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Complaints Policy
Complaints Policy

How we handle complaints fairly, efficiently and effectively.

Tracey Cresswell avatar
Written by Tracey Cresswell
Updated over a week ago


This policy is intended to ensure that we handle complaints fairly, efficiently and effectively. 

This policy provides guidance to our employees and people who wish to make a complaint to or about us, regarding our services, employees and complaint handling.


A complaint is considered as an expression of dissatisfaction made to or about us, our services, employees or the handling of a complaint where a response or resolution is expected or required. A complaint may be verbal or received in writing.

We are committed to managing people’s expectations, and will inform them as soon as possible, of the following:

  • the receipt of their complaint

  • the complaints process

  • the expected time frames for our actions

  • the progress of the complaint and reasons for any delay

  • their likely involvement in the process, and

  • the possible or likely outcome of their complaint.

We will advise people as soon as possible when we are unable to deal with any part of their complaint and provide advice about where such issues and/or complaints may be directed.

We will also advise people as soon as possible when we are unable to meet our time frames for responding to their complaint and the reason for our delay.

Objectivity and fairness

We will address each complaint with integrity and in a fair and objective manner. We will ensure that the person handling a complaint is different from any employee whose conduct or service is being complained about. 

Responding flexibly

Our employees are empowered to resolve complaints promptly and with as little formality as possible. We will adopt flexible approaches to service delivery and problem solving to enhance accessibility for people making complaints.

We will assess each complaint on its merits and involve people making complaints in the process as far as possible.

The contact details for submitting a complaint are:  

phone: +852 5801 4223



Complaints Procedure


When responding to complaints, employees should act in accordance with this complaint handling procedure.

The six key stages in our complaint management process are set out below.

Receipt of complaints

Unless the complaint has been resolved at the outset by the employee receiving the complaint, then it will be forwarded to the Compliance Officer. 

The Compliance Officer will record the complaint, its supporting information and assign a unique reference number to the complaint file.

The complaint record will contain:

the contact information of the person making a complaint

issues raised by the person making a complaint and the outcome/s they want

Acknowledgement of complaints

An acknowledgement of receipt of a complaint will be sent within 2 working days.

Consideration will be given to the most appropriate medium (e.g. email, letter) for communicating with the person making a complaint.

Initial assessment and Resolution

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.

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

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.

Where we consider that resolution requires more than 7 working days, we will advise you.

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

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, all complaints must be resolved within 3 weeks of receipt. 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. 

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 or appeal to the Financial Ombudsman.

If in the course of investigation, we will consider any applicable privacy obligations. 

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,

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.

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 oversight bodies).

Continuous improvement

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

support the appropriate resolution of complaints

implement best practices in complaint handling

implement appropriate changes arising out of our analysis of complaints data

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