1. General
At Implemented Portfolios Pty Ltd (IPL), we are never satisfied when it comes to doing better and our customers and the moments that matter are very important to us. If something goes wrong, we’re determined to make it right again. If you’ve had an experience with IPL that you are not satisfied with, we’re here to resolve the issue, so please talk to us.

Client complaints (and other customer complaints) in respect of the Company’s provision of financial services in Australia will be monitored and dealt with by IPL’s Chief Operating Officer (COO).

2. Complaint defined

ASIC defines a complaint as an expression of dissatisfaction made to or about an organisation, related to its products, services, staff or the handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required.

Under this policy, the following samples of expressions of dissatisfaction are complaints:

• posts (that meet the definition of ‘complaint’ above) on a social media channel or account owned or controlled by IPL that is the subject of the post, where the author is both identifiable and contactable;
• an objection to a proposed decision about how and to deal with an investment correction;
• complaints about a matter that is the subject of an existing remediation program or about the remediation program itself (e.g. delays, lack of communication).

3. Complaints Procedure
Following notification of a complaint, the COO will log notice of the complaint in the IPL Complaints Register.

The COO, in association with the officer responsible for the client relationship where relevant, will:

• acknowledge the complaint promptly (within 24 hours – or one business day);
• investigate the complaint;
• decide upon appropriate action; and
• respond to the complainant within 30 days of receiving the complaint advising of any decision and the reasons why (which will then be recorded in the complaints register) and informing them of any remedy and avenues of appeal.

The level of detail in a response to the complainant will reflect the complexity of the complaint and the nature and extent of any investigation conducted by IPL.

The written response will include the following:

• Final outcome of the complaint, including details of any actions taken to resolve the complaint;
• Reasons for the outcome, if the complaint was rejected in part or in full, including details of findings and the basis of the decision; and
• Complainant’s right to take the matter to AFCA and the contact details for AFCA.

Should this produce a satisfactory result for the complainant, a note of this will be made in the Complaints Register, finalising the matter.

However, if an issue has not been resolved to the satisfaction of the complainant, the complaint can be escalated to the Australian Financial Complaints Authority (AFCA). AFCA provides fair and independent financial services complaint resolution that is free to consumers.

• Making a complaint online: www.afca.org.au/about-afca/contact-us/
• Telephone: 1800 931 678
• Email: info@afca.org.au
• Or you can write to AFCA at:
  • The Manager
  • Australian Financial Complaints Authority Limited
  • GPO Box 3
  • Melbourne VIC

Should the complaint be escalated to AFCA, consider the need to promptly report this matter to the professional indemnity insurers.

4. Complaints are a key indicator for systemic issues
IPL understands that complaints serve as a key risk indicator for systemic issues warranting early identification and resolution, to not only avert matters from being escalated to AFCA, but to also avoid further harm /detriment to more clients.

Through monitoring from the IPL Board, Management has set clear accountabilities for complaint handling functions as well as the identification and management of system issues, including robust systems to enable systemic issues to be investigated, followed up and reported on to the GRCC and board.

A complaints register is maintained by the Company and the GRCC receives an update each meeting about the latest complaints received.

5. Related policies
This policy will be reviewed every two years to ensure it remains consistent with all relevant legislative requirements, as well as the changing nature of the organisation.