COMPLAINTS POLICY
1. INTRODUCTION
In accordance with the Financial Advisory and Intermediary Services Act (FAIS) and the General Code of Conduct for Financial Services Providers, Spectre Wealth (Pty) Ltd (“the Provider”) has established this Complaints Management Framework. Internal dispute resolution processes are vital to our service standards and professional responsibility. This framework ensures the effective and fair handling of all client complaints, reflecting our commitment to the highest standards of ethics and client care. All staff members of Spectre Wealth (Pty) Ltd, under the leadership of [Name of Responsible Person], are committed to this policy and shall cooperate fully in its implementation.
Contact Information
Email: info@spectrewealth.co.za
Office Tel: 087 133 3918
Address: Jupiter House, Riverpark, 42 Homestead Road, Rivonia, Sandton
2. GENERAL CODE OF CONDUCT
Spectre Wealth (Pty) Ltd is committed to implementing and maintaining a comprehensive Complaints Management Framework in line with the General Code of Conduct, 2003 (as amended).
A “complaint“ is any expression of dissatisfaction that alleges:
- A contravention of law or failure to comply with a rule, agreement, or code of conduct;
- Maladministration, negligence, or failure to act that caused harm or prejudice;
- Unfair treatment by the provider or its service suppliers.
Spectre Wealth (Pty) Ltd undertakes to:
- Require complaints to be submitted in writing;
- Maintain complaint records for at least 5 years;
- Handle all complaints fairly and efficiently;
- Investigate and respond promptly;
- Advise clients on further available remedies where applicable.
3. BASIC PRINCIPLES OF OUR COMPLAINTS PROCEDURES
We commit to:
- A clear internal complaints policy;
- Ensuring clients understand how to lodge complaints;
- Easy access to complaint resolution procedures;
- Fair and balanced handling of complaints;
- Removing unreasonable barriers to lodging complaints;
- Regular reviews of this framework;
- Allocating sufficient resources and training staff adequately;
- Escalating serious complaints to qualified personnel;
- Implementing follow-up processes to address root causes.
4. LODGING A COMPLAINT
Clients must lodge written complaints, supported by relevant documentation. Complaints will be managed by the responsible person, and monitored by our Compliance Officer, Leona Prinsloo.
Our Complaints Management Framework includes:
- Clear responsibility allocation;
- Ongoing monitoring and review;
- Regular reporting to the Compliance Officer and/or FSCA;
- Client communication at each step;
- Risk and trend analysis;
- Data capture and categorisation;
- Acknowledgement, investigation, and resolution process;
- Recording in control sheets and registers.
5. INITIAL HANDLING OF INFORMAL COMPLAINTS
For minor concerns not qualifying as formal complaints:
- Listen attentively;
- Empathise where necessary;
- Assess validity;
- Apologise if appropriate or explain misunderstandings;
- Record in the routine complaints register.
6. COMPLAINTS MANAGEMENT PROCEDURES
Key Persons:
- Responsible Person for Complaints Management: Gansen Govender
- Compliance Officer: Leona Prinsloo
Objective:
- Prompt resolution of complaints;
- Avoid escalation;
- Identify and rectify root causes.
Possible Complaint Areas:
- Misrepresentation of product features
- Willful/negligent conduct causing harm
- Administrative or claims handling issues
- Inadequate product disclosures
- Breach of laws, rules, or contracts
- Repetitive issues or misconduct
- Unfair treatment or maladministration
- Complaints regarding our handling process
Complaint Handling Steps:
| 1 | Verbal complaints must be escalated to the Responsible Person. |
| 2 | Verbal complaints to be documented immediately. (Annexure A: Complaint Control Sheet) |
| 3 | Written complaints are recorded and tracked. |
| 4 | Complaints entered in the register. |
| 5 | Task created for ongoing monitoring and management. |
Complaint Categories and Actions:
| Category | Action |
| Misrepresentation | Internal investigation |
| Admin/Claims issues | Internal or refer to Insurer |
| Product design/pricing | Refer to product provider |
| Legal breach | Internal investigation |
| Breach of mandate | Internal investigation |
| Misconduct or bad faith | Internal investigation |
| Advice quality | Internal investigation |
| Performance or lapses | Internal or refer |
| Complaint handling | Internal or refer |
| Non-payment of claims | Internal or refer |
| Accessibility issues | Internal or refer |
7. COMPLAINT MANAGEMENT & REVIEW
| 1 | Acknowledge in writing within 2 working days. If unresolved, update the client within 15 working days. |
| 2 | No need to request written confirmation for simple verbal complaints, but still record formally. |
| 3 | Responsible Person investigates (unless conflict arises; then Compliance Officer steps in). |
| 4 | Notify insurer, where applicable. |
| 5 | For minor issues, send written resolution confirmation. |
| 6 | All offers to be made and accepted in writing. |
| 7 | If complaint is invalid, explain reasons in writing. |
| 8 | Offer mediation involving Compliance Officer. |
| 9 | If unresolved in 30 working days, provide Ombud contact details and complaint form. |
| 10 | Once resolved, close complaint register entry. |
| 11 | Quarterly reporting to Leona Prinsloo. |
| 12 | File complaints separately by year (5-year retention). |
8. COMPLAINT CLASSIFICATION AND ESCALATION
The Responsible Person must assess each complaint for escalation or Compliance Officer intervention.
9. ANALYSIS OF COMPLAINTS
The complaints register will track:
- Customer details and complaint types
- Number of complaints received/upheld/rejected
- Reasons for rejections
- Complaints escalated (insurer/Ombud)
- PI claims and goodwill payments
- Number of unresolved complaints
This data will be analysed quarterly and used for compliance, conducting risk management, and continuous improvement.
10. DETAILS OF OMBUDSMAN
The NFO is an umbrella Financial Services Ombud scheme formed by the amalgamation of 4 separate previously existing South African Ombud Schemes: the offices of the Banking Ombud (OBS); the Credit Ombud (CO); the office of the Long-term Insurance Ombud (OLTI); and the Short-Term Insurance Ombudsman (OSTI).
For complaints about the way we handled your complaint about LONG-TERM INSURANCE or SHORT TERM INSURANCE, contact the office of the NFO on the details below:
NATIONAL FINANCIAL OMBUDSMAN CONTACT DETAILS:
| NFO Johannesburg
Houghton Estate, Johannesburg, Gauteng, 2198 |
NFO Cape Town
6 Vineyard Road, Claremont, Cape Town, 7700 |
Contact Details:
+27 66 473 0157
|
For complaints about the way we handled your complaint about FINANCIAL SERVICES, contact the office of the Financial Services Providers Ombudsman (also known as the FAIS Ombud):
FINANCIAL SERVICES PROVIDERS OMBUDSMAN (FAIS OMBUD)
| Ground Floor, Baobab House
Eastwood Office Park Cnr Lynnwood Road & Jacobson Drive Pretoria 0081 |
Postal Address:
PO Box 74571 Lynnwood Ridge Pretoria 0040 Email: info@faisombud.co.za |
Telephone 012 470 9080
Website: www.faisombud.co.za |
PENSION FUNDS ADJUDICATOR
| 4th Floor Block A
Riverwalk Office Park 41 Matroosberg Road Ashlea Gardens Pretoria 0081 |
Postal address:
PO Box 580 Menlyn Pretoria 0063 Email: enquiries@pfa.org.za |
Telephone: 012 346 1738
Fax: 086 693 7472
Website: |