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DISPUTE RESOLUTION POLICY

1. General

In delivering financial products to clients, situations may arise that cause dissatisfaction.

Dissatisfied clients will typically raise a complaint or dispute several issues, for example level of service provided, financial loss suffered, poor communication, etc.

While a complaint may mean any query, complaint or dispute in our business, AP Financial Services Group Limited (AP Group) has defined a complaint as any expression of dissatisfaction with our services that:

  • threatens to escalate to a court or 3rd party (at which point it becomes a dispute);
  • relates to fraudulent behaviour or non-compliance with legislation or practice standards; and/or
  • is likely to lead to financial loss for any party.

Complaints of this nature will need to be recorded in a complaints register for two reasons – (i) for tracking and ensuring that a resolution is achieved, and (ii) for future evaluation and analysis to help identify systemic issues that require corrective action.

Some client queries are more likely to be service related matters, eg statements not issued on time, typographical errors or incorrect details on correspondence etc. These items should be recorded separately from the complaints register.

The complaints handling system is generally based on Australian Standards on Complaints Handling AS 4269-1995, and consists of an Internal Dispute Resolution (IDR) system and membership of an ASIC approved External Dispute Resolution (EDR) scheme. We recognise that for effective complaints handling, there needs to be commitment at all levels to be pro-active and positive in handling and responding to complaints and issues raised.

Factors underpinning our approach are:

  • Our commitment to dispute resolution. We recognise that complaints and complainants provide an opportunity to correct deficiencies in our systems and practices and should be viewed as a valuable source of continuous improvement for our company.
  • An organisational culture that acknowledges client rights and protection of their interests.
  • Allocation of sufficient resources to resolve disputes.
  • The visibility of our complaint handling process. Our clients know in advance of what our complaint procedures are as this is disclosed in our Financial Services Guide (FSG).
  • Our quick response to client complaints and our commitment to adhering to our published timeframes.
  • A commitment to fee-free processes for the client.
  • A commitment to be fair to both the complainant and the staff member taking into account the rights of both parties.
  • Our commitment to fair remedies and reasonable compensation for legitimate losses.
  • Our commitment to accurate and effective data collection which identifies systemic issues so that appropriate measures can be developed to prevent their re-occurrence.

An underlying feature of our dispute resolution procedures is our preference to resolve complaints directly through our IDR procedures, rather than involve external third parties.

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