BC-3.3.17
General principles for objectivity in the complaints handling process include:
(a) Openness: The process must be clear and well publicised so that both staff and customers can understand.
(b) Impartiality:
(i) Measures must be taken to protect the person the complaint is made against from bias;
(ii) Emphasis must be placed on resolution of the complaint not blame; and
(iii) The investigation must be carried out by a person independent of the person complained about.
(c) Accessibility:
(i) The investment firm licensee must allow customer access to the process at any reasonable point in time; and
(ii) A joint response must be made when the complaint affects different participants.
(d) Completeness: The complaints officer must find the relevant facts, talk to both sides, establish common ground and verify explanations wherever possible;
(e) Equitability: Give equal treatment to all parties.
(f) Sensitivity: Each complaint must be treated on its merits and paying due care to individual circumstances.
(g) Objectivity for personnel — complaints handling procedures must ensure those complained about are treated fairly which implies:
(i) Informing them immediately and completely on complaints about performance;
(ii) Giving them an opportunity to explain and providing appropriate support;
(iii) Keeping them informed of the progress and result of the complaint investigation;
(iv) Full details of the complaint are given to those the complaint is made against prior to interview; and
(v) Personnel must be assured they are supported by the process and should be encouraged to learn from the experience and develop a better understanding of the complaints process.
(h) Confidentiality:
(i) In addition to customer confidentiality, the process must ensure confidentiality for staff who have a complaint made against them and the details must only be known to those directly concerned;
(ii) Customer information must be protected and not disclosed, unless the customer consents otherwise; and
(iii) Protect the customer and customer's identity as far as is reasonable to avoid deterring complaints due to fear of inconvenience or discrimination.
(i) Objectivity monitoring: Investment firm licensees must monitor responses to customers to ensure objectivity which could include random monitoring of resolved complaints.
(j) Charges: The process must be free of charge to customers;
(k) Customer Focused Approach:
(i) Investment firm licensees must have a customer focused approach;
(ii) Investment firm licensees must be open to feedback; and
(iii) Investment firm licensees must show commitment to resolving problems.
(l) Accountability: Investment firm licensees must ensure accountability for reporting actions and decisions with respect to complaints handling.
(m) Continual improvement: Continual improvement of the complaints handling process and the quality of products and services must be a permanent objective of the investment firm licensee .
Amended: January 2012
Adopted: October 2011
Adopted: October 2011