Complaints Procedure

1. Scope

The board of directors and Key Individuals of Asuer are responsible for effective complaints management and must approve and oversee the effectiveness of the implementation of the complaint management framework.

1.1 What counts as a complaint

A "complaint" in terms of this policy means an expression of dissatisfaction by a person to an employee, a Key Individual or Representative, the Complaints Officer or, to the knowledge of Asuer, to a service supplier relating to a financial product or financial service provided or offered by Asuer which indicates or alleges, regardless of whether such an expression of dissatisfaction is submitted together with or in relation to a client query, that:

• Asuer, its representative or a product/service provider used or recommended by Asuer has contravened or failed to comply with an agreement, a law, a rule, or a code of conduct which is binding on the provider or to which it subscribes;
• Asuer, its representative or a product/service provider used or recommended by Asuer's maladministration or wilful or negligent action or failure to act, has caused the person harm, prejudice, distress, or substantial inconvenience; or
• Asuer, its representative or a product/service provider used or recommended by Asuer has treated the person unfairly;

and excludes any complaint:

• upheld immediately by the person who initially received the complaint;
• upheld within Asuer's ordinary processes for handling client queries in relation to the type of financial product or financial service complained about, provided that such process does not take more than five business days from the date the complaint is received; or
• submitted to or brought to the attention of Asuer in such a manner that it does not have a reasonable opportunity to record such details of the complaint as may be prescribed or required to investigate the complaint.

1.2 Who is a complainant

A "complainant" in terms of this policy means a person who submits a complaint and includes a:

• Customer;
• person nominated as the person in respect of whom a product supplier should meet financial product benefits, or that person's successor in title;
• person whose life is insured under a financial product that is an insurance policy;
• person that pays a premium or an investment amount in respect of a financial product;
• member of a pension fund, provident fund, friendly society, medical scheme, or group scheme; or
• person whose dissatisfaction relates to the approach, solicitation, marketing or advertising material or an advertisement in respect of a financial product, financial service, or related service of the provider,

who has a direct interest in the agreement, financial product, or financial service to which the complaint relates, or a person acting on behalf of such a person.

1.3 What "upheld" means

"Upheld" means that a complaint has been finalised wholly or partially in favour of the complainant and that:

• the complainant has explicitly accepted that the matter is fully resolved; or
• it is reasonable for the provider to assume that the complainant has so accepted; and
• all undertakings made by the provider to resolve the complaint have been met, or the complainant has explicitly indicated its satisfaction with any arrangements to ensure such undertakings will be met by the provider within a time acceptable to the complainant.

2. Purpose

The objective of this complaint management framework is to bring about:

• Fair outcomes for complainants;
• The fast, effective, and objective resolution of any complaint;
• Proper and regular feedback to complainants;
• Improved organisational effectiveness through learning from client feedback and root cause analysis;
• Effective engagement between Asuer and the relevant Ombudsman scheme;
• Identification of possible service breakdowns and product or third-party challenges; and
• Compliance with reporting requirements to the Registrar and/or the public where relevant.

3. Policy statement

Asuer is dedicated to ensuring that all complaints received are resolved promptly and in a fair and equitable manner. We also consider client complaints and feedback vitally important: they enable us to continuously improve our value proposition.

3.1 Key principles

• Accessibility: The complaints process is simple and easily accessible;
• Client-centricity: Clients will be treated with respect, and receive regular and clear, plain-language feedback;
• Quality investigation: Circumstances relating to a complaint will be investigated thoroughly;
• Timely resolution: Complaints must be resolved well within the timelines set out in this framework;
• Impartial review: The person responsible for complaints management's duties, reporting lines and performance agreement will ensure that they act impartially and objectively;
• Meaningful management information: Informative reports on complaints will be developed and provided regularly to senior management.

4. Complaints framework

4.1 Complaints Officer

To enhance accountability we have appointed Paul Ontong as our Complaints Officer. The Complaints Officer is responsible for monitoring social media platforms for complaints, recording and analysing complaints, monitoring resolution deadlines, recording all client communication, identifying trends and reporting to senior management, thoroughly investigating complaints, regularly liaising with complainants, recommending suitable resolutions, providing management information, liaising with the relevant Ombud scheme, and monitoring Ombud determinations and guidance.

4.2 Lodging a complaint

Complaints should preferably be lodged via email to complaints@asuer.co.za. You may also use WhatsApp Customer Care on +27 62 783 7187 or call +27 10 823 7237.

Anyone who receives a complaint or becomes aware of a complaint should bring it to the attention of the Complaints Officer immediately. On receipt of a complaint the Complaints Officer will:

• Acknowledge receipt to the complainant straight away (extended in certain circumstances to at most 5 days) and advise the client of further steps and the expected date of resolution;
• Capture and classify the complaint in the complaint register;
• Investigate the complaint further;
• Resolve the complaint immediately if possible;
• Make recommendations for resolution and obtain approval for a compensation or goodwill payment if relevant;
• Revert with findings within 3 weeks from receipt of the complaint;
• If the investigation has not been finalised, advise the client and provide an expected date of resolution.

4.3 Complaint outcomes

The complaint may either be "rejected" (not upheld, the complaint is regarded as finalised after advising the complainant that no further action will be taken) or "upheld" (finalised wholly or partially in favour of the complainant). When a complaint is rejected the complainant will be informed and provided with clear and adequate reasons for the decision, the escalation process available, how to use it, and the relevant time limits.

4.4 Escalation

Where a complaint could not be resolved to the complainant's satisfaction by the Complaints Officer, the complainant may refer the matter to a Key Individual. After escalation, if the client is still not satisfied, Asuer will regard the complaint as being unsatisfactorily resolved. The client may then approach the office of the Ombud for Financial Services Providers or take such other steps as may be advised by their legal representatives.

4.5 Unresolved complaints

Where Asuer has not been able to arrive at a resolution within six weeks after having received the complaint, the client must be advised that they may refer the matter to the Ombud, be provided with the Ombud's contact details, and advised that this must be done within a period of six months.

The Ombud for Financial Services Providers may be contacted as follows:

• Telephone: +27 12 762 5000 / +27 12 470 9080
• Facsimile: +27 86 764 1422 / +27 12 348 3447
• Email: info@faisombud.co.za
• Website: www.faisombud.co.za

4.6 Complaints about related / associated entities

We request and review the complaints processes of our product providers and distribution partners as part of our due diligence. Where any complaint received pertains to something out of our control (e.g. product information, product performance, or advice provided by a third-party provider), Asuer will forward the complaint to the party concerned, advise the client accordingly, and where possible facilitate the resolution process.

4.7 Record keeping

Asuer keeps records of all complaints. The record, related correspondence, evidence, documentation, evidence of losses sustained, investigations and decisions are kept for a minimum period of 5 years. The complaint register also enables root cause analysis to identify failings in control systems, poor staff or service-provider performance, skills gaps, or misconduct.

5. Consequences of non-adherence

Disciplinary action will be taken against staff members who do not comply with this policy and related procedures.

6. Training and awareness

Staff members receive a copy of this policy on employment and receive training if complaints management and handling falls within their scope of duties. A complaint manual has been developed to further guide staff with regards to complaint handling.

7. Review

This policy is reviewed regularly.