Complaints Management Policy

The Financial Advisory and Intermediary Services (FAIS Act 37/2002) provides a duty on every Authorised Financial Services
Provider (hereafter “the Provider”) to offer clients a formal process to resolve Complaints.
The process to resolve Complaints must offer the client an opportunity to lodge a Complaint with the Compliance Officer
and that such Complaint must be resolved within 6 (six) weeks. Should it not be resolved within 6 (six) weeks, the matter can
be escalated to the FAIS Ombud for a final ruling within 6 (six) months after a determination that the Provider cannot resolve
the Complaint.
The Provider is constantly searching for new ways of improving client service experience through innovative ideas and
personal attention. Client Complaints will be facilitated as fairly, effectively and promptly as possible.
Feedback from clients is highly valued as it allows the Provider to constantly advance service delivery and processes by
satisfactorily resolving any Complaints.

Unless the context clearly indicates otherwise, the following definitions shall have the meanings for purposes of this policy:
“Complaint” means a grievance or statement of dissatisfaction relating to a financial service rendered by the Provider or its
Representatives to the complainant in which it is alleged that the Provider or a Representative:
▪ has failed to comply with a provision of the FAIS Act or has wilfully or negligently rendered a financial service, and
as a result, the complainant has or is likely to suffer damage or financial prejudice
▪ has treated the complainant unfairly
“FAIS Ombud” means the Ombud of Financial Services Providers as referred to in Sec 20(2) of the FAIS Act
“Resolution” means the process of resolving a Complaint following the internal Complaint Resolution procedures of the
“Rules” means a set of explicit governing principles of the office of the FAIS Ombud as published in the Gazette

This document serves to state the commitment of the Provider in terms of Complaints Resolution. The Provider will maintain
an effective Complaint Resolution procedure to ensure prompt Resolutions of written Complaints by means of:
▪ Enabling easy access to the dispute Resolution policies and procedures to the clients by means of our website or
on request by mail, fax or email
▪ Taking all necessary steps to investigate the Complaint after receipt and recording thereof, offering proper
▪ Addressing and resolving any Complaints received in a timely and fair manner
▪ Being transparent in the Resolution process
▪ Ensuring that responsibilities and mandates are delegated to facilitate disputes and an escalation process to staff
with adequate expertise to improve services and dispute Resolution systems and procedures where necessary
▪ Furnishing the client with comprehensive reasons and providing procedural advice and contact details of the
relevant regulatory body in the instances where the outcome of a dispute is not satisfactory to the client
▪ Maintaining appropriate records of all Complaints for a period of 5 (five) years
▪ Implementing follow-up procedures to implement remedial actions to prevent similar Complaints from occurring
and improve services and procedures
▪ If necessary, appointing an independent mediator to resolve the Complaint to the benefit of both the client and
the Provider
▪ Empowering and properly train employees to deal with Complaints

A quick and appropriate response must be ensured when a Complaint is lodged and therefore a proper procedure must be
in place to facilitate the response times and to whom it each step will be escalated.
Any client can submit a Complaint to the Compliance Officer of the Provider with the following details:
4.1 Submission
Address: Contact details:
Floor 2, The Club Tel: 072 351 1653
C/O Pinnaster and 18th Street E-mail:
Hazelwood, Pretoria
The Complaint must be in writing and contain the following information:
▪ Client details (name, surname, ID number, contact details, employment details)
▪ Date of Complaint and description thereof
▪ Any documentary proof, if applicable
4.2 Acknowledgement
▪ Upon receipt, the Complaint must be validated and logged as a new Complaint on the Complaint Register
▪ The Compliance Officer will acknowledge receipt of the Complaint in writing within 5 (five) working days
▪ The Complaint will be assigned and investigated as a responsibility of the Compliance Officer together with the
relevant entity and business unit concerned
4.3 Reply and investigation
▪ Resolve the Complaint immediately or take the necessary action to resolve the Complaint within 5 (five) working
▪ If the above timeframe is not possible, advise the client of steps taken and expected date of Resolution
▪ The nature of the Complaint and the product type will also be taken into account when the above points are
▪ The Complaints Register must be updated with all developments and activities
▪ The client must be informed in writing of the Resolution and outcome of the Complaint
No person who is directly involved in the Complaint is allowed to investigate same and the investigation shall be carried out
by the Compliance Officer. No matter the outcome of the matter, the nature of the Complaint will be investigated to ensure
that remedial action is taken to avoid that a similar Complaint arises in the future.
4.4 Secondary Reply
▪ The client must be notified if the Complaint is not resolved within 6 (six) weeks
▪ The client must further be informed of his/her right to approach the relevant regulatory authorities as set out at
the end of this policy within 6 (six) months of the occurrence of the conduct giving rise to the Complaint
▪ Different regulatory bodies (including legal advisory bodies) may be contacted according to the nature of the
product and services concerned

The Rules governing the proceedings of the office of the FAIS Ombud make provision for the following rights and duties of
the Provider:
▪ The Provider has a right to be informed of the Complaint submitted to the Ombud to enable the Provider to
respond thereto fully
▪ The Provider may submit any information or documentation that is relevant to the Complaint
▪ The Provider has a duty to submit further information if so requested by the Ombud and if needed, to discuss the
matter with the Ombud
▪ The Provider has a duty to act professional and reasonable
▪ The Provider must cooperate with a view to ensuring efficient Resolution of the Complaint

When the Ombud accepts a Complaint in terms of Sec 27(5) of the FAIS Act, the office of the Ombud may require the FSP to
pay a case fee.
Should a Complaint not be resolved through conciliated settlement, the Ombud will make a determination which can be a
monetary award or any order that can be made by a court. The Ombud has the legal status of a civil court judgment.
A cost award may be made against the Respondent (the person against whom a Complaint was made). It is also possible for
a cost award to be made against the complainant if his/her conduct was unreasonable, or it has caused/is likely to cause
damages to the Provider’s reputation, or if the complainant caused an unreasonable delay in the finalisation of the

The Ombud may grant leave to appeal to the Board of Appeal. An application for leave to appeal must be made within 1
(one) month of the Ombud’s determination.
Should the Ombud refuse to leave to appeal, a request can be directed to the chairperson of the Board of Appeal for
permission to appeal within 1 (one) month of the Ombud’s refusal. The applicant must inform the Ombud if such an
application is made.
The Board of Appeal will decide and it will have the same status as a civil court judgment.

Physical address:

FAIS Ombud 473 Lynnwood Road Sussex Office Park Block B, Ground Floor Lynnwood Pretoria, 0081 South Africa

Client contact division:

Tel: +27 12 470 9080

Tel: +27 12 762 5000

Fax: +27 012 348 3447



Postal address

PO Box 74571 Lynnwood Ridge 0040