Part E – Prompt and Fair Resolution of Complaints

21. Internal dispute resolution

21.1 We will have an internal process for handling complaints from our customers in relation to the products and services we provide.

21.2 We will provide information on our website about how we deal with complaints, including your right to take unresolved complaints AFCA.

21.3 Our complaint resolution procedures will comply with the same ASIC standards and requirements that Australian Financial Services Licence holders must comply with, except where we promise to improve on those standards and requirements.

21.4 We will work to resolve your complaint as quickly as possible, including “on the spot” if we can.

21.5 We will acknowledge all complaints within 1 business day or as soon as practicable and provide an initial response within 10 days from the date of the complaint.

21.6 We will provide you with a written response within 30 calendar days of receiving the complaint that will include:

a. the outcome of our investigation of your complaint;

b. your right to take your complaint to AFCA;

c. AFCA’s contact details.

21.7 If we reject or partially reject your complaint we will advise you of the reasons for our decision by:

a. identifying and addressing the issues raised in the complaint;

b. setting out our findings on material questions of fact and referring to the information that supports those findings;

c. providing enough detail for you to understand the basis of our decision and be fully informed when deciding whether to escalate the matter to AFCA.

21.8 There may be some circumstances where (unless otherwise required to do so) we will not provide a written response to you because we have either:

a. resolved the complaint to your satisfaction within 5 days; or

b. given you an appropriate explanation and/or apology and there are no further actions we can take to reasonably address the complaint.

21.9 We will only be able to deal effectively with your complaint if you continue to communicate with us and respond to our reasonable requests for information while we are considering the complaint.

21.10 We are committed to responding to complaints and disputes in a way that is:

a. prompt, efficient and transparent;

b. consistent with the law; and

c. fair in all the circumstances.

22. External dispute resolution

22.1 If we are not able to resolve your complaint to your satisfaction, you can take your complaint to AFCA.

22.2 AFCA may not deal with your dispute unless you have attempted to resolve the problem with us first and either:

a. we have made a proposal to resolve the complaint and you have told us the proposal is not acceptable to you; or

b. at least 30 calendar days (or the timeframe set by AFCA) has elapsed since you made your complaint.

22.3 AFCA may consider whether we have complied with the standards of this Code when seeking to resolve a matter.

You can contact AFCA on telephone 1800 931 678, by email at info@afca.org.au or their website www.afca.org.au.

23. Online Small Business Lenders Code Compliance Committee

23.1 You can report an alleged breach of this Code to the Online Small Business Lenders Code Compliance Committee (CCC).

23.2 The CCC is an independent committee that has been established to monitor our compliance with this Code. The CCC can investigate any activities within its Terms of Reference including any alleged breaches by us of the Code. It is authorised to take actions that are within its powers and to make recommendations to the AFIA Board.

23.3 We will co-operate and comply with all reasonable requests of the CCC in the performance of its monitoring and investigative functions.

23.4 The CCC can make a range of decisions or recommendations to resolve an alleged breach of the Code. In some circumstances the CCC can impose sanctions on us.

23.5 We will abide by decisions made by the CCC.

You can contact the CCC by email at CCC-OSBL@afia.asn.au or here under the Reporting a breach of the Code heading.