1. Purpose

1. It is Spot Me Finance Pty Ltd (SMF) policy to operate and maintain internal dispute resolution (IDR) procedure, based on the requirement for a holder of an Australian Credit Licence (ACL) to be compliant with Regulatory Guide 165 (Licensing: internal and external dispute resolution (RG165)), and the AS ISO 10002-2006 Customer satisfaction – Guidelines for Complaints Handling in Organizations.

2. The purpose of this policy is to

   • Recognize, promote and protect customers’ rights to complain about their dealings with SMF;

   • Ensure that an accessible complaints management process is in place;

   • Take appropriate action to resolve complaints as required;

   • Provide a mechanism for resolving complaints in a timely, efficient and courteous manner; and

   • Record, assess and review complaints on an ongoing basis in order to improve the products and services offered by SMF.

3. SMF will conduct regular and ongoing reviews of its IDR policy procedures, the Complaints Register and its training procedures to determine whether not amendments need to be made in accordance with information provided to it by the Complaints Manager. If necessary, amendments will be made to this policy.

2. Definition Of Dispute

1. In order to comply with Regulatory Guide 165 and ASIC requirements for IDR procedures, SMF has adopted the AS ISO 10002-2006 definition of Complaint: “An expression of dissatisfaction made to an organization, related to its products or services, or the complaints handling process itself, where a response or resolution is explicitly or implicitly implied.”

2. The National Consumer Credit Protection Act (2009) refers to the necessity for a credit provider to have processes in place for dealing with ‘disputes’. In Regulatory Guide 165 the words ‘complaint’ and ‘dispute’ are used interchangeably and for that reason and for the purposes of this policy, we take ‘dispute’ and ‘complaint’ to mean the same thing.

3. IDR Responsible Person

1. SMF appoints a Complaints Manager as the person responsible implementing and maintaining the IDR processes. The Complaints Manager will regularly review the record of complaints and disputes made against SMF so that systematic problems are identified and, if necessary, resolved.

2. The Complaints Manager will also ensure all SMF staff are provided with a copy of this policy and trained in how to:

• Listen and respond to a complainant’s initial complaint advice;

• Attempt to resolve the complaint with the complainant;

• Escalate a complaint to the Complaints Manager;

• Provide information to a complainant on how, where, who and what information to include when making a written complaint.

4. Making a Complaint

1. It is SMF policy that its IDR policy, processes and procedures will provide an environment whereby complainants will have the opportunity to raise any concerns they may have in relation to the service and/or product provided by SMF and be assured that their concerns will be addressed by SMF staff in a fair, consistent and timely manner, regardless of how the complaint advice is received.

2. SMF is committed to providing complainants with a simple and uncomplicated complaints process. A complaint or dispute can be made to SMF by any of the following methods:

   • Email;

   • Live Chat;

   • Web form; or

   • Mail

3. If requested, staff will assist customers wishing to register a complaint or dispute. This may include SMF staff filling out a complaint form on behalf of the complainant.

5. Complaint Response

1. It is the procedure of SMF that, where possible, staff will resolve all complaints at the time they are received. If it is not possible, SMF staff are required to escalate the complaint to the Complaints Manager.

2. When investigating, and responding to complaints, SMF staff will be required to:

• Make every effort to respond to each complaint within 24 hours of receipt;

• Where the complaint or dispute cannot immediately be resolved, advise the customer in writing within 2 working days that the complaint or dispute has been received and provide them with a copy of this policy for their records;

• The SMF staff member must deal with the complaint or dispute within 21 days;

• If it is not possible to make a decision within the 21-day period, the investigating staff member must write to the complainant advising that a further period of investigation is required. The complainant will also be advised of their right to escalate the complaint to the Complaints Manager, if they remain dissatisfied with the handling of their complaint up to now. The period during which a final decision must be made can be no more than 45 days from the date of lodgment of the complaint or dispute;

• Where a complaint or dispute remains unresolved for a period in excess of 45 days from the date of lodgment of the complaint or dispute, the investigating staff member must advise the complainant in writing when a decision is expected to be made. Regular updates, at no less frequent intervals than monthly, should be made to the complainant during this period of time;

• As soon as a complaint or dispute has been resolved, the investigating staff member will ensure that the agreed action, if any, is put into place. In addition, the staff member will also advise the complainant in writing the following:

• The outcome of the investigation;

• Reasons for the outcome including, where applicable, reference to statutory or other provisions;

• That if, after having raised the complaint to the Complaints Manager, the complainant is still dissatisfied with all or part of the response, the complainant has the right to escalate the complaint to the External Dispute Resolution (EDR) scheme of which SMF is a member;

• That the EDR scheme is a free service; and

• The name and contact details of the EDR scheme of which SMF is a member.

• All complaints and disputes will be dealt with in an equitable, objective and unbiased manner.

• We will ensure that, so far as is possible, the investigating staff will be a person who was not involved in the initial matter giving rise to the complaint and will be a person with sufficient seniority and authority within the organization to deal with the matter.

• There will be no charge levied on the complainant for the determination a complaint or dispute through the internal dispute resolution process.

• All complaints or disputes will be dealt with in a confidential manner. Except where necessary for the determination of the dispute, confidential information that includes personally identifiable information, will be removed.

6. Settlement

1. All SMF staff has the authority to resolve any complaint or dispute, does not involve alteration of the amount owing by a customer to the company. Examples of which can include any combination of the following:

• Direct apology to the complainant (verbal, written or both);

• Agreeing to bring the matter to the attention of senior managers;

• Staff Training; and/or

• Review of internal procedures.

2. Only the Complaints Manager or Company Directors have the authority resolve any complaint or dispute that involves payment by way of adjustment to a customer's account up to the amount of $1,000. A Company Director can only approve settlement of a complaint or dispute involving an amount greater than $1,000.

7. Complaints Register

1. A Complaints Register will be maintained by the company for and tracking of complaints and disputes, which are not resolved to the satisfaction of the customer within 24 hours of lodging of the complaint or dispute.

2. The officer responsible for ensuring that the Complaints Register properly maintained is the Complaints Manager.

3. The Register will contain records of all complaints and disputes the following:

• Index number of the complaint or dispute (by which the complaint will be identified);

• Date the complaint or dispute was first notified;

• Name of the complainant;

• SMF member number and loan number;

• Details of the complaint or dispute;

• Category of dispute;

• Date of first response;

• Person responsible for management of the complaint or dispute;

• Action taken;

• Terms of resolution (if any); and

• Date resolved.

4. The Register shall be maintained in strictest confidence with granted only to; Company Directors, Senior Management, ASIC, CIO and other regulatory authorities with appropriate authority to view the register, or when required to by law.

5. The Complaints Manager will ensure that any additional information arising from investigation of a complaint or dispute is retained (including both hard and soft copies) so that adequate review can be made from time to time, both internally or by later referral to an EDR scheme.

8. How To Lodge a Complaint

If you have a complaint, please contact our Complaints Manager on complaints@spotmenow.com.au, Please include the following:

• Your name

• Loan number this relates to

• Details of the Complaint / Dispute

The Complaints & Disputes was last updated on June 2018