Complaints & Internal Dispute Resolution Policy¶


Code	`CON-002`
Domain	Customer & Conduct
Owner	Head of Customer Experience
Status	Draft
Applicability	Platform
Jurisdiction	NZ + AU
Business domain	BD01
Review date	2027-03-25

Regulations: FSCL / FSOS · ASIC RG 271 · AFCA Rules ¶

Purpose¶

Govern the platform's internal dispute resolution (IDR) process across NZ and AU. Defines acknowledgement timeframes, resolution obligations, record-keeping standards, and the escalation pathway to external dispute resolution schemes (FSCL in NZ, AFCA in AU).

Scope¶

All complaints received from retail and small business customers across NZ and AU, regardless of channel (digital, phone, written, or in-person). Includes complaints about products, service quality, fees, decisions, and the conduct of staff or agents.

Policy statements¶

The platform SHALL acknowledge every complaint within one business day in NZ and within five business days in AU. Acknowledgement SHALL confirm receipt, provide a reference number, and state the expected resolution timeframe.

The platform SHALL resolve complaints within 45 calendar days of receipt. Where a complaint cannot be resolved within 45 days, the customer SHALL be notified of the reason for delay and advised of their right to escalate to the applicable external dispute resolution scheme.

Complex complaints — including those involving potential financial loss, potential regulatory breach, or vulnerable customers — SHALL be escalated to a senior complaints handler within five business days of receipt.

Where a complaint cannot be resolved to the customer's satisfaction, the final response SHALL include a clear explanation of the platform's decision, the basis for that decision, and the details of FSCL (NZ) or AFCA (AU) as the applicable external dispute resolution scheme.

Complaints involving potential systemic issues — affecting more than one customer or arising from a common root cause — SHALL be escalated to the Head of Compliance for root cause analysis and remediation planning.

All complaint records SHALL be retained for seven years and SHALL be available for regulatory inspection. The complaints register SHALL be reported to the Board Risk Committee at least quarterly, including trends, root causes, and resolution rates.

The platform SHALL not treat a complaint as resolved unless the customer has been given the opportunity to accept or decline the outcome, or the statutory resolution period has elapsed.

Satisfying modules¶

Module	Name	Mode	Description
MOD-047	Agent action logger	`LOG`	Complaint handling actions logged — IDR process is fully auditable
MOD-053	Case & complaint management module	`ALERT`	IDR SLAs enforced automatically — agent cannot ignore a case past SLA without triggering escalation
MOD-083	Agent assist & compliance coaching panel	`AUTO`	IDR complaint obligations surfaced to the agent in real time during a customer interaction — script prompts ensure required disclosures are not omitted.
MOD-149	Scam intelligence reporting & reimbursement	`AUTO`	Scam reimbursement cases are tracked through the IDR workflow with statutory SLA timers — reimbursement decisions are documented and communicated within required timeframes.

Part of Customer & Conduct · Governance overview Compiled 2026-05-22 from source/entities/policies/CON-002.yaml