispute relating to hardship).

If the Compliance Manager is unable to resolve the complaint within forty-five (45) calendar days, a letter or email must be provided which:

  • informs the client of the reasons for the delay;
  • provides the client with monthly updates on the progress of the complaint;
  • specifies a date when a decision can be reasonably expected; and
  • includes a copy of the Credit Guide.


RESPONDING TO COMPLAINTS WITHIN APPROPRIATE TIME LIMITS

Complaints referred to the Compliance Manager must be responded to in the same manner as they are received unless otherwise requested by the client. For example, a telephone complaint must be initially responded to with a telephone call.

The time and date of all telephone calls to the client made in connection with a complaint must be recorded with other details about the complaint outlined in section 5.2.

The client must receive a communication in their preferred contact method at least once every five (5) business days after the initial complaint is made until the complaint is resolved within the appropriate timeframes outlined in section 8.4.

TYPE OF COMPLAINT MAXIMUM TIMEFRAME TO RESPOND
For complaints involving applications for hardship relief or request for postponement of enforcements proceedings made. Twenty-one (21) calendar days.
For complaints involving default notices. Twenty-one (21) calendar days.
For all other complaints. Forty-five (45) calendar days.

A final response is not required to be provided when a complaint (except for a complaint relating to hardship) is resolved to the complainants complete satisfaction by the end of the fifth (5th) business day of receipt and if the complainant has not requested a response in writing.

A final written response must be provided for all complaints relating to hardships. Please refer to Initium Investments’ Hardships Policy for further details.



RESOLUTION OF COMPLAINTS

When an outcome is reached for a complaint, the client needs to be advised of the final response by email, fax or letter.



COMPLAINTS REGISTER

A Complaints Register is to be compiled and managed by the Compliance Manager.

A copy of the Complaints Register is to be provided to the Compliance Manager prior to the quarterly meeting of the Compliance Committee.

The Compliance Manager must maintain a hard copy record of the Complaints Register in the office of the Compliance Manager.



IDENTIFYING AND RECORDING SYSTEMIC ISSUES

The Compliance Manager should aim to identify any systemic issues or recurring complaints as a result of compiling the Complaints Register.

Where any systemic issues or recurring complaints are identified, these should be addressed to the Compliance Manager by preparing a report to accompany the Complaints Register. The issues will be included in the Compliance Report presented at the next meeting of the Compliance Manager and Director of Initium Investments. This will encourage the identification of compliance issues or risks, which can be investigated to determine their causes and then rectified.



REMEDIES


TYPES OF REMEDIES AVAILABLE FOR RESOLVING COMPLAINTS

If the Compliance Manager is of the opinion that a complaint requires a remedy (e.g. compensation), the matter must be referred to the Director to make a determination.



INTERNAL STRUCTURES AND REPORTING REQUIREMENTS


RESOLVING COMPLAINTS

Once the complaint has been resolved, the client must be notified.

Level 1 complaints – this should be affected by the same method that the complaint was originally made (e.g. by telephone or email), unless otherwise requested by the client. Details of the time and date of any telephone calls must be recorded, together with the information about the complaint.

Level 2 and 3 complaints – a formal email or letter must be sent to the client notifying or confirming (as appropriate) the resolution of their complaint. A copy of all correspondence must be maintained in the Complaints Register.



DUTY OF CARE TO CLIENTS AND STAFF

The IDR process should not involve the release of information in relation to Initium Investments generally, or clients or staff individually, that contravenes any of Initium Investments’ policies in relation to confidential information or the contractual obligations of Initium Investments.

Further information and advice on this matter can be obtained from the Compliance Manager.Reponses to IDR matters that contain personal information on clients or staff must be provided to the Compliance Manager for final approval, prior to publication or release.



CONCLUSION


EXTERNAL DISPUTE RESOLUTION (“EDR”) SCHEME

Initium Investments is a member of the AFCA. AFCA is an EDR Scheme approved by ASIC.

This external and impartial service is available to clients free of charge. It has jurisdiction to hear and resolve any dispute that is not resolved by Initium Investments’ IDR process.

The external and impartial process will apply the law and may take into account what is fair in all the circumstances to both the client and Initium Investments.

Initium Investments has a guide for clients that includes reference to the availability of this EDR mechanism.



TRAINING

Employees of Initium Investments who deal with clients, not just complaints handling staff, need to have an understanding of the IDR procedures. Consequently, all employees of Initium Investments will receive regular training and information about the IDR process. This training will be scheduled and conducted at the discretion of the Compliance Manager.



DOCUMENT RETENTION AND AUDIT

Managers, Compliance Managers, officers or employees of Initium Investments are required to retain copies of all Complaints Handling documents in accordance with Initium Investments’ Document Retention Policy. These files are to be maintained at the premises of Initium Investments . A copy must also be provided to the Compliance Manager for storage and inspection by ASIC as required.

The Complaints Register is provided to the Compliance Manager on a monthly basis and a hard copy is kept on file.



POLICY REVIEW

This Policy will be reviewed regularly by the Compliance Manager, having regard to the changing circumstances of Initium Investments. Any amendments to this Policy will be advised by email and any updates to this Policy will be advised to Initium Investments’ staff.