SUMMARY
Real Assets Advisory & Finance (Real Assets) always seeks to provide our customer’s with excellent service and to resolve any concerns or complaints you may have in fast and fair manner.
To ensure that our Internal Dispute Resoution (IDR) process conforms to ASIC regulatory requirements and industry best practice, we have submitted it for review by the Commercial & Asset Finance Brokers Association.
- We understand that resolving any complaints in a positive manner is an important aspect of customer support, and we welcome feedback as a means of improving our customer services.
- We will treat all customer complaints with courtesy, and ensure that the resolution process is transparent and communicated clearly to the client.
- We will apply this policy to all our disputes clients, suppliers and other relationships
- Our IDR process will also be implemented in line with our Privacy Policy, and conducted in line with relevant regulations to protect client information
- This IDR process will be made available on our website and we will inform clients of it, before commencing service with them.
- The Responsible Manager will manage complaints.
- Our Internal Dispute Resolution Manual complies with ASIC’s requirements and details how we manage and report complaints.
- We are a member of the Australian Financial Complaints Authority (AFCA) Member #82573
- We accept EDR scheme decisions and implement their recommendations as soon as we are informed of them.
- The Responsible Manager will be responsible for maintaining information on any complaints, compliance breaches and their resolution.
- Any compliance breaches will be reported to the regulator in line with our policy, and an assessment will be made along with recommendations to prevent the recurrence of these issues.
INTERNAL DISPUTE RESOLUTION (IDR) POLICY
Real Assets views the IDR process as a way to strengthen our relationship with the customer, by addressing any concerns or complaints in such a way to provide a positive experience for the client.
We recognize the requirement under the National Consumer Protection Act 2009 that Internal Dispute Resolution (IDR) policy is in place, that complies with the standards and requirements of ASIC RG165 (July 2020) which covers disputes in relation to the credit activities engaged in Real Assets and its representatives.
Receiving Complaints*[i]
Complaints can be lodged by contacting the Disputes Officers by:
- online via our customer feedback form on http://www.realassetsaf.com
- by telephone on 0432-982-857
- via email to our Responsible Manager: peter.knight@realassetsaf.com
- by post to 9 Bruny Place, Lyons, Canberra, ACT
Any complaint which is resolved to the customer’s satisfaction by the end of the next business day (starting from when the complaint was received) will not need to be captured as per the full IDR policy below.
Investigating Complaints
The responsible officer for handling and resolving complaints will review will conduct a reasonable review of the complaint carefully and promptly, including relevant documentation.
Appropriate Time Limits and Responses / Referral of Unresolved Complaints for External Dispute Resolution (EDR)
The officer responsible for handling and resolving a client complaint will provide a written final response to the complainant within 45 days which will contain the following information:
- the outcome of the dispute at IDR
- the customer’s right to take their dispute to EDR (no matter what the result of the investigation was at IDR)
- the name and contact details of our EDR scheme.
If the officer is unable to give a final response within the specified period, they will, before the end of the period:
- inform the complainant of the reasons for the delay
- advise the complainant of their right to complain to EDR
- provide the complainant with the name and contact details of our EDR scheme.
The customer can go direct to EDR regarding disputes involving hardship or postponement which also involve issues with default notices.
Legal Processes
Legal proceedings will not be undertaken. nor will any other enforcement action be taken during the IDR period – or for at least 14 days from a final response through the IDR process – unless the statute of limitations is about to expire.
Recording Complaints, Identifying & Recording Systemic Issues.
Any complaints will record the following information, which will be made available to the complainant.
- Complaint Number
- Date of Complaint
- Client Name
- Complaint Type
- Responsible Officer
- Outcome of Complaint
- Date of Resolution / Escalation
Response where Complaint is Shown to be Justified
Where a customer complaint is merited, the relevant officer will recommend a solution comprising one or more of the following:
- an apology
- compensation
- vary contractual obligations
- a free service
INTERNAL STRUCTURES AND REPORTING REQUIREMENTS
The Officer responsible for complaint handling / resolution will report directly to the owners of Real Assets. The Officer will, at a minimum, make an annual written report of any complaints received and their resolution. The Officer will also conduct an annual review of Real Assets IDR policies and processes and make recommendations on ways in which these could be improved.
IDR Process Guidelines
- Assessment Process – All complaints will be handled in a transparent and systematic manner. Any structural issues will be identified and measures to prevent a recurrence will be clearly documented.
- Customer focused – We will respond in a courteous manner, with the goal of resolving any issue in an efficient manner that leaves the client with a positive experience of how we address their concerns
- Costs – There will be no cost to clients for the IDR procedures
- Confidentiality – We will keep information confidential in line with our Privacy Policy and relevant regulations
- Professionalism – we will ensure that Real Assets and its representative conduct themselves in a professional manner in handling and resolving client complaints. That they show client consideration, investigate the basis for such claims fully, and that communicate clearly, timely and in full regarding the causes and actions being taken in regard to the complaint.
- Transparency – Real Assets will make our IDR policies and procedures available to customers, and take reasonable measures to ensure clients understand how to make a complaint or apply for hardship or postponement. This information will be posted on our website at all times. Anyone responsible for customer relations should have an understanding of our IDR procedures.
Transparency of our IDR Policy
Real Assets will post our IDR process on our Website (www.realassetsaf.com) and ensure that any staff responsible for client relations provide the details of our IDR to their customers
Their disclosure documents will be required to detail that they:
- Are an employee of Real Assets, and where relevant that they are acting as a Credit Representative – including their licensed qualifications and number.
- That they abide by the Internal Dispute Resolution Procedures of Real Assets
- The Credit Representatives AFCA Membership Number
STEPS FOR CLIENTS TO NOTIFY REAL ASSETS OF A COMPLAINT
Real Assets requests that clients explain the details of their complaints as clearly as possible, either verbally or in writing.
We will seek to resolve all complaints promptly and fully. Our goal is to give the customer a positive experience of our ability to address their concerns, and we value the feedback we receive from this process as a way to improve our client support.
We will observe the following principles in handling your complaint:
- Particularly in a period of health concerns, we recognize that in person contact may be difficult. If useful, we are happy to address face-to-face, but can also do so remotely either by audio or video conference and via email.
- We expect that both sides will act in good faith to identify and resolve any issues, and that they will treat the other professionally and with courtesy.
- we expect that both sides will provide all essential and relevant information, documents, written statements and any other materials that may properly and reasonably be believed to assist in resolving the complaint;
- we expect that both sides will comply with all reasonable requests from the other party to provide information within a reasonable time frame.
EXTERNAL DISPUTE RESOLUTION SCHEME
If we do not reach agreement on your complaint, you may refer the complaint to the Australian Financial Complaints Authority (AFCA) of which Real Assets is a member.
Phone 1800 931 687 or http://www.afca.org.au
External dispute resolution is a free service established to provide you with an independent mechanism to resolve specific complaints.
[i] We adopt the definition of “‘complaint” in AS ISO 10002-2006, namely “ an expression of dissatisfaction made to an organisation, related to its products or services, or the complaints handling process itself, where a response or resolution is explicitly or implicitly expected”. This means we will treat informal complaints seriously and refer them to IDR unless they are resolved by the end of the next business day.