Complaints Handling Policy (Australia)

Policy/Procedure

  1. Balance is committed to maintaining adequate resources for the selection, support and training of the personnel involved in dealing with complaints. The staff who are nominated to handle the complaints will be sufficiently trained and competent.
  2. All complaints (either in writing, by email or verbal) must be referred to the Compliance Officer who will arrange for an appropriate acknowledgement to be sent to the complainant generally within 24 and no longer than 48 hours.
  3. The Complaints Register must be updated and include the following details:
    • the name, address and telephone number of each complainant;
    • the date and time each complaint was received;
    • the employee to who the complainant first spoke and such employee’s record of the conversation;
    • all correspondence concerning the complaint;
    • a report detailing how each complaint was resolved; and
    • any other information the Compliance Officer deems appropriate.
  4. The validity of the complaint is investigated by the Compliance Officer with the relevant Officer and/or external service provider.
  5. Subject to the result of this investigation, an appropriate full response is to be sent to the complainant within 14 days of receipt. Should this not be possible, the complainant must be advised of progress and the timetable for a complete response within 14 days of receipt of the complaint. For retail clients, the final response should also contain details of the fact that if the complainant is not satisfied with the response, they have access to at no cost:
    Australian Financial Complaints Authority
    GPO Box 3
    Melbourne, VIC 3001
    Telephone: 1800 931 678
    Email: info@afc.org.au
    an external complaint resolution scheme of which Balance is a member.
    The Compliance Officer will be the person primarily responsible for dealing with the Australian Financial Complaints Authority.
  6. Should the basis of the complaint be valid, the relevant policy, procedure, agreement or other document should be reviewed, and necessary changes made to eliminate the cause of the complaint occurring again.
  7. The Compliance Officer will determine who the most appropriate person to sign the response is.
  8. Should the complaint be about the Compliance Officer then a Director will undertake their role in this Procedure.
  9. It is the annual responsibility of the Compliance Officer to review all client complaints received by Balance, if any and:
    • prepare a report summarising the review of client complaints received by Balance, if any, and their disposition;
    • detail the results of any inspection, examination, or investigation by Balance or a governmental or regulatory agency, if any, of any suspected violation of applicable Australian laws or ASIC policies; and
    • propose any improvements to the Partnership that the Compliance Officer believes to be appropriate.
  10. All complaints will be reported to the Partners on a quarterly basis.
  11. Any information collected by Balance in its attempt to resolve the complaint will be handled in accordance with Balance’s Privacy Policy.
  12. This procedure will be reviewed on an annual basis by the Compliance Officer.

Remedies

  1. Balance will provide remedies in respect of complaints by taking into account what is fair and reasonable in the circumstances, legal obligations and good industry practice. The remedy will be chosen after considering all aspects of the complaint. These may include compensation, unwinding an investment, an apology or goodwill gesture.
  2. In the event that a complaint is due to the error of Balance or one of its officers, Balance will take immediate action to correct the situation which will include, where appropriate, ensuring that a client does not incur a financial loss as a direct result of the error.
  3. The complaints are classified and analysed to identify systemic problems and safeguard against recurring problems. Regular reviews of internal dispute resolution procedures will also be conducted every 2 years.

Responsible Officer

  1. The responsible officer for all internal and external complaints is the Compliance Officer.

Internal complaints

  1. Where a complaint originates from an internal source, all procedures detailed in this document apply to the extent relevant. However, where an internal complainant is not satisfied with the investigation response received from the Compliance Officer or other relevant Officer of Balance (following the requirements of paragraph 10), the complaint will, at the discretion of the Compliance Officer, be referred to an external service provider/advisor for resolution.
  2. The following is a pro forma Complaints Register:
1. Complaint Number(e.g. 2021-01)
2. Name of Complainant
3. Complainant’s Address and Telephone Number
4. Date and Time Received
5. Employee who took the Complaint and Summary of Complaint
6. Date Reported to the Partnership
7. Date of Acknowledgment
8. Officer/Service Provider Subject of Complaint
9. Relevant Policy/Procedure, Compliance Plan Item
10. Date of Response
11. Summary of Response
12. Changes Required to Policies/Procedures, Compliance Plan