1. Introduction
1.1 Background This document outlines the policy and framework that Firenze follows to handle complaints and manage conduct risks in line with industry best practices. Firenze is committed to ensuring customers are treated fairly, and that complaint-handling processes do not create unnecessary barriers or delays. The firm’s commitment includes:
This document ensures that the Company, its management, and its employees are aware of the policy regarding disputes and their resolution. The firm strives to maintain high standards of customer service and accountability.
1.2 Purpose The purpose of this document is to set out the policy that will be adopted by Firenze in regard to ensuring any expressions of dissatisfaction (complaints) in relation to any actions and/or behaviours attributed to Firenze or anyone representing Firenze (whether directly or indirectly) are assigned appropriately and tracked to conclusion. The firm is committed to treating customers fairly and delivering fair outcomes. We recognise that from time to time things can go wrong. Consequently, customers can raise their dissatisfaction with us and it is important to put things right. It also involves Firenze considering the impact of the error and assessing whether redress is appropriate and reasonable to do so. Recognising complaints and dealing with them appropriately gives us the opportunity to:
Information and details about raising a complaint is available to all customers through our App, website and customer service channels. Complaints may be about any of the products or services we offer or those of any third parties. Firenze is committed to consistent; prompt, impartial and fair resolution of complaints by ensuring they are administered appropriately and in a timely manner and, in line with this policy, escalated appropriately to suitably experienced and competent individuals.
1.3 Approval and ownership This Policy is approved and owned by Anna Curtis (Head of Finance and Operations). This version of the Policy remains effective until it is withdrawn, or an update approved. This document will be reviewed and revised at least annually or where appropriate. Any changes to this Policy will require approval from the individual responsible for Complaint Handling. If you have any questions, require clarification or guidance on any element of this Policy, you should contact the individual responsible for Complaint Handling in the first instance. In their absence, you should contact their deputy.
1.4 Scope The general principles of this policy are applicable to how the business handles ALL customers' complaints with specific policy requirements that must be met whether or not the complaint is categorised as a regulated complaint. This policy therefore applies to:
2. Definition
2.1 Regulated complaints
Firenze considers a complaint as being any oral or written expression of dissatisfaction, whether justified or not, from or on behalf of a person (a person includes individuals and legal entities, such as companies, partnerships and trusts) about the provision of, or failure to provide, a financial service which:
2.1.1 Unregulated financial complaints An unregulated financial complaint is treated internally as though it is a regulated complaint. Firenze strives to focus on doing the right thing for customers and will not adhere to a lesser standard just because it is an unregulated product. The key difference in the policy for Unregulated Financial Complaints, however, is that the customer does not have the ability to complain to the FOS so we add an additional internal step for escalation: the final response to a Complainant should state that they can refer the complaint to the Head of Clients if they are still unsatisfied after the final response. The Head of Clients will then have discretion over to how to handle the complaint. 2.2 Eligible complainants Firenze considers an eligible complainant to be:
3. Complaint handling procedures and consumer awareness
3.1 Procedures Firenze will establish and operate appropriate and effective complaint handling procedures for:
3.2 Complaint handling principles All complaints will be handled in line with the following principles:
3.3 Handling Timescales Firenze strives to resolve complaints at the earliest opportunity from when they are first recognised. It is the intention of the firm to handle complaints at the first point of contact and to have robust systems and controls in place to manage them on an ongoing basis. If the complaint cannot be resolved or handled at first point of contact, the firm will aim to resolve it by close of business on the third business day following receipt. Where a complaint has been resolved within this timeframe, the complainant will be issued with a Summary Resolution Communication (SRC), summarising that their concerns have been addressed and confirming the next steps. Complaints resolved during this period will be considered to have been resolved ‘informally’ and in line with the Complaints handling process. Where the complaint is not resolved within 5 working days an acknowledgment letter will be issued promptly to the customer containing a copy of the firm’s Complaint Procedures. The complainant will be kept informed of any investigation and about the outcome of the complaint within 8 weeks. At this point the complainant will be issued with either a final
response, or written response explaining why the firm is not able to provide a final response and when we expect to do so.
3.4 Forwarding Complaints Where the firm has reasonable ground to believe that another firm may be solely or jointly responsible for a regulated complaint, it will promptly forward the relevant part of the complaint to the other firm, and ensure that by forwarding any complaints we:
3.5 Redress Redress is effectively how we put the customer back in the position they would have been in, had the event complained about not happened. This will often include offering the customer a payment in recognition of financial loss. However it may be appropriate, depending on the circumstance, to consider other types of redress. The firm defines redress under the following categories:
4. Principles Information, communication and training
4.1 Complaint Principles Firenze is committed to delivering fair outcomes for all customers that choose to make a complaint and will:
Perform root cause analysis to identify and rectify causes of complaints; We take responsibility for our errors and openly admit when we are at fault. We uphold accountability for our mistakes and maintain transparency in our interactions with customers. We are committed to keeping customers informed, providing regular updates, and ensuring fairness in addressing the reasons behind a complaint.
4.2 Communication General Firenze will provide adequate communication of this policy to ensure that all staff maintain adequate awareness and knowledge of it. It is expected that all staff from Senior Management to Administrators are able to identify any complaint they may receive and escalate appropriately. Clear instructions will be provided to all users to ensure that standards are complied with.
4.3 Complaint handling staff All staff dealing directly with complaints must be competent to undertake the role. Competence must be attained and maintained, with appropriate evidence. Complaint Handling staff must act independently and must be of sufficient seniority within our firm. They will be responsible for and deal with all complaints received, and have the authority to settle complaints (including, where appropriate, the offering of redress).
6. Record keeping
6.1 Retention requirements All complaints must be logged on the complaints register immediately and updated accurately as the investigation progresses. We will keep a record of each complaint received and the measures taken for its resolution, and retain that record for 3 years from the date the complaint was received or in accordance with the Document Management, Retention and Destruction Policy, whichever is the longer. Should there be any communication with internal or external counsel (Privileged communications) relating to a case, these will be held separately by our Legal Counsel for as long as required.
6.2 Accessibility of records All records will be retained in a format that:
As Firenze maintains its records in electronic form, we will take reasonable steps to ensure that:
7. Complaint Monitoring The firm will ensure that quality assurance checks are undertaken to ensure the handling of customer complaints consistently delivers fair outcomes for customers and the competence of complaint handlers is maintained. The Quality Assurance framework will ensure:
The second line compliance team will undertake periodic monitoring of complaints handling and of, the first line quality assurance activities undertaken.
8. Root cause and management
8.1 Root cause analysis (RCA) A full analysis of complaints received will be undertaken in order to identify whether any lessons can be learned, such as whether existing processes aren't working, whether additional training is needed or a business or process change is required. (Refer to complaint procedures for more detail) In addressing every identified complaint, our objective is to gain a comprehensive understanding of the incident, considering the specifics of what occurred and the underlying reasons. We acknowledge that issues may arise despite our preventive efforts, and we maintain a culture that refrains from assigning blame. Instead, we approach investigations with a collaborative mindset and a sincere commitment to improvement. Our focus is on learning from incidents, fostering a culture of continuous enhancement and a genuine desire to improve our organisation. 8.2 Management information (MI) Appropriate MI relating to complaints received, their root causes and how they're handled will be collected and reviewed by senior management. MI will not simply focus on high-level data, but also on areas such as:
MI will be able to evidence the root causes identified, underlying specific complaints or any systemic compliance failures. Where the complaints records show a trend, we will consider the position of other clients who may also have cause to complain but haven’t.
9. Senior management oversight Firenze’s senior management is responsible for the implementation of the complaint handling policy, associated procedures and for monitoring compliance with them. Firenze will allocate responsibility for overseeing our complaint handling to a senior manager within our business. This will be documented in their statement of responsibilities. As part of their oversight role, this person will ensure we comply with the following:
In addition to the above, senior management is responsible for establishing a “complaints function”, which is accountable for the investigation of complaints – this will be proportional to the size and complexity of Firenze and the number of complaints received.
10. Policy breaches
10.1 Non-compliance Non-compliance, whether deliberate or not, of any point within this policy will be treated as a disciplinary matter.
10.2 Reporting If any individual becomes aware, whether directly or indirectly, of any instances of non- compliance or potential instances of non-compliance (whether deliberate or not) with this policy, they must be reported to the appropriate Senior Manager responsible for Complaint Handling.
10.3 Failing to report
If any individual fails to report a known breach of this policy, disciplinary action could be instigated.
11. Associated policies and documents
This policy is approved by the Firenze Board and in implementing this policy, the Board has delegated executive responsibility for the Head of Finance & Operations. The owner of this policy will ensure that the policy is implemented in practice and will inform the owners of other impacted policies where new or significant changes are made to this policy. This policy and future changes will be communicated via internal communication channels to key stakeholders. The owners of related policies must undertake the required review and any subsequent amendments to their own policies to ensure they are aligned with this policy. The implementation of this policy will be supported through ongoing training, the associated business standards and procedures and relevant systems and controls. The governance framework and oversight activities will provide assurance that colleagues understand their responsibilities.
