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Version 1.0 – July 2022
Copyright © 2022 Greener
All Rights Reserved
The digital version of this document is the most recent version. It is the responsibility of the individual to ensure that any printed version is the most recent version. The printed version of this document is uncontrolled and cannot be relied upon.
Introduction
Terms and Definitions
Scope
This document outlines our arrangements for dealing with client complaints or disputes in a genuine, prompt, fair and consistent manner. Our IDR will offer:
a) The opportunity to resolve complaints or disputes quickly and directly
b) The ability to identify and address recurring or systemic problems (which can then lead to product or service improvements)
c) The capacity to provide solutions to problems rather than have remedies imposed by an external body
d) The chance to improve levels of customer and investor confidence and satisfaction
e) The ability to solve complaints or disputes directly with clients, so that a complaint or dispute is dealt with at the earliest possible stage following IDR procedures
f) Informing complainants about the availability and accessibility of the relevant external dispute resolution scheme
Responsibilities
Managers and supervisors are responsible for the implementation of these arrangements within the scope of their responsibilities and must ensure that all staff under their control understand and undertake their responsibilities accordingly.
IDR Principles
Visibility
We will take necessary steps to ensure customers know about the existence of our IDR procedure and how to make a complaint. This visibility can be demonstrated by:
Commitment
We are actively committed to effective and efficient complaint and dispute handling. This commitment can be demonstrated by:
Ensuring all relevant staff are aware of and educated about IDR procedures
Ensuring that adequate resources are allocated to IDR
Implementing management systems and reporting procedures to ensure timely and effective complaint or dispute handling and monitoring
Resources
We ensure the arrangements for making complaints or disputes are simple and accessible. Information about making and resolving complaints or disputes is easy to understand and is in plain English. A link to this IDR Policy is also provided in on our website (Greener - Awarded #1 cleantech start-up in Australia ) and other digital assets (e.g. mobile application, cloud-based merchant portal). We provide the following medium to submit complaints or disputes.
Responsiveness
We will respond to complaints or disputes promptly in accordance with the urgency of the complaint or dispute. We endeavour to acknowledge receipts of complaints within 24 hours, but where that is not possible, the acknowledgement will be made as soon as practicable.
We will respond in writing unless you instruct us to respond by other means.
Some complaints can be resolved very quickly, and we will endeavour to provide a response within 7 days. Frequently, complaints are simply cases of confusion or misunderstanding which can be sorted out to everybody’s satisfaction very quickly. However, circumstances may require a longer period for us to respond. We will continue to communicate relevant information during the resolution process and will let you know after 14 days if the issue is complex and requires more time.
We will work to provide an IDR response to a complainant no later than 30 calendar days after receiving the complaint. The 30-day timeframe begins on the day that the complaint is received, regardless of whether the day of receipt is a business day. ‘Day 1’ is the first calendar day after the we have received the complaint.
Situations where we may not be required to respond within 30 days include situations where there is no reasonable opportunity for us to provide the IDR response within the timeframe because of the resolution is particularly complex or circumstances beyond our control are causing delays. In such circumstances, before 30 days we will inform you about the reasons for the delay, your right to complain to AFCA, and contact details for AFCA.
In circumstance where we are unable to respond to a complaint or dispute with 30 days, we will advise the reason for the delay as well as your right to complain to AFCA along with their contact details.
Objectivity
Collecting Information
We have established a recording system for managing complaints/disputes while protecting personal information and ensuring complainant or disputant confidentiality. The system specifies the steps for identifying, gathering, maintaining, storing, and disposing of records. It records information on complaints or disputes handling and takes the utmost care in maintaining and preserving such items as electronic files and magnetic recording media. However, no personally identifiable information is stored in our system.
We will ask that you include the following in your complaint or dispute:
Investigation of Complaints
All complaints/disputes are classified and then analysed to identify systematic, recurring, and single incident problems and trends. This helps in eliminating the underlying causes of complaints/disputes. To do this, it will be important to be able to analyse complaints or disputes according to categories, such as type of complainant, subject of the complaint, outcome of a complaint, and timeliness of response.
Responses
The level of detail in our IDR response to a complaint or dispute will reflect the complexity of the complaint and the nature and extent of any investigation conducted by us. While we strive for transparency we cannot provide or confirm information that would serve as a breach Greener’s privacy or other legislative obligations.
We will notify you by phone or email to notify you that the Internal Dispute Resolution (IDR) process has concluded. Your response will include:
Rejection of complaints or disputes
If we reject or partially reject the complaint, the response will clearly set out the reasons for the decision by:
a) Identifying and addressing the issues raised in the complaint
b) Setting out our findings on material questions of fact and referring to the information that supports those findings
c) Providing enough detail for you to understand the basis of the decision and to be fully informed when deciding whether to escalate the matter to AFCA or another forum
Multi-tiered IDR responses
Any complaints that can’t be resolved by a Customer Success Manager, Customer Support Manager, or another similar customer-facing role, will be escalated immediately to Information Security Manager. That individual will work with the Company employee who first received the complaint, as well as any other employees who are chosen to be included, to investigate that complaint and prepare an IDR response. That group of employees will then decide who will deliver the IDR response to the consumer. This multi-tiered IDR response process does not affect the Company’s complaint response timelines, and a response will be delivered as quickly as possible to the consumer and not later than 30 days.[NM7]
Timeframes
Greener will
The responsible manager will:
a) record details of all complaints and responses in the Complaints Register (Appendix 2) including the date they are received and the date of the response.
b) provide a final written response to standard complaints within 30 days2 (21 days for disputes involving default notices) after receiving the complaint.
In our pursuit of best practice, we will always endeavour to outperform the established timeframes whenever possible. Where we conclude complaints within five business days,4 no IDR response will be provided unless requested by the complainant (or where other exceptions5 apply). Despite our best endeavours, there are many variables that can affect complaint response times, which include the complexity of the issues raised, the availability of information (including from third parties) and other circumstances beyond our control.
Where such circumstances give rise to complaint management delays, we will provide the complainant with an ‘IDR delay notification’8 prior to the expiration of the relevant IDR timeframe. This will inform the complainant about the reasons for the delay; their right to complain to AFCA if they are dissatisfied; and the contact details for AFCA as outlined below (under External Dispute Resolution).
Documenting
We maintain adequate documentation to:
All conversations are logged and tracked to ensure processes are followed in-line with policy.
All complaints will be received either in writing via our CRM Hubspot. The employee receiving the complaint will determine if that complaint relates to financial or CDR data, and if so will document it for tracking in our CDR Complaints Database, managed in a secured Excel file internally within the Company. Only customer success and support staff as well as [xxx] will have access to that file.
The table in the file has the following column headings:
Charges
We ensure:
Confidentiality
We ensure the confidentiality of the information. Our data handling policy is transparent with no transactional Personal Identifiable Information (PII) stored in the system.
Continual Improvement
The continual improvement of the complaints or disputes handling process and the quality of products and services we offer is one of our central objectives. This involves conducting regular reviews of IDR procedures to identify areas for improvement. We consider that reviews should be conducted at least every two years to ensure that the complaints or disputes system is operating effectively.
Managing Systemic Issues
The Board of Directors of the Company (“Board”) will periodically review reports, metrics, and analysis of consumer complaints to identify and address systemic issues, as well as improve overall consumer satisfaction and company sustainability. The Board has identified [xxx] as the accountable person responsible for handling all complaints and their resolutions, and for managing systemic issues identified through consumer complaints.
The Board also encourages all staff to escalate any possible systemic issues they have identified from consumer complaints to their managers, who must then escalate those issues to [xxx] for investigation and action. The Company will regularly review these complaints to identify systemic issues, and report on the outcome of their investigations, including actions taken, in a timely manner. When systemic issues have been identified, the Company will take quick action to identify affected consumers and provide fair remediation.
Customer-focused approach
We adopt a customer-focused approach which involves being open to customer feedback, offering customer helpful and user-friendly response in plain English. We will show commitment to resolve complaints or disputes by its actions.
IDR Process, Complaint Types, Reponses
The below sets out the overall process for handling complaints and disputes.
Step 1 – Complaint Received
Complaint received via Hubspot or phone call and key data recorded in CDR Complaints Database.
Step 2 – Complaint Acknowledged
Written or verbal message sent to complainant confirming receipt and indicating estimated timetable to resolution. We may organise a meeting with you to talk through and better understand the issue, including the right Greener team members in relation to the complaint.
Step 3 – Assess Complaint
Complaint reviewed in detail, to evaluate whether an immediate resolution is possible, further investigation is required, or if the complaint needs to be escalated. In the event of a security or data complaint, the Information Security Manager (ISM) must be informed.An assessment of the risk to our services and ISMS should be carried out where it makes sense prior to escalating any dispute, and contingency actions should implemented where needed
Step 4 – Investigate
If no immediate resolution available in Step 3, issue is investigated by 1 or more personnel to understand key issues, severity, and potential resolutions. Internal discussions held to gather further information. Where needed, legal advice will be obtained. Evidence and analysis is documented.
Step 5 – Make Determination
Once all relevant information gathered and analysed, a determination is made and approved by the appropriate person. Decisions are recorded.
Step 6 – Resolve
Any resolution determined in Step 5 is enacted. If it is determined to be a systemic issue it is escalated within the Company.
Step 7 – Inform Complainant
Resolution shared with complainant, including the details of any appropriate remedies. Details of how the complaint can be escalated to AFCA are also shared. Correspondence is in writing via email however there could also be a phone call, video call or in person meeting depending on the nature of the complaint.
Step 8 – Document
Details of the resolution, remedies, communication with complainant, and any other pertinent issues documented in the CDR Complaints Database.
Complaint Types
Section to be created if and when complaints are received, to assist with triaging and resolution.
Potential Solutions
Section to be created if and when complaints are resolved, to assist with timely and complete resolutions.
External Dispute Resolution
Australian Financial Complaints Authority (AFCA)
Complainants and consumers have the right to refer to our ASIC approved External Dispute Resolution provider, AFCA, for both resolved and unresolved complaints. This is a free service established to provide an independent mechanism to resolve specific complaints. Details for AFCA will be provided to all complainants.
Complaints may be submitted to AFCA in the following ways:
Greener’s AFCA membership number is [to be inserted once Greener is an Accredited Data Recipient and receives AFCA membership].
Neil McVeigh is Greener’s EDR Manager and System Issues Contact. His email is neil@getgreener.com.
We may, at our own election, decide to refer the complaint to AFCA. This may happen when, for instance, we have provided a response as per this policy and the complaint remains unresolved and you have not referred to AFCA. In such circumstances we will first seek your consent as per RG 267.99.
This process is in line with Regulatory Guide 267 Oversight of the Australian Financial Complaints Authority (RG267) detailing how ASIC will perform its oversight role in relation to AFCA.
The Office of the Australian Information Commissioner (OAIC)
Complaints involving your Privacy/ Consumer Data Right (CDR), and how we have handled your personal information, are addressed by the OAIC. Privacy complaints can be lodged online or by contacting the OAIC using the details below:
Breach of Policy
We will take all necessary measures to remedy any breach of this policy including the use of our disciplinary or contractual processes where appropriate.
Appendix 1 – Public Facing Copy
Raising Issues
We’re human, and sometimes we make mistakes. If you feel that we have messed up please reach out and tell us about your issue. We find that chatting is the fastest way to resolve complaints*. Our internal dispute resolution process is easy to access and if free of charge.
Get in touch
If you’d like to get in touch with us, or need help submitting a complaint or dispute, you can reach us in any of the following ways:
What to include when you contact us
We’ll be able to help you better and quicker if you can include the following when you contact us:
Our response times
We will acknowledge the receipt of complaints or disputes promptly, in most cases within 1 business day. We will respond in writing unless you instruct us to respond by other means.
Frequently, complaints are simply cases of confusion or misunderstanding which can be sorted out to everybody’s satisfaction very quickly. For more complex issues we will continue to communicate relevant information during the resolution process and will let you know after 14 days if the issue requires more time. We commit to responding fully to a complainant no later than 30 calendar days after receiving the complaint.
In circumstance where we are unable to respond to a complaint or dispute with 30 days, we will advise the reason for the delay, your right to complain to the Australian Financial Complaints Authority (AFCA – see contact details below), and AFCA’s contact details.
Our investigation and review process
Complaint we receive are first handled by our Customer Success team, who will provide the initial acknowledgement of receipt. They may also organise some time to talk through and better understand the issue, and they will include the right Greener team members in relation to the complaint.
The assigned team members then define next steps and, where needed, legal advice will be obtained. They will contact you via email; however there could also be a phone call, video call or in-person meeting depending on the nature of the complaint and your communication preferences.
In the event of a security or data complaint, the Information Security Manager must be informed that a dispute exists. An assessment of the risk to our services and Information Security Management System (ISMS) will be carried out where it makes sense prior to escalating any dispute, and contingency actions should implemented where needed.
All conversations are logged and tracked to ensure processes are followed in-line with policy.
The response you’ll receive
We will notify you by email, or your preference contact method, to notify you that the Internal Dispute Resolution (IDR) process has concluded. The response will include the final outcome of the complaint - either confirmation of actions taken by the firm to fully resolve the complaint or reasons for rejection or partial rejection of the complaint. The response will also include details of your right to take your complaint to AFCA (Australian Financial Complaints Authority) if you are unhappy with the decision, as well as AFA’s contact details and Greener’s membership details.
The External Dispute Resolution (EDR) Process
Should you not be satisfied with the IDR decision, or your complaint is not resolved within 30 days from us receiving it, you can initiate an EDR process with Australian Financial Complaints Authority (AFCA). We are a member of the AFCA, membership number for Greenr Global Pty Ltd is [xxx].
You can contact AFCA on:\
Keen to know more?
You can access our full Internal Dispute Resolution (IDR) policy here.
*From the lawyers: a 'complaint' is defined as "an expression of dissatisfaction made to an organisation or a CDR representative of a CDR participant, related to its products or services, or the complaints handling process itself, where a response or resolution is explicitly or implicitly expected."