1.“Centbee” means Centbee (Pty) Ltd with registration number 2017/014560/07 and registered address at Workshop 17 The Fire Station, 16 Baker Street, Rosebank, Johannesburg, 2196.
2.“Complaint” means an expression of dissatisfaction by a formal complainant, relating to a product or service provided or offered by Centbee, or to an agreement with the Centbee in respect of its products or services and indicating that: –
2.1 Centbee or its service provider has contravened or failed to comply with an agreement, a law, a rule, or a code of conduct which is binding on Centbee or to which it subscribes;
2.2 Centbee or its service providers’ maladministration or wilful or negligent action or failure to act, has caused the complainant harm, prejudice, distress, or substantial inconvenience; or
2.3 Centbee or its service provider has treated the complainant unfairly; regardless of whether such an expression of dissatisfaction is submitted together with or in relation to a customer query.
3.“Complainant” means a person who has submitted a specific and formal complaint to the financial services provider or its service provider and who: –
3.1 is a customer or prospective customer of Centbee concerned and has a direct interest in the agreement, product or service to which the complaint relates; or
3.2 has submitted the complaint on behalf of a person mentioned in clause 2.1 provided that a prospective customer will only be regarded as a complainant to the extent that the complaint relates to the prospective customer’s dissatisfaction in relation to the application, approach, solicitation or advertising or marketing material contemplated in the definition of “prospective customer”.
4. “Customer” of Centbee means any user, former user or beneficiary of one or more of the financial products or services provided by Centbee and their successors in title.
5. “Customer Query” means a request to Centbee by or on behalf of a customer or prospective customer for information regarding the financial products, services or related processes or to carry out a transaction or action in relation to any such product or service.
6. “FAIS” means the Financial Advisory and Intermediary Services Act No. 37 of 2002 (as amended), which was designed to protect customers of financial services providers; regulate the selling and advice-giving activities of FSPs; ensure that the consumers are provided with adequate information about the financial products they use and about the people and institutions who sell these financial products and establish a properly regulated financial services profession.
7. “FAIS Ombud” the FAIS Ombud deals with complaints submitted to the Office by a specific customer against a financial services provider.
8. “Financial Services Provider” means Centbee (Pty) Ltd with FSP No [to be confirmed] and place of business Workshop 17, 16 Baker Street, Rosebank, Johannesburg, 2196.
9. “Prospective customer” of Centbee means a person who has applied to or otherwise approached the financial services provider in relation to becoming a customer of the financial services provider, or a person who has been solicited by Centbee to become a customer or has received marketing or advertising material in relation to Centbee’s products or services.
10. “Routine Complaints” is where a customer submits an expression of dissatisfaction together with a customer query or relating to a customer query and which further can be resolved internally within a period of 15 (fifteen) days. Routine complaints are, therefore, customer queries that have been escalated by the customer previously, but now the customer has become dissatisfied with the process being followed to resolve the customer query.
11. “Serious Complaints” means complaints that contravene regulatory requirements and are likely or may already have caused a customer to suffer financial prejudice.
12. “Service provider” means another person with whom the financial services provider to whose products or services the complaint relates has an arrangement in relation to the marketing, distribution, administration, or provision of such products or services, regardless of whether or not such other person is the agent of the financial services provider.
13. “Resolved” in relation to a complaint means that the complaint has been finalized in such a manner that the complainant has explicitly accepted that the matter is fully resolved or that it is reasonable for the financial services provider to assume that the complainant has so accepted. A complaint should only be regarded as resolved once any and all undertakings made by the financial services provider to resolve the complaint have been met.
14. “TCF” Treating Customers Fairly is an outcomes-based regulatory and supervisory approach designed to ensure that specific, clearly articulated fairness outcomes for financial services customers are delivered by regulated financial service providers (FSPs). FSPs are expected to demonstrate that they deliver the required 6 TCF Outcomes to their customers throughout the product life cycle, from product design and promotion, through advice and servicing, to complaints and claims handling – and throughout the product value chain.
1.1 As a customer or prospective customer, if you have a complaint against Centbee, it must be submitted to us in writing. It can be submitted either by hand or email at the contact details that appear in this document.
1.2 You should provide sufficient detail of the complaint.
1.3 The complainant must include their full name, identity number and cell phone number for identifying purposes.
1.4 We will keep a record of the complaint and maintain such record for 5 (five) years as required by legislation.
2.1 Once your complaint has been received, it will be allocated to and dealt with by adequately trained staff.
2.2 The person responsible for your complaint will furnish you with his/her contact details and the reference number of your complaint (if applicable).
2.3 The Key Individual will have oversight over the complaints allocated to various personnel, and you may direct any queries to the Key Individual whose details are recorded in this document.
3.1 We will ensure that all potential issues are captured and classified for escalation, review and action as required.
3.2 Any complaint, issue or negative customer interaction must be reduced to writing and must be logged and classified for action.
3.3 A third party acting on behalf of a complainant must deliver a certified or original consent or power of attorney to act on behalf of a complainant. Should such a third party fail to deliver consent or power of attorney, no further dealings will be pursued with such third party until the proper authority is obtained. The complaint will, however, be taken up directly with the complainant on whose behalf the complaint is made.
3.4 All complaints must be formally logged using the following system:
The process adopted to log complaints, whether manual or via a computer database system
1. All formal complaints must be submitted in writing and must be emailed to firstname.lastname@example.org; or delivered by hand to Centbee’s offices located at Workshop 17 The Fire Station, 16 Baker Street, Rosebank, Johannesburg, 2191.
2. Complaints must include the complainants full name, identity number and cell phone number.
3. Upon receipt of the complaint, the Complaints Manager will review the complaint and acknowledge receipt of the complaint, by way of a formal letter as attached to the end of this document marked as annexure A, via email within 48 (forty-eight) hours of receiving the complaint. This letter will contain a complaint reference number which should be used in all correspondence.
4. Within 72 (seventy-two) hours, the details of the individual handling the complaint will be sent to the complainant.
5. The complaint will be classified according to a risk rating as described below, and the complainant will further be informed of the expected turnaround time to resolve the complaint based on the risk level.
6. The complaint will be investigated and, if possible, resolved.
7. Should the outcome of the complaint be unfavourable towards the complainant, a formal letter, as attached to the end of this document marked as annexure B, will be sent to the complainant via email indicating the unfavourable outcome and providing the complainant with the details of the FAIS ombudsman should the complainant be unsatisfied.
8. However, should the outcome be favourable, a formal letter, as attached to the end of this document marked as annexure C, will be sent via email to the complainant explaining that the complaint has been resolved successfully and in the client’s favour.
9. A follow up email will be sent to the customer to confirm they are satisfied with how the complaint has been handled.
10. All complaints will be reviewed monthly to better align this policy with the complaints as received from time to time.
All complaints will be prioritized as follows:
3.5.1 Risk 1 – Routine complaints, potential low business impact. This requires a response to the customer within 15 working days.
22.214.171.124 Routine complaints have the potential of becoming serious or official complaints should they be disregarded or ignored by a financial services provider.
126.96.36.199 The staff member logging the complaint should review the complaint and its priority with the Key Individual before proceeding to the next step.
188.8.131.52 The Key Individual will decide on the appropriate person(s) to carry out subsequent steps, including the investigation.
3.5.2 Risk 2 – Urgent, serious business impact. This requires a response to the customer within 5-10 working days.
184.108.40.206 Serious complaints are complaints logged on media platforms, received from legal advisors or immediately evidence contravention of legislation requirements such as failure to conduct a proper needs analysis.
220.127.116.11These complaints from the outset may cause reputational harm to a financial services provider and/or may cause financial loss to a customer.
18.104.22.168 These complaints should ideally be handled by the Key Individual or a suitable senior person delegated to the task by the Key Individual.
22.214.171.124 Complaints from third parties and/or legal advisors will be responded to within 24 hours, acknowledging receipt of the complaint and further requesting authority to act on the complainants’ behalf, such as a power of attorney or consent by the complainant to deal with the complaint on the complainant’s behalf.
126.96.36.199 No information will be divulged to a third party who does not have the proper authority to act on a complainant’s behalf.
3.6.1 Complaints will be categorised according to their nature, e.g. service, product related, features, performance, advice given, etc.
3.6.2 These categories are then narrowed down to the impact on customers. The impact of the complaint is measured by further categorising it according to the following TCF Outcomes:
188.8.131.52 TCF Outcome 2 – These are complaints relating to the design of a product or service. The categories which affect TCF outcome two would be product features and charges.
184.108.40.206 TCF Outcome 3 – These complaints relate to unsuitable or inaccurate, misleading, confusing or unclear information provided to a customer throughout the life cycle of a product. This could vary from advice, product information, the information provided in advertising or marketing material about a product or service rendered etc. These disclosures would include the conflict of interest disclosures required by the General Code of Conduct of FAIS (Code), Section 4 and 5 of the Code or any other disclosure requirements in terms of the Code or any other legislation.
220.127.116.11 TCF Outcome 4 – These are complaints which relate to the advice given to a customer by an advisor which was misleading, inappropriate and/or tainted with conflicts of interest which was not disclosed. Inappropriate advice given as a result of lack of knowledge, skill or experience on the part of the advisor of the product or service being rendered would also be included here. The failure to conduct a needs analysis and to consider the customer’s financial position, goals or life stage would also amount to a contravention of suitable advice requirements and any complaint in association herewith would fall into this category.
18.104.22.168 TCF Outcome 5 – Complaints in this category pertain to product performance and service related issues. This would include complaints relating to a customer’s disappointment with limitations in a product or service performance of which they were unaware as well as the inability of a product to meet a customer’s expectations. Complaints related to a product supplier’s exercise of a right to terminate a product or amend its terms, would also be included in this category.
22.214.171.124 TCF Outcome 6 – These complaints relate to product accessibility, changes or switches, complaints relating to complaints handling and complaints relating to claims would be categorised here.
3.6.3 Other categories may be developed which are appropriate to this outcome and will be incorporated into the policy and attached complaint register.
4.1 All complaints must be acknowledged within 24 hours of receipt.
4.2 Where an acknowledgement is made telephonically it will be followed up with a written response either by SMS or email.
4.3 A complaint reference number will be despatched to the complainant on acknowledgement of the complaint.
4.4 The details of the person allocated to the complaint will be despatched to the complainant within 48 hours from receipt.
5.1 The investigation will be driven by analysing the root cause of the complaint to enable the complaint to be appropriately dealt with and to avoid, if possible, its reoccurrence.
5.2 This may require that both internal and external key facts are identified and clarified.
5.3 Should a complaint relate to product features or services handled solely by a product supplier, this matter will be escalated and appropriately dealt with in conjunction with the product supplier, ensuring that the matter is resolved to the satisfaction of the complainant.
5.4 All areas of interaction and communication will be documented, and where appropriate, consent obtained from the complainant to ensure that no personal information is divulged or processed without the complainant’s knowledge or consent.
5.5 During the investigation process, the complainant will be kept appropriately updated of the progress of the investigation.