Complaint Management

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1: INTRODUCTION

AIICO Capital Limited (“ACL”) is a client and service-oriented company that sees client’s satisfaction as wealth creation and views complaint management process as an avenue to continuously deliversatisfactory services to our Clients. To articulately manage the process, we have developed an approach in line with the SEC Complaint Management Framework for managing complaints which are regarded as Client Compliant Management (“CCM”).

As a Capital Market Operator (CMO), we recognize the need to establish a Complaint Management Framework which will address complaints professionally, competently, timely, and in a manner complaint with the principles of natural justice, equity and good conscience as well as upholding utmost confidentiality.

2: OBJECTIVES

The objectives of the Complaints Management Framework are to:

  1. 2.1: Provide guidance to the individuals who are responsible for handling and resolving complaints within AIICO Capital Limited
  2. 2.2: Ensure clients receive the excellent level of service they are entitled to receive
  3. 2.3: Provide an effective method of early detection of failures in service delivery and serve as a valuable source of feedback on quality of service
  4. 2.4: Provide an opportunity for the Company to improve its services and sustain its good reputation
  5. 2.5: Ensure adherence to SEC rules relating to the Complaints Management Framework of the Capital Market Operators.

It is necessary to note that Client complaints can be verbal or written. All complaints must be recorded and resolved timely in accordance with laid down rules set by the SEC.

3: KEY FEATURES OF AIICO CAPITAL CLIENT COMPLAINT MANAGEMENT FRAMEWORK

The following highlights the key features of the AIICO Capital Limited’s CCMF

  1. 1: Quarterly reporting of client complaints to the regulatory authorities
  2. 2: Documented complaint management process that ensures consistency in application
  3. 3: Formulation of a Complaint Management Committee.
  4. 4: Periodic client complaint management training; and
  5. 5: Weekly updates on complaints and resolution to be reported to the Head of Sales and Client Service / Compliance Officer.

4: POLICY STATEMENT

The aim of having an efficient Client Complaint Management procedure is to ensure proper management of complaints brought to the attention of the company for fair resolution. It is designed to improve the services offered, by helping to detect weakness, remedy unfair situations and improve operating methods within the system.

The Board and Management are highly committed to promoting an effective and efficient complaint handling process within the Company and adequate resources shall be deployed towards ensuring the achievement of this objective. All Complaints received shall be acknowledged and analyzed towards aiding and ensuring informed and continuous quality improvement initiatives.

The major aims of this Framework are to:

  1. 1: Provide accessibility and a platform for clients to communicate any dissatisfaction to ACL.
  2. 2: Improve communication links between ACL and its clients
  3. 3: Establish and maintain a clear, effective and transparent procedure for reasonable and prompt management of all client complaints.
  4. 4: Continuous management of clients’ experience enhanced client satisfaction and brand protection
  5. 5: Identify developmental and improvement areas in order to provide better services
  6. 6: Establish a consistent approach and guideline to be observed when attending to complaints; and
  7. 7: Comply with regulations on Complaint Management, particularly with the SEC Client Complaint Framework.

5. TYPES OF CLIENT COMPLAINTS

We recognize that Complaints may fall into one or more of the following categories:

  • a: Complaints alleging financial losses;
  • b: Complaints with potential legal/regulatory implications;
  • c: Complaints alleging failure of service delivery; and
  • d: Complaints that increases the risk of reputational damage.
  • 5.1: Causes of complaints

    The following issues have been identified as causes of clients‘ complaint though the list is inexhaustive:

    • 1. Delay in execution
    • 2. Poor Client service
    • 3. Failure to carry out instructions
    • 4. Negligence, which includes
      • a. Failure to follow through on promises; and
      • b. Failure to carry out instructions.
    • 5. Mistakes in the computation of charges/fees
    • 6. System errors; and
    • 7. Communication and or technological failures
  • 5.2: Channel of Complaint

    AIICO Capital’s clients may lodge their complaints through any one or more of the following channels:

    1. 1: Verbal Complaints - Complaints may be reported verbally through our Client Service Help Desk or Relationship Managers or through members of staff. Complaints may also be verbally reported via the line 01-6350003.
    2. 2: Written Letters - Complaints may be reported through letters addressed to AIICO Capital Limited at Plot 12, 2nd Floor AIICO Plaza , Churchgate Street, Victoria Island, Lagos and marked for the attention of;
      1. a: Client Service Unit
      2. b: Relationship Manager (where the name is known)
      3. c: the Managing Director
    3. 3: By Email - Complaints can be reported through emails to the client service email address, through members of Staff of the Company. This complaint should be sent to [email protected]

    The recipient of the complaint in respect of clauses a, b and c above shall escalate the complaint to Senior Management for the purpose of implementing and monitoring compliance of the Complaint Management Policy. Provided that Senior Management shall assign the duty of resolution of such complaints to the Complaint Management Committee for resolution in accordance with Clause 7 below

6: RISK RATING OF COMPLAINTS

We have categorized Client’s complaints under three board heading of low, medium and high based on internationally accepted risk rating method and for ease of treatment of complaints.

  1. 1: Low risk

    Complaints that can easily be resolved via any channel which such complaint is received or shortly thereafter. This has minimal financial or legal implications and can be handled by any staff without any specific exp

  2. 2: Medium risk

    Complaints that can be resolved on the spot but require assistance of a support staff at the back office. This also has minimal financial and legal implications; and

  3. 3: High risk

    These are Complaints that have financial, legal and or reputational implications and require the expertise of the centralized complaint management desk within Client Service and the operations team for resolution.

7: CLIENT COMPLAINT MANAGEMENT PROCEDURE

The procedure for managing client complaints is progressive in nature. Upon the completion of the first stage, the next stage shall commence and shall continue in that order until final resolution of the complaint. Note that as soon as a resolution is reached, subsequent stages of the CCM would be discontinued. The stages are outlined below;

  1. 7.1: Acknowledgement upon the receipt of a Client’s complaint, the immediate recipient of the complaint should take any of the following actions depending on the mode of complaint as listed under clause 7.

    1. 7.1.1: In the case of verbal complaints:

      a: An attempt should be made to calm the offended client while an employee with better knowledge of the situation (preferably the client’s Relationship Manager) is notified;

      b: Neither the employee of first contact nor the Relationship Manager is to admit liability on behalf of the Company or to apportion blame in the presence of the client. The aim here is to contain the situation until it is escalated to the next stage if required; and The complainant’s email address shall be obtained and an email acknowledging receipt of the verbal complaint shall be sent same day of receiving such complaint. Such email shall detail the nature of the complaint

      c: The client should be informed of the nearest date within which the business will revert to him on the issues in dispute.

    2. 7.1.2: In the case of written complaints

      a: The recipient of the letter must send it to Client Service Desk as soon as it is received;

      b.Client Service Desk shall immediately send out an acknowledgement to the client within 24 hours (in case of complaint received via email) and within three (3) working days (in case of complaint received via post) assuring the Client of the receipt of the complaint and the proposed date of communication of the findings on the issues raised by the complainant in the correspondence. Client Service Desk shall notify Compliance Unit of the complaint via the complaint register which is to be sent on a weekly basis(Friday COB). The Client Service Desk shall keep a Register of Complaints. The Compliance Unit will also send copies of the Complaint and the acknowledgment to the relevant Competent Authority as part of routine regulatory reporting obligation.

      c: The client should be informed of the nearest date within which the business will revert to him on the issues in dispute.

    1. 7.2: Timeline for Resolution of Complaints

      AIICO Capital’s Policy is to resolve all complaints within ten (10) working days from the date the complaint is received. After resolution of the complaint, the Company shall notify the relevant Competent Authority of the resolution of the Complaint within 2 (two) working days.

      7.3: Complaints Escalation to the Competent Authority

        7.3.1: Complaints not resolved within the time-frame of ten (10) working days shall be referred to the relevant Competent Authority within two (2) working days either by Client Service or the Complainant.

        A letter and a summary of the proceedings of events leading to the referral and copies of relevant supporting documents shall be sent to the Competent Authority. Clients are hereby notified that sanctions may be imposed by the SEC for failure to forward a summary of the proceedings within the above stated timeline.

      1. 7.3.2: If the client is not satisfied with the decision of the Competent Authority, the Complainant shall have the right to refer the Complaint to the SEC within 2 (two) working days where he/she is not satisfied with the decision of the Competent.

  2. 7.4.1.Complaints referred by Compliance Unit to the relevant Competent Authority shall be resolved within 20 (twenty) working days of receipt of the Complaint.

    The complainant shall refer the complaint to the SEC within two working days, if the decision of the Competent Authority is unsatisfactory.

    Where there is no relevant Competent Authority or client is not satisfied by the decision reached, the Complaint shall be referred to the SEC within 3 (three) working days either by the Company or the Complainant. The summary of the proceedings of events leading to the referral and copies of relevant supporting documents shall be attached to the letter to the SEC.

8: REGISTER OF COMPLAINTS

The procedure for managing client complaints is progressive in nature. Upon the completion of the first stage, the next stage shall commence and shall continue in that order until final resolution of the complaint. Note that as soon as a resolution is reached, subsequent stages of the CCM would be discontinued. The stages are outlined below;

  1. 8.1: All complaints must immediately be reported to the Head Sales & Client Services;
    1. 8.1.1: All complaints must be recorded in the Electronic Complaint Log. The Electronic Complaint Log must, at least, include the following information:
      1. a: Date of complaint;
      2. b: Complainant’s name;
      3. c: Nature of the complaint and the circumstances;
      4. d: Name of the person who is the subject of the complaint;
      5. e: The product or the services which are subject of the complaint; and
      6. f: The date and summary of the decision reached on the complaint.
      7. g: Remarks and comments
      8. h: Dates of referral to the Competent Authority and/or the SEC, as the case may be
  2. 8.2: Scope of Complaints to the Competent Authority and SEC at first instance
    1. 8.2.1: Clients shall not lodge at first instance with the relevant Competent Authority or the SEC.
    2. 8.2.2: Only complaints between Capital Market Operators and complaints against the Relevant Authority may be lodged at first instance, with the SEC.
    3. 8.2.3: Only complaints
      1. a: against a Competent Authority
      2. b: against Capital Market Operators by Regulators and or Self-Regulatory Organisations and;
      3. c: trade manipulation, accounting frauds, Ponzi schemes and such other complaints may be lodged with the SEC in the first instance.
    1. 8.3: Escalated Complaints

      In cases where the Client had already escalated the complaint to the SEC and the Company is aware, the Company will write the Regulator within two (2) working days stating that the CCM process has commenced. The Client will be notified of this and the Company will continue with the CCM process except instructed otherwise by the Regulator.

      1. 8.3.1: Investigation

        Where complaints cannot be resolved immediately at the point the Complaint is made, such complaints will be thoroughly investigated. The head of the relevant Unit or business against whom the Complaint is levied shall be notified of the Complaint (via email) by the Client Service Officer. This shall be done on the same day on which the Complaint is received.

        In all cases, the occurrence of the complaint shall be recorded in the Complaint Register by the responsible Client Service Officer within 24 hours of receipt. The issues complained about must be clearly defined and recorded. Steps taken to ensure the resolution of the complaint as well as the resolution must also be stated as soon as it occurs.

        Investigations of complaints received after 5:00pm shall be initiated latest 8:00am on the next business day. The head of the Unit against whom the complaint is lodged shall investigate the true state of affairs leading to the complaint. Investigation must be concluded within 24 hours of receipt of the email notifying the Unit head of the existence of the Complaint. If a suitable resolution is reached at this stage, it must be communicated to the following officers before the client is informed of the decision:

        1. a: Unit Head of the affected department
        2. b: Head, Internal Control
        3. c: Compliance Officer

        Communication of the decision reached to the abovementioned officers is to ensure that AIICO Capital collectively owns the decision communicated to the client.

      2. 8.3.2: Escalation

        Any unresolved complaints as well as all complaints brought to the Company’s notice by any Regulator must be escalated to the Complaint Management Committee. The Panel is expected to take one of the following actions:

        1. a: Approve the decision communicated as the appropriate resolution to the complaint. Approval can be done by Circular; or
        2. b: Further investigate all unresolved cases and decide on the best solution to the complaint.

        If a resolution cannot be reached immediately, the head of the Client Service Unit shall verbally and inwriting communicate with the offended client until a resolution is reached within the timeline stated in this Framework. All verbal communications must be transcribed and circulated amongstmembers of the Complaint Management Committee.

      3. 8.3.3: Communication of Decision

        All resolutions reached must be promptly communicated to the complainant in writing. In cases where any Regulator had been informed about the situation, such Regulator must be copied on all written correspondences to the complainant.

9: DISPUTE RESOLUTION

AIICO Capital will always seek harmonious ways to resolve clients’ complaints. The company will encourage and pursue the use of alternative dispute resolution techniques in resolving issues to avert public court cases that may create acrimony between the company and its clients. This approach will be deployed where all available measures to resolve an issue is unsuccessful. It is the responsibility of Senior Management to choose an appropriate and independent negotiator, mediator or arbitrator to mediate. Such person must be independent and shall not;

  1. a: Be a former employee of the Company;
  2. b: Perform other functions that could affect independence; and
  3. c: Be subjected to receive instructions or be influenced by the Company

10: RECORD RETENTION

AIICO Capital will always seek harmonious ways to resolve clients’ complaints. The company will encourage and pursue the use of alternative dispute resolution techniques in resolving issues to avert public court cases that may create acrimony between the company and its clients. This approach will be deployed where all available measures to resolve an issue is unsuccessful. It is the responsibility of Senior Management to choose an appropriate and independent negotiator, mediator or arbitrator to mediate. Such person must be independent and shall not;

  1. 10.1: CLIENT COMPLAINT REGISTER

    Upon resolution of client complaint, the complaint record (which includes details of how the complaint was resolved) and associated correspondence shall be retained in the records for at least 7 (seven) years from the date the complaint was received whether or not the Complaint has been resolved. The date on which the complaint was resolved must be recorded. This record will also include information on measures taken for resolution of issues logged by Clients.

11: COMMITMENT AND RESOURCES

The Senior Management shall be committed to the laid down procedures. The Senior Management shall act through the Complaint Management Committee to ensure that these procedures are integrated into the culture of the organization and monitored for compliance purposes.

The Complaint Management Committee, saddled with the responsibility of executing the terms of this policy, shall sit on ad-hoc basis, with membership comprising of representatives of the following offices:

  1. a: Head of Investment Operations
  2. b: Company Secretary/Legal Officer
  3. c: Head of Client Services
  4. d: Head of Internal Control/Internal Audit
  5. e: Compliance Officer
  6. f: Heads of Investment Units

The management shall also ensure that:

  1. a: All members of staff are educated about and familiar with the internal procedures
  2. b: Adequate financial resources are allocated to complaints management and sufficient levels of authority are delegated to handle the process
  3. c: Adequate systems are put in place and reporting procedures implemented to ensure timely, effective and consistent complaints handling and monitoring
  4. d: Reasonable steps are taken to ensure that clients know about the existence of the complaints handling mechanism and how to lodge complaints

12: REPORTING

At the end of every quarter, a status update of complaint filed with AIICO Capital shall be forwarded to the SEC.

Such report shall be sent to the SEC not later than the 20th day of a new quarter.

13: PERIODIC REVIEW OF THE FRAMEWORK

This Framework shall be subject to review annually or as recommended by the regulatory authority (SEC). The compliance and internal control unit shall be responsible for the periodic review.