1. PURPOSE OF POLICY 
The purpose and objective of the Complaints Policy is to:
1.1 Ensure that clients’ rights are safeguarded by providing a structured process for addressing grievances related to financial services.
1.2 Establish a mechanism for the prompt and impartial investigation of complaints, promoting fair outcomes for all parties involved.
1.3 Establish clear procedures for clients to lodge complaints, ensuring they understand their options and the process involved. This includes appropriate management and categorisation of complaints, expected timeframes for resolution, and the conditions under which these timeframes may be extended.
1.4 Hold the company responsible for its conduct by adhering to ethical standards and regulatory requirements.
1.5 Use insights from any complaints to improve service quality, identify potential issues, and enhance overall compliance and regulatory practices.
1.6 Outline the communication standards with complainants.

2. DEFINITIONS
2.1 ‘Advice’ means, any recommendation, guidance or proposal of a financial nature furnished, by. any means or medium, to any client or group of clients: –
2.1.1 In respect of the purchase of any financial product;
2.1.2 In respect of the investment in any financial product;
2.1.3 On the conclusion of any other transaction, including a loan or cession, aimed at the incurring of any liability or the acquisition of any right or benefit in respect of any financial product; or
2.1.4 On the variation of any term or condition applying to a financial product, on the replacement of any such product, or on the termination of any purchase of or investment in any such product,
2.1.5 and irrespective of whether or not such advice: –
2.1.6 Is furnished in the course of or incidental to financial planning in connection with the affairs of the client; or
2.1.7 Results in any such purchase, investment, transaction, variation, replacement or termination, as the case may be, being affected;
2.1.8 that results in the purchase, by the Complainant, of any product based on the advice.
2.2 ‘Business Day’ means any day except a Saturday, Sunday, or public holiday.
2.3 ‘Client Query’ means a request to the provider or the provider’s service supplier by or on behalf of a client, for information regarding the provider’s financial products, financial services or related processes, or to carry out a transaction or action in relation to any such product or service.
2.4 ‘Complainant’ means a person who submits a complaint and includes a:
2.4.1 Client;
2.4.2 Person nominated as the person in respect of whom a product supplier should meet financial product benefits or that persons’ successor in title;
2.4.3 Person whose life is insured under a financial product that is an insurance policy;
2.4.4 Person that pays a premium or an investment amount in respect of a financial product;
2.4.5 Member;
2.4.6 Person whose dissatisfaction relates to the approach, solicitation marketing or advertising material or an advertisement in respect of a financial product, financial service, or related service of the provider, who has a direct interest in the agreement, financial product or financial service to which the complaint relates; or
2.4.7 or a person acting on behalf of a person referred to above.
2.5 ‘Complaint’ means an expression of dissatisfaction by a person to us as a service provider or to our knowledge, to our service supplier relating to a financial product or financial service provided or offered by us. This expression of dissatisfaction, regardless of whether it is submitted together with or in relation to a client query, indicates or alleges that:
2.5.1 The provider or its service supplier has contravened or failed to comply with an agreement, a law, a rule, or a code of conduct which is binding on the provider or to which it subscribes;
2.5.2 The provider or its service supplier’s maladministration or wilful or negligent action or failure to act, has caused the person harm, prejudice, distress, or substantial inconvenience; or
2.5.3 The provider or its service suppliers has treated the person unfairly.
2.6 ‘Compensation payment’ means a payment, other than a goodwill payment, made by us to a complainant, whether in monetary form or in the form of a benefit or service, to a complainant to compensate the complainant for a proven or estimated financial loss incurred as a result of the provider’s contravention, non-compliance, action, failure to act, or unfair treatment forming the basis of the complaint.. Compensation payment excludes:
2.6.1 payment of amounts contractually due to the complainant in terms of the financial product or financial service concerned; or
2.6.2 refunds of amounts paid by or on behalf of the complainant to us where such payments were not contractually due;
But includes any interest on late payment of any amount referred to in 2.6.1 or 2.6.2.
2.7 ‘Complaints Handling’ refers to the process of addressing and resolving complaints, which includes ongoing interaction with Complainants. The Process is expected to adhere to certain minimum standards
2.8 ‘Complaints Management’ means the management of the entire lifecycle of a complaint. This includes the ease of process for clients to lodge complaints and the associated communication. It encompasses the handling, recording, resolution, and quality control of complaints; the management and training of personnel involved in complaint management processes; decision-making processes; restoration of client trust; compilation and analysis of reports; and, ultimately, learning from feedback gathered through complaints to take corrective and proactive actions accordingly.
2.9 ‘Evidence’ means the information the business has obtained in order to review, adjudicate and resolve a complaint and shall include all information submitted by the Complainant to be stored and recorded on the complaints management system or other repositories for storing and recording information. This shall include, but is not limited to, personal information and documents, claim forms, administration documentation, sales and other recordings, application forms, policy documentation, trade accounts and fees, trading history etc.
2.10 ‘Goodwill payment’ means a payment, whether in monetary form or in the form of a benefit or service, by or on behalf of a provider to a complainant as an expression of goodwill aimed at resolving a complaint, which cannot be misconstrued as a concession or acceptance of fault, on or by the Provider.
2.11 ‘Intermediary Service’ means, subject to subsection (3)(b) of the FAIS Act, any act other than the furnishing of advice, performed by a person for or on behalf of a client or product supplier:
2.11.1 The result of which is that a client may enter into, offers to enter into or enters into any transaction in respect of a financial product with a product supplier; or
2.11.2 With a view to:
buying, selling or otherwise dealing in (whether on a discretionary or non-discretionary basis), managing, administering, keeping in safe custody, maintaining or servicing a financial product purchased by a client from a product supplier or in which the client has invested;
collecting or accounting for premiums or other moneys payable by the client to a product supplier in respect of a financial product; or
receiving, submitting, or processing the claims of a client against a product supplier.
2.12 ‘Reject or rejected’ in relation to a complaint means that the complaint has not been upheld, and we regard the complaint as finalised after advising the complainant that we do not intend to take any further action to resolve the complaint.
2.13 ‘Reportable complaint’ means any complaint other than a complaint that has been:
2.13.1 Upheld immediately by the person who initially received the complaint;
2.13.2 Upheld within the provider’s ordinary processes for handling client queries in relation to the type of financial product or financial service complained about, provided that such process does not take more than five business days from the date the complaint is received; or
2.13.3 Submitted to or brought to the attention of the provider in such a manner that the provider does not have a reasonable opportunity to record such details of the complaint as may be prescribed in relation to reportable complaints.
2.14 ‘Upheld’ means that a complaint has been finalised in such a manner that the complainant has explicitly accepted that the matter is fully resolved or that it is reasonable for us to assume that the outcome has been accepted.

3. OUR DUTIES
In alignment with the Financial Advisory and Intermediary Services Act 37 of 2002 (“FAIS Act”), the FAIS Codes, and the Office of Ombud for Financial Services Providers, we commit to the following:
3.1 Keeping records of complaints for a duration of 5 years;
3.2 Addressing client complaints promptly and fairly; and
3.3 Taking necessary steps to investigate and respond to these complaints in a timely manner.

4. TYPES OF FORMAL COMPLAINTS
Formal Complaints refer to expressions of dissatisfaction regarding a product, service, or experience, shared through the various avenues listed below. These complaints can be directed at the business and/or individuals, and often seek resolution, acknowledgment, or simply to raise awareness about an issue. Issues may involve various topics, such as customer service, product quality, privacy concerns, or content moderation.
Social Media Complaints – Trustpilot, Facebook, Hellopeter, Google review, etc.
Complaints Mailbox
FAIS Ombudsman Complaints [[email protected]]
FSCA Complaints [[email protected]]

5.  COMPLAINTS PROCEDURE
5.1 Step 1: Making a Complaint
Social Media Complaints
Lodge your complaint in writing on the applicable social media platform.
Complaints Mailbox
Lodge your complaint in writing to our Complaints Department by sending an email to [email protected].FAIS Ombudsman Complaints
Lodge your complaint in writing to the FAIS Ombudsman by sending an email to [email protected].
FSCA Complaints
Lodge your complaint in writing to the FSCA by sending an email to [email protected] / [email protected].
What needs to be included in your complaint?
When submitting your complaint, please ensure that it includes all pertinent information. This should encompass your trading account number, a comprehensive account of the relevant facts, specific dates associated with the issue, and any supporting documentation that may aid in the investigation of your complaint.
5.2 Step 2: Receipt of the Complaint
Once your Complaint is received, the Complaints Department will acknowledge receipt via email within 24 hours. The acknowledgement email will contain:
Your Complaints Reference Number;
This Complaints Policy which outlines everything you need to know about the complaints handling process;
A request for additional information required from you, if any;
Contact details of the persons assisting you with your Complaint;
Expected turnaround times to finalise the matter (30 Business days); and
Any other relevant information that may facilitate the efficient and timely resolution of your complaint.
5.3 Step 3: Investigation of the Complaints
Our Complaints Department will conduct a thorough and systematic examination of the issues raised by the Complainant. This process typically involves gathering relevant information, reviewing documentation, and analysing the facts surrounding the complaint. The goal is to determine the validity of the claims, identify any potential breaches of policy or procedure, and assess the impact of the issue on the Complainant and the business. The investigation will also consider all pertinent laws, regulations, and guidelines, including Treating Customers Fairly (TCF) outcomes and the General Code of Conduct (GCOC). Ultimately, the investigation aims to reach a fair and informed resolution, ensuring accountability and improving practices where necessary.
5.4 Step 4: Complaint Outcome
Once the Complaints Department concludes their investigation, they will send the complainant a written Complaint Outcome Report, along with a Settlement Agreement, if applicable. This correspondence will be delivered as soon as feasible, depending on the complexity and nature of the complaint. The Complaints Department will endeavour to provide you with the Complaint Outcome Report within 30 business days (6 weeks) from date of receipt of your complaint. However, if additional time is needed due to complexities, we will notify you in writing about the extension.
5.5 Step 5(A): Satisfied with the Complaint Outcome
If you are satisfied with the Complaint Outcome, you must confirm this in writing by responding to the original complaint outcome email. You will also be required to submit the fully signed Settlement Agreement (if applicable) to proceed with the proposed resolution.
Furthermore, it is crucial that we receive any outstanding Know Your Customer (KYC) documentation in accordance with our standard KYC process.
Please be advised that the fully signed Settlement Agreement will confirm that the complaint has been resolved in full and finality, and that no further claims can be made regarding the matter.
As a result, the complaint will be considered closed once all of the aforementioned steps have been completed.
5.6 Step 5(B): Dissatisfied with the Complaint Outcome
If you are dissatisfied with the Complaint Outcome Report, you must notify the Complaints Department of your concerns and provide a detailed explanation of why you believe the outcome or offered resolution is unjust. The Complaints Department will then escalate proceed to reassess your complaint and seek an appropriate resolution.
If you are dissatisfied with the Complaint Outcome Report, you must promptly request an escalation to the business within the 6-week timeframe, providing reasons for your dissatisfaction. The business will then escalate your complaint and furnish you with final feedback. Should you find the outcome of the escalation satisfactory, we will proceed to implement that resolution.
If you remain unsatisfied with the outcome of the escalation, you have the option to approach the FAIS Ombudsman as an alternative course of action. It is important to note that, according to the FAIS Ombud Rules, the business has 6 weeks from the date of receipt to resolve your complaint. If we fail to resolve your complaint within this period, you may submit your complaint to the FAIS Ombudsman. Additionally, you must submit your complaint to the FAIS Ombudsman within 6 months of receiving the final outcome of your complaint.

 6. ALTERNATIVE DISPUTE RESOLUTION
The business should always be given the opportunity to resolve the Complaint. As a Financial Services Provider (FSP), we are legally required to resolve a complaint within 6 weeks from the date of receipt. However, our internal target is to resolve all Complaints within a maximum period of 30 business days. If a Complainant is not satisfied with the response from us (the final Complaint Outcome), they may follow any of the below procedures:
If the Complainant is not satisfied with the response received from the Complaints Department, the Complainant may appeal or request an escalation to management;
Submit a formal complaint to the FAIS Ombudsman Office within 6 months of receiving our final complaint outcome response;
Approach the small claims court; or
Consult an attorney to explore further legal action (Please note that any legal consultations or actions taken will be at your own expense, and the business will not be liable for any associated fees or costs).

7. FAIS OMBUDSMAN RULES ON PROCEEDINGS 
Details of the duties of the provider and rights of the complainant as set out in the rules applicable to the relevant Ombud.
Timeframes for the resolution of Complaints are in terms of the Rules on Proceedings of the Office of the Ombud for Financial Services Providers, 2002