a) This document
represents our policy towards complaints, how a consumer can make them and how
as a company we handle them.
b) This policy and
procedure have been created to meet general standards and requirements and
complies with standard complaint handling procedures, including the Financial
Ombudsman Service (FOS) and FCA regulations such as CONC and DISP.
c) We take our
responsibilities seriously, in addition to the legal and regulatory
requirements we have as a financial firm.
d) We are committed to
ensuring the fair treatment of our consumers and ensuring they face no post
sale barriers with our service, and we have effective and transparent
procedures in place.
e) As a business we
ensure that complaints can be made using any reasonable means and recognise
complaints require a resolution.
As per FCA material, they define a complaint as the
‘Any oral or written expression of dissatisfaction, whether
justified or not, from, or on behalf of, a person about the provision of, or
failure to provide, a financial service, claims management service or a redress
determination, which alleges that the complainant has suffered (or may suffer)
financial loss, material distress or material inconvenience.’
3. Customer Complaints Procedure
‘Our aim is always to provide an exceptionally high level
of service to all of our customers. Where customers are unsatisfied, it’s
important to us that this is dealt with objectively, fairly and as quickly as
we are able to.
The following procedure explains how we deal with
complaints, our commitments to you and what action to take if you think your
complaint has not been resolved to your satisfaction.
If you have a complaint about any aspect of our service,
then we would like to hear from you. Please use the below details to let us
T: 0330 202 1201
P: 4th Floor,
Kingsgate House, Wellington Road North, Stockport, SK4 1LW
We kindly ask, so we can look into your complaint as
quickly as possible. You include as much detail as you can, however if we are
missing anything we will be in touch. We will aim to come back to you within 48
working hours of receiving your complaint.
If we are able to investigate and resolve your complaint
within 3 days, you will receive a summary resolution response from ourselves,
which will detail our outcome and findings.
In the event our investigations take longer than 3 days, we
will issue you a Final Response within the 8-week timescale. Whilst we try to
close any complaint before this 8-week time frame, we do need to make you aware
we do have this time. Our final response will include detailed information of
your complaint, our investigation, and the resolution we have come to. If you
are not satisfied with our Final Response or the handling of your complaint
within the 8-week time frame, you can contact the Financial Ombudsman service
using the details below. You must do this within six months of our final
T: 0800 023 4567
P: Exchange Tower, Harbour Exchange, London, E14 9SR
4. Processes and Responsibilities
a) As per DISP 1.9 and to
ensure that we handle our complaints efficiently and effectively, any correspondence
or notes from phone communication will be documented on our Autoconvert system.
b) This will allow the
complaints handler to review the whole complaint and refer back to any point in
the investigation if they are required to do so.
c) Any documentation
received regarding the complaint will also be uploaded to the application.
d) All records of
complaints will be kept as per our retention periods, only employees that
require access to customer complaint notes will be granted this information.
e) We aim to resolve all
complaints as soon as possible to minimise the number of open complaints
a) Staff will receive
complaints training within their initial induction and at least once a year.
b) Training will ensure
our team understands the processes that we have in place and the regulatory
importance of following these processes.
c) At any time, staff
have the opportunity to request further training on any aspect of our business.
Customers Fairly (TCF)
a) As a company, we
ensure that we follow all regulatory guidelines, including treating customers
b) When it comes to
complaints, we guarantee that our customers will not face any post sale
c) Our staff are aware
that they need to assist customers as much as possible when they wish to make a
complaint, and they should not receive a different service to any other
d) As per DISP 1.3.2
customers are made aware they can make a complaint verbally or in writing and
these contact details are provided in our complaint’s procedure for ease for
e) We will ensure that
our complaints procedure is in a clear location so our consumers can access it
with ease. To ensure we are in compliance with DISP 1.2, our complaints
procedure is clearly listed on our website and a copy will be sent via
f) Specifically, to meet
DISP 1.2, our complaints procedure will also detail contact details for the
g) Customers will have
their expectations managed, and staff will explain the complaints process so a
customer can understand the next steps.
h) As per DISP 1.4.1, we
will thoroughly investigate any complaint competently, diligently and
impartially, ensuring that any evidence obtained is saved to the customers
application for record.
i) In line with 1.4.2 all
factors of the customer journey and outcome will be considered in our
j) We will keep in
constant communication with all parties, including our finance partners,
ensuring we keep in touch at least once a week whilst investigations are taking
k) We will assess fairly,
consistently, and promptly
● the subject matter of
● whether the complaint
should be upheld.
● what remedial action
or redress (or both) may be appropriate.
● if appropriate,
whether it has reasonable grounds to be satisfied that another respondent may be
solely or jointly responsible for the matter alleged in the complaint.
l) All communication
received will be acknowledged within 48 hours, as per DISP 1.6.1.
m) If a customer makes a
complaint about a specific member of the team, that employee will not have any
involvement in handling the customer’s complaint.
n) Customers will never
be charged for making a complaint, no matter what method of communication they
use (DISP 1.3.1).
o) Where a customer has
referred a complaint to the FOS, we will fully comply with any further
investigations and comply promptly with any settlements or rewards in line with
p) At any point in our
trading future, we are required to publish our complaints data due to the
number of complaints received, we will ensure this is easily available to our
customers and contains all the required information and in the time limits
required. We will inform the FCA in writing as and when this has been
q) As per DISP 1.8,
should we receive a complaint which is outside of the time limit (as detailed
in DISP 2.8) for referral to the FOS and we reject the complaint, we will
provide a full explanation of this to the complainant.
r) For reference these
time limits are as follows –
● more than six months after the date on which we sent our
final response, redress determination or summary resolution communication
● More than six years after the event complained of
● three years from the date on which the complainant became
aware (or ought reasonably to have become aware) that they had cause for
a) In line with DISP 1.5
we have put in the following process should we resolve the complaint within 3
working business days.
b) Once resolved, we will
send the customer a Summary Resolution using our templates.
c) This will include
details of how the customer can refer their complaint to FOS should they wish
to if they are not satisfied with our response, the time limits able to do this
and that we consider the complaint closed.
d) Depending on the
customer’s circumstance, and if it is deemed easier or preferred for the
customer, we may communicate this resolution via other methods such as
a) Compensation or
redress will be decided on an individual basis and detailed to the customer in
our final communication.
b) Management will take
into account all aspects of the complaint and any suffering caused to the
customer and offer compensation based on these aspects and per
c) Where Compensation and
redress is considered or decided, we will ensure all factors have been taken
into account including all evidence obtained and regulation set out by the FCA
d) Compensation or
redress may also involve agreements with lenders or suppliers, to determine an
overall decision, and where application all communication and decision will be
e) As with all complaint
records, redress and compensation will be recorded so we are able to report
amounts to the regulator.
- Point of
a) As per DISP 1.3.7, the
firm has appointed Stephen to currently handle all complaints and SQ issues.
b) We will ensure this
information remains clear and up to date on our FCA register.
c) As the firm grows and
moves forward, we will consistently review Stephen’s ability to carry out this
responsibility and regularly review their knowledge and training to ensure they
are competent in their responsibilities.
d) We will request an
email or detailed description over the phone to handle the complaint
e) They will then liaise
with the customer and any third parties as required (and in line with DISP
1.7.1) and issue a final response letter or summary resolution.
f) If in the event or
circumstance we are required to forward the complaint, we will do so promptly
and inform the customer that we have done so.
g) We are committed to
ensuring that we are in control of all complaints and complete them as soon as
h) Stephen will ensure
all complaints are updated on the complaints log, system and compliance monitoring
i) Templates will be used
when liaising with customers for acknowledgement (including initial and holding
letters), Summary Resolution and Final Response Letters to ensure that the
customer receives information required in DISP such as (but not limited to) 1.6.1 and 1.6.2.
j) This will
a. Acceptance or
rejection of the complaint
b. Information on any
redress offered and agreed on
c. Information on how the
customer can contact FOS and the time limits applicable
d. FOS explanatory
k) If we cannot provide
the customer with a final response in 8 weeks, we will ensure a holding letter
is provided that will include:
a. Why we are unable to
b. A timeframe of when we
believe we will be able to
c. Informing they are
able to contact FOS and the contact details to do so
d. FOS explanatory
l) If we are able to
resolve the complaint before the 8-week period, the final response will be sent
as soon as possible.
m) All correspondence
with customers will be clear, fair and not misleading. Where information such
as FOS details is required to be prominent, this will be done so.
a) It is important that
we can differentiate between a complaint and an SQ issue.
b) Whilst they are
different, we do adopt the same principles, and try to assist our consumers
rectify any issues they have with their vehicle.
c) We provide this
service as an extension to our offerings in the hope we can make the consumer’s
journey as easy as possible.
d) We will assist
liaising with the dealer/lender, if necessary, to try to come to an arrangement
to provide our consumer with the vehicle they desire.
e) All SQ’s will be
documented on our complaints log for management information purposes, which
assists in providing additional information on dealerships and their
f) Root analysis may be
conducted on specific issues, which will be issued to the board of Directors
and used when completing Dealer Due Diligence.
g) To ensure we meet DISP
1.3.2A, we are committed to learning from all complaints and SQ issues
received, ensuring we are analysing any patterns produced or guidance
h) As per DISP 1.3.3 we
will ensure appropriate management controls are in place to identify and remedy
any recurring or systematic problems, both with regulated and SQ
i) The following
processes and training have been implemented to include:
a. How to identify a root
b. How to
c. to consider whether
any information could impact other aspects of our process and policies, and if
action is required
d. if action needs to be
taken to amend a certain process and implement a timeframe and actions as to
when and how this will be done
e. keeping records of all
changes and ensure version control rules are met
j) Should issues or
problems be identified and other customers who may not have come forward be (or
suspected to be impacted) we will take appropriate action to contact those
customers and if applicable, take steps to remedy the problem, obtain a
solution or calculate redress (as per DISP 1.3.6)
It is extremely important that this policy is
complied with to protect our consumers. As a company we will ensure that we
keep up to date with regulatory and legal requirements, and that our processes
and policies are updated accordingly to meet regulation (DISP, CONC, TCF)
We may conduct root analysis on our complaints to identify
any patterns that may potentially form, therefore limiting risk to our
All complaint information will be reported within our
RegData as per DISP 1.10 rules and guidance or upon request. We will ensure
that all information requested by the FCA including but not limited to total
amount, amount closed, amount open and redress paid, is accurate, honest, and
up to date as per the Reg Data system. We do not anticipate meeting the
500-complaint threshold in the near future but will continue to review
processes and implement necessary reporting requirements when required.
In the event a complaint identifies an area of
concern within our procedure, this will be assessed and rectified where
This policy will be reviewed on at least an annual basis
with any updates will be reissued on this policy.
All policy changes are approved by directors.