1     Policy

 1.1     To provide an environment where clients, customers, staff and third parties have the opportunity to raise any complaint concerns that they may have in relation to the service provided by SMS Finance; and to ensure that their compliant concerns are addressed in a fair, consistent, efficient and effective manner.

2     Purpose

2.1     This procedure is in place to ensure client, customer, third party, official and staff complaints are handled efficiently and effectively, so that:
2.1.1     Complaints are tracked and resolved;
2.1.2     Incidents are documented;
2.1.3     Preventative action is taken where applicable;
2.1.4     Changes are made to systems and procedures where required; and
2.1.5     Training issues are addressed.

3     Scope

3.1     This procedure covers client, customer, third party, official and staff complaints.

4     Department responsible for implementation

4.1     Compliance Department:

•    John McNamara complaints contact person.
•    Judy Gleeson Deputy Complaints contact person.

5     Definitions

5.1     A complaint is an expression of dissatisfaction raised by a customer, client, third party, official or member of staff, which relates to the service provided by SMS Finance. (i.e. the way the complainant has been directly or indirectly treated, or something we have/have not done).

6     General

6.1     SMS Finance is one of the largest finance broking firms in Queensland who arrange all forms of finance, acting for many small and large companies and individuals throughout Queensland, and we pride ourselves on our ethics and reputation.
6.2     It is of utmost importance to SMS Finance that we operate in a professional manner and within the requirements of the applicable legislation at all times. An effective Complaints Handling process is a material part of this objective.
6.3     Handling a difficult complainant and their complaint requires patience and skill to avoid an initial ‘negative’ situation becoming even more negative and degenerating into a dispute.
6.4     For this reason we have Complaints procedures to assist our customers, clients and staff in resolving any complaints they may have.
6.5    Employees are required to familiarise themselves with the company’s complaints procedures, and to raise any issues, concerns or questions with the complaints officer.
6.6     Whilst it is the company’s objective to provide an environment in which the need to complain is eliminated, the attitude of the company is to welcome complaints when we receive them.
6.7     Complaints provide us with the opportunity to resolve any misunderstandings in a manner that is fair to both SMS Finance and the complainant, and to implement procedures which will eliminate the source of the complaint and/or its recurrence.
6.8     Customers and clients who complain to us are giving us constructive feedback on how we can improve our business.
6.9     All complaints should be acted upon immediately to ensure that the complaint is resolved before it may unnecessarily escalate into a dispute.

7     Complaints from /clients / Customers

When complaints are received from customers or third parties;

7.1    Listen, record all details and determine what the complaint is about or what action the complainant wants taken.
7.2         Confirm the details received.
7.3     Ensure not to lay blame or cause further offence to the customer. Rather, empathise with this complainant in a courteous manner.
7.4        Resolve the complaint, if possible.

7.5    All complaints, resolved or unresolved are to be documented in the complaints register and a copy of the process given to John McNamara.

7.5         If the staff member receiving the call does not have the ability to
resolve the complaint immediately and to the satisfaction of the complainant, the complaint should be immediately referred to: John McNamara the Complaints contact person in the first instance and Judy Gleeson the Deputy Complaints contact person if John McNamara is unavailable.

7.6     An investigation will be undertaken and John McNamara will directly respond to the client upon completion of the investigation within 24 hours..

7.7    SMS Finance will provide written acknowledgment of receipt of the complaint, unless the complaint is otherwise resolved.

7.8    SMS Finance will provide a substantive response within 45 days of the complaint, if unable to provide a response within 45 days a written explanation as to why will be provided. Our written response to the client will be within the COSL guidelines as per the IDR procedures report.

7.9     Where the complainant is not satisfied in whole or in part with our response to their complaint, the complainant has the right to raise the complaint to the External Disputes Resolution Scheme (COSL ) of which SMS Finance is a member.
7.10     The contact details for (COSL) will be provided to the complainant by SMS Finance.

8     Complaints from Authorities/Governing Bodies or other Regulatory Bodies

8.1     These complaints are of a particularly litigious nature, whereby breaches of pertinent guidelines and acts (such as the Debt Collection Guidelines set by the Australian Competition and Consumer Commission, or the Privacy Act) may have occurred.
8.2     At no stage should any employee make official or unofficial commentary to a member or office bearer of a governing body, licensing authority, or other regulatory body in relation to the business or operations of SMS Finance – unless specifically authorised to do so.
8.3     Complaints or queries of this nature should be referred immediately to John McNamara.
8.4     Staff are required to request that complainants put the complaint in writing to John McNamara at the address provided below, stating:

“I am not authorised to make any comment or disclose information to assist you immediately with your request. Please submit your query in writing, addressed to the John McNamara. I am happy to provide you with the contact details.”

John McNamara
Managing Director
SMS Finance
PO Box 56
COTTON TREE QLD 4556

9     Media

9.1     At no stage is any employee to act as a spokesperson for SMS Finance to any form of the   media.
9.2     Employees are instructed to refer all media enquiries to John McNamara.  If John is available, request an email or letter be sent to John McNamara, including the party's name, the name of the organisation they represent and concise details of their enquiry or reason for calling.

10     Staff complaints about external parties

10.1     Staff complaints regarding external parties (eg abusive or inappropriate calls received) should be directed to John McNamara or Judy Gleeson in the first instance.
10.2     John McNamara will handle complaints of this nature on a case-by-case basis.

11     Staff grievances / complaints about  internal issues

11.1     These complaints must be directed to John McNamara or Judy Gleeson for reasons of confidentiality and the specialist knowledge these issues require.

12     Records

12.1     Management of records and data are logged electronically in the Complaints Register held in Administration / Compliance & Legislation / Complaints Register.
12.2     Records are maintained in accordance with IDR procedures.

13     COMPLAINTS REGISTER - FILES

13.1     Complaints Register / Complaint file / SMS Finance Complaint Procedures Policy / COSL Complaint procedure hand book / MFAA I.D.R Procedures / MFAA Code of Practice.