Complaints Handling Policy

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1. Purpose

This Policy sets how [Organisation] receives, records, resolves and learns from complaints. It ensures that:

2. Scope and application

This Policy applies to all complaints made to or about [Organisation], its staff, its authorised representatives and credit representatives, and its service providers who handle complaints for us, through any channel. It applies to all employees, contractors, directors and representatives.

3. Key definitions

4. Principles

1. Complaints are welcome. Everyone has a right to complain. Complaints are valuable information about our products, services and controls (RG 271.15, RG 271.129).
2. Easy and free. Complaints can be made in any reasonable way, and the process is free (RG 271.136, RG 271.141).
3. Recognise, never reclassify. If it meets the definition, it is a complaint. It is never recorded as 'feedback' or an 'enquiry' because it was verbal, lacked merit or was settled with a goodwill payment (RG 271.31).
4. Fair and objective. Each complaint is considered on its merits, without actual or perceived bias, and wherever possible by someone not involved in the matter (RG 271.167).
5. Timely. We aim to resolve complaints at the first point of contact and always within the maximum IDR timeframes (RG 271.104, RG 271.163).
6. Clear reasons. Complainants receive enough detail to understand our decision and decide whether to go to AFCA (RG 271.54).
7. No detriment. No one is disadvantaged for complaining, and adverse action is postponed where appropriate while a complaint is open (RG 271.171).
8. Learn and fix. Complaints are analysed for systemic issues, possible breaches and root causes, which are escalated and fixed (RG 271.120).

5. Regulatory and standards framework

6. Three lines of accountability

7. Roles and responsibilities

8. Recognising a complaint

It is the complainant's expression of dissatisfaction that starts our obligations, not the referral of a matter to a complaints team (RG 271.35, RG 271.106). Staff must be proactive in recognising complaints (RG 271.30).

8.1 These are complaints (RG 271.32)

• posts that meet the definition on a social media channel or account owned or controlled by [Organisation], where the author is identifiable and contactable (protect the person's privacy when responding);
• an objection to a proposed decision about how and to whom to pay a superannuation death benefit;
• complaints about a matter that is the subject of an existing remediation program, or about the remediation program itself (for example delays or lack of communication); and
• complaints about the handling of an insurance claim (for example excessive delays or unreasonable information requests).

8.2 These are not complaints, unless they raise a complaint (RG 271.33)

• employment-related complaints by our staff (handled under [HR policies]);
• comments where no response is expected, such as survey feedback or simple reports (for example that an ATM is damaged);
• hardship notices or requests to postpone enforcement proceedings, unless the customer raises issues that meet the definition of complaint; and
• reports of unauthorised transactions under the ePayments Code and chargeback disputes, unless the customer raises separate issues or is dissatisfied with the outcome or handling.

9. Making a complaint and accessibility

• Complaints can be made by phone ([toll-free or local call number]), email, letter, online form, social media, in person, and through representatives. Complaints do not need to be in writing (RG 271.136–RG 271.137).
• The IDR process must be easy to understand and use, including for people with disability or language difficulties (RG 271.134). [Organisation] offers interpreters, the National Relay Service, accessible formats and adjustable website text (RG 271.135).
• The IDR process, and material explaining it, are free (RG 271.141).
• Complainants may use a representative, such as a financial counsellor, lawyer, family member, friend or member of parliament. Once told of an authorised representative, we deal with the representative and do not contact the complainant directly, except in the circumstances in RG 271.139.
• Information about how to complain and about AFCA is in our Financial Services Guide, Product Disclosure Statements, Credit Guide, periodic statements and National Credit Code notices, on our website, and in welcome packs (RG 271.113–RG 271.114, RG 271.132).

10. Customers who need additional assistance

• Staff are trained to identify, support and assist people who need help to make a complaint (RG 271.138), and to recognise signs of vulnerability.
• Complaints are triaged on receipt. They are prioritised where the complainant is experiencing family or domestic violence or financial abuse, has a serious or terminal illness, or where delay could affect their basic living conditions (RG 271.158).
• We adapt how we communicate (channel, timing, format, interpreter, trusted contact) and record the adjustments with the person's consent.
• We take care not to disclose information that could put a person at risk, for example to a joint account holder who is a perpetrator of abuse.
• Where a complaint involves financial hardship, we tell the complainant about our hardship assistance and refer them to free financial counselling (for example the National Debt Helpline).

11. Handling a complaint

11.1 Unreasonable complainant conduct

Every complaint is handled equitably, including those from people whose behaviour is unreasonable or challenging. The [Unreasonable Complainant Conduct Procedure] sets how we manage such conduct while protecting staff (RG 271.152, RG 271.170). Restrictions are approved by [the Complaints Manager], recorded with reasons, and never prevent access to AFCA.

12. Maximum IDR timeframes

These are the maximum timeframes in RG 271 Table 2 (enforceable: RG 271.56–RG 271.60). [Organisation]'s internal targets are shorter. Time runs in calendar days from the day after the complaint is received (RG 271.56 note).

12.1 Delays

An IDR response may be given after the maximum timeframe only if there was no reasonable opportunity to respond in time because the complaint is particularly complex or circumstances beyond our control are causing delay, and we gave the complainant an IDR delay notification before the timeframe expired (RG 271.64–RG 271.66). Examples of complexity and of circumstances beyond our control are in RG 271.67–RG 271.68. Workload or resourcing shortfalls are not acceptable reasons. Delay notifications are approved by [the Complaints Manager] and tracked; the complainant can still go to AFCA at any time.

12.2 Complaints closed within five business days

A written IDR response is not needed if, by the end of the fifth business day after receipt, the complaint has been resolved to the complainant's satisfaction, or we have given an explanation or apology where no further action can reasonably be taken (RG 271.71–RG 271.74). A written IDR response is still required if the complainant asks for one; the complaint is about hardship, a declined insurance claim or the value of an insurance claim; or it relates to a decision (or failure to decide) of a superannuation trustee (RG 271.75). These complaints are still recorded and reported.

12.3 Multi-tier processes and customer advocates

• The maximum timeframes apply to the whole IDR process, including internal escalations and reviews (RG 271.102, RG 271.105).
• A customer advocate review may be offered after an IDR response, as an alternative to AFCA, never as a mandatory step. The total time (IDR plus customer advocate) must not exceed the maximum timeframe, with time stopping between the IDR response and the complainant's request for review (RG 271.109–RG 271.110).

13. The IDR response

The IDR response is in writing and must (RG 271.53–RG 271.55):

14. AFCA

• [Organisation] is a member of AFCA, complies with the AFCA Rules and cooperates with AFCA, including on information requests and determinations.
• When a complaint is unresolved at IDR, or not resolved within the maximum timeframe, we tell the complainant of their right to go to AFCA and how to contact AFCA (RG 271.111–RG 271.112).
• The AFCA Rules set time limits for lodging a complaint with AFCA, which run from the date of the IDR response and from when the complainant became aware of their loss (rule B.4.3). Check the current AFCA Rules for the limits and exceptions. IDR responses are dated and kept.
• Complaints referred back to IDR by AFCA are handled within AFCA's refer-back timeframes. The RG 271 delay exceptions do not extend those timeframes (RG 271.66 note 3).
• We may refer an unresolved complaint directly to AFCA only with the complainant's consent (RG 271.115–RG 271.116).
• AFCA must report systemic issues it identifies to ASIC, APRA or the ATO within 15 calendar days (RG 271.123). AFCA systemic issue referrals and adverse determinations are escalated to [Compliance] and the accountable executive on receipt.
• AFCA complaint volumes, outcomes and determinations are analysed alongside IDR data for root causes.

15. Systemic issues

Complaints are a key risk indicator for systemic issues (RG 271.117). [Organisation] must (RG 271.118–RG 271.120, enforceable):

16. Links to breach reporting, incidents and remediation

• Complaint data is analysed regularly to identify matters that may need to be reported to ASIC under s912D (RG 271.181(c)). Any complaint that may involve a breach of a legal or regulatory obligation is referred to [Compliance] the same day under the RiskFA Compliance and Breach Reporting Policy.
• Receiving a complaint, and short preliminary inquiries to resolve it, are not usually a reportable investigation. But once steps are taken to find out whether a significant breach has occurred, an investigation has started, and it must be reported to ASIC if it continues for more than 60 days (RG 78.55, RG 78 Example 6(d)).
• Breaches of the enforceable paragraphs of RG 271 are breaches of a core obligation. A single breach is not deemed significant merely because the IDR requirements are civil penalty provisions (ASIC Instrument 2024/620 s5; RG 78.37(c)), but it must still be checked against the other deeming categories and the significance factors (RG 78.40–RG 78.41), and repeated or systemic IDR failures may be significant and reportable (RG 78.37(c), Example 4(d)). IDR timeliness and content failures are recorded as breaches.
• Complaints about an existing remediation program are complaints and are handled under this Policy (RG 271.32(c)). Remediation programs are run under the RiskFA Customer Remediation Policy and RG 277.
• Complaints that reveal incidents are recorded under the RiskFA Incident & Issues Management Standard, which requires complaints data to be reviewed at least [monthly] for incidents and systemic issues (section 14 of that Standard).
• Disclosures that may qualify for whistleblower protection are handled under the RiskFA Whistleblower Policy and are not recorded in a way that identifies the discloser.

17. Records and the complaint management system

• All complaints are recorded in the [complaint management system], which tracks the progress of each complaint (RG 271.179–RG 271.180). Appendix B lists the minimum fields, which include the data ASIC requires for IDR data reporting.
• Records are accurate, complete and kept up to date, with every change dated. Complaints resolved at first contact are recorded too.
• Complaint records are handled in line with the Privacy Act and our [Privacy Policy] (RG 271.169).
• Records, including IDR responses and delay notifications, are kept for at least [7 years], or longer where the law requires.
• Complaint data quality is checked [monthly] before internal and ASIC reporting.

18. IDR data reporting to ASIC

• AFS licensees that provide financial services to retail clients, credit licensees, unlicensed product issuers and secondary sellers covered by s1017G(1)(d), superannuation trustees and RSA providers must report IDR data to ASIC for each six-month reporting period ending 30 June and 31 December (ASIC Corporations (Internal Dispute Resolution Data Reporting) Instrument 2022/205 ss 4–6). This is separate from the RG 271 requirements (RG 78.13(d), RG 78.14).
• Reports are lodged through the ASIC Regulatory Portal, in CSV format as set out in ASIC's IDR data reporting handbook (the version named in the instrument), within two months after the end of each reporting period (Instrument 2022/205 s5(1)–(2)).
• If there were no reportable complaints in a period, a nil confirmation is lodged through the Portal within the same two months (s5(3)–(4)).
• As at October 2026, Instrument 2022/205 is due to be repealed on 1 April 2027 (s8). Compliance tracks its replacement as a regulatory change.
• Giving ASIC IDR information is a core obligation for breach reporting purposes (RG 78.148(a)(xi), RG 78.149(a)(ix)). A late or materially inaccurate IDR data report is recorded as a breach and assessed.
• ASIC publishes IDR data. The [Complaints Manager] reviews our published data against peers.
• The IDR report is reviewed by [Compliance] and approved by the [accountable executive] before lodgement.

19. Resourcing, delegations and training

• The IDR process is resourced to operate fairly, effectively and efficiently, including for spikes in volume, and resourcing is reviewed at least [quarterly] (RG 271.142–RG 271.143, RG 271.153).
• Complaint handlers have authority to resolve complaints, and financial delegations allow fair and efficient resolution: [$X] for frontline staff, [$Y] for complaint handlers, [$Z] for the Complaints Manager (RG 271.146–RG 271.147).
• All staff are trained at induction and [annually] to recognise and record complaints. Complaint handlers are trained in RG 271, consumer protection laws, AFCA approaches, codes, our products, assisting people who need additional assistance, unreasonable conduct, written communication and systemic issue identification (RG 271.148–RG 271.150).
• Complaint handlers have the tools they need (scripts, templates, systems) and access to support such as debriefing and employee assistance (RG 271.151–RG 271.152).
• Performance measures and incentives for complaint staff reward fair outcomes and quality, never low complaint numbers or low payments.

20. Quality assurance, compliance audits and review

• Quality assurance: [Customer Resolution QA] reviews a sample of at least [X%] of complaints each [month] for correct recording, clear and consumer-focused communication, fair outcomes, and AFCA information (RG 271.188).
• Compliance audits: [Compliance] audits compliance with RG 271 and this Policy at least [annually] (RG 271.189–RG 271.190). Non-compliance leads to feedback, retraining, supervision and, where appropriate, rectification for affected complainants.
• Review program: the IDR process is reviewed at least every [2 years] by [Internal Audit / an independent reviewer] for suitability and effectiveness, prompt identification of systemic issues, the effectiveness of remedial action, improvements needed, and customer satisfaction (RG 271.193–RG 271.196). Actions are tracked to completion.
• Customer advocate recommendations, where applicable, are considered through a transparent process (RG 271.191–RG 271.192).

21. Public complaints policy

[Organisation] publishes a plain-language complaints policy on its website in an accessible location, available in other formats and languages and in hard copy on request, free of charge (RG 271.172, RG 271.174). It explains (RG 271.173):

22. Internal reporting, measures and key risk indicators

Complaints reports go to senior management [monthly] and to the [Board Risk Committee] [quarterly] (RG 271.183). Reports to the Board and executive committees must include metrics and analysis of complaints, including systemic issues (RG 271.119). They cover at least the items in RG 271.184:

23. Related documents

• [Public Complaints Policy], [Internal Complaint Management Procedure], [Hardship Procedure] and [Unreasonable Complainant Conduct Procedure]
• the RiskFA Compliance and Breach Reporting Policy, [Incident & Issues Management Standard] and the RiskFA Customer Remediation Policy
• [Privacy Policy], the RiskFA Whistleblower Policy and [Vulnerable Customers Policy]
• ASIC: RG 271 Internal dispute resolution, RG 267 Oversight of the Australian Financial Complaints Authority, RG 78 Breach reporting by AFS licensees and credit licensees, RG 277 Consumer remediation, IDR data reporting handbook
• AFCA: Complaint Resolution Scheme Rules and Operational Guidelines
• Standards: AS 10002:2022 Guidelines for complaint management in organizations

Appendix A. IDR response letter content checklist

Appendix B. Complaint record fields

Appendix C. Systemic issue escalation template