Complaint Handling Policy

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1. COMPLAINTS POLICY AND PROCEDURE

1.1. Introduction

The purpose of this document is to set out a complaints policy and the procedure to be followed when resolving complaints. The complaints policy and procedure shall be referred to as the Complaint Management System (“CMS”).

When responding to complaints, staff should act in accordance with our complaint handling procedures as well as any other internal documents providing guidance on the management of complaints.
Staff should also consider any relevant legislation and/or regulations when responding to complaints and feedback.

The CMS is a procedure internal to Falcon FX, which a complainant must first follow and exhaust before seeking remedies external to Falcon FX.

The five key stages in our CMS are the following, and are set out below:

 1.2.Receipt of complaint

Unless the complaint has been resolved at the outset, we will record the complaint and its supporting information in a complaint register. We will also assign a unique identifier to the complaint file.

The record of the complaint will document:

  • the name and contact information of the person making a complaint
  • issues raised by the person making a complaint and the outcome/s they want
  • any other relevant; and
  • any additional support the person making a complaint requires.

1.3.Acknowledgement of complaints

We will acknowledge receipt of each complaint promptly, and preferably within 2 business days. Consideration will be given to the most appropriate medium (e.g. email, letter) for communicating with the person making a complaint.

1.4. Initial assessment and addressing of complaints

1.4.1.Initial assessment

After acknowledging receipt of the complaint, we will confirm whether the issue/s raised in the
complaint is/are within our control. We will also consider the outcome/s sought by the person making
a complaint and, where there is more than one issue raised, determine whether each issue needs to
be separately addressed.

When determining how a complaint will be managed, we will consider:

  • The nature of the complaint;
  • How serious, complicated or urgent the complaint is;
  • How the person making the complaint is being affected;
  • The risks involved if resolution of the complaint is delayed; and
  • Whether a resolution requires the involvement of other organisations.

1.4.2. Addressing complaints

After assessing the complaint, we will consider how to manage it. To manage a complaint we may:

  • Give the person making a complaint information or an explanation;
  • Gather information from the product, person or area that the complaint is about, or
  • Investigate the claims made in the complaint.

We will keep the person making the complaint up to date on our progress, particularly if there are any delays. We will also communicate the outcome of the complaint using the most appropriate medium. Which actions we decide to take will be tailored to each case and take into account any statutory requirements.

The nature of the complaint will determine which person within the orgainisation will attend to the complaint. The purpose of this is to ensure that the most qualified and knowledgable person in the orgainsation is allocated to the complaint.

1.5.Providing reasons for decisions

Following consideration of the complaint and any investigation into the issues raised, we will contact the person making the complaint and advise them:

  • the outcome of the complaint and any action we took;
  • the reason/s for our decision;
  • the remedy or resolution/s that we have proposed or put in place; and
  • any options for review that may be available to the complainant, such as an internal review, external review or appeal.

If in the course of investigation, we make any adverse findings about a particular individual, we will consider any applicable privacy obligations under the Protection of Personal Information Act and any applicable exemptions in or made pursuant to that Act, before sharing our findings with the person making the complaint.

1.6. Closing the complaint, record keeping, redress and review

We will keep comprehensive records about:

  • How we managed the complaint;
  • The outcome/s of the complaint (including whether it or any aspect of it was substantiated, any recommendations made to address problems identified and any decisions made on those recommendations; and
  • Any outstanding actions that need to be followed up.

We will ensure that outcomes are properly implemented, monitored and reported to the complaint handling manager and/or senior management.

1.7.Alternative avenues for dealing with complaints

We will inform people who make complaints to or about us about any internal or external review options available to them (including any relevant Ombudsman or regulatory bodies, such as the FSCA).

1.8.The three levels of complaint handling

We aim to resolve complaints at the first level, the frontline. Wherever possible staff will be adequately equipped to respond to complaints, including being given appropriate authority, training and supervision.

Where this is not possible, we may decide to escalate the complaint to a more senior officer within Falcon FX. This second level of complaint handling will provide for the following internal mechanisms:

  • assessment and possible investigation of the complaint and decision/s already made, and/or
  • facilitated resolution (where a person not connected with the complaint reviews the matter and attempts to find an outcome acceptable to the relevant parties).

Where a person making a complaint is dissatisfied with the outcome of Falcon FX’s review of their complaint, they may seek an external review of our decision (by the Ombudsman for example).

1.9.Accountability and learning

1.9.1.Analysis and evaluation of complaints

We will ensure that complaints are recorded in a systematic way so that information can be easily retrieved for reporting and analysis.

Regular reports will be run on:

  • the number of complaints received;
  • the outcome of complaints, including matters resolved at the frontline;
  • issues arising from complaints;
  • systemic issues identified; and
  • the number of requests we receive for internal and/or external review of our complaint handling.

Regular analysis of these reports will be undertaken to monitor trends, measure the quality of our customer service and make improvements.

Both reports and their analysis will be provided to Falcon FX’s board of directors.

1.9.2.Monitoring of the complaint management system

We will continually monitor our complaint management system to:

  • ensure its effectiveness in responding to and resolving complaints; and
  • identify and correct deficiencies in the operation of the system.

Monitoring may include the use of audits, complaint satisfaction surveys and online listening tools and alerts.

1.9.3.Continuous improvement

We are committed to improving the effectiveness and efficiency of our complaint management system. To this end, we will:

  • support the making and appropriate resolution of complaints;
  • implement best practices in complaint handling;
  • recognise and reward exemplary complaint handling by staff;
  • regularly review the complaints management system and complaint data; and
  • implement appropriate system changes arising out of our analysis of complaints data and continual monitoring of the system.

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