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.
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.