RBS Group Guidelines for Effective Complaints Handling
RBS, in the interests of transparency to its clients, makes its internal complaint handling procedures available on its website.
Overview
It is important when dealing with complaints from clients that we maintain a positive attitude towards resolving the complaint. Our complaints handling policy is based on the premises that:
1. a client has a right to complain and have a complaint handled;
2. complaints provide feedback about product or service experience; and
3. a complaint received gives the organisation the opportunity to maintain confidence in our product or services.
Complaint Handling
Complaint Handling is viewed by ASIC as an important responsibility of all licensed entities. Licensees are required to have the necessary procedures in place to ensure their clients have adequate avenues to lodge a complaint. The extent of a Licensee’s procedures will depend upon whether their Financial Services are provided to Retail or Wholesale clients (please see specific Business Unit Procedures).
It is critical that a Retail client who makes a complaint is made aware of their right to take their complaint to the appropriate External Dispute Resolution (“EDR”) scheme if the matter cannot be solved internally. The Compliance Department will provide the appropriate membership details when required.
Handling a client’s complaint efficiently needs patience and skill to avoid an initial “negative” situation becoming even more negative and degenerating into a dispute. Communication with the client in a manner that acknowledges and empathises with the client’s feelings is a key element in minimising potential dispute.
The following are general guidelines for processing written or oral (telephone) complaints:
Verbal Complaints
The steps are:
a) identify yourself, listen, record all details and determine what the client wants;
b) confirm the details received;
c) acknowledge the client’s feelings and empathise with the client in a courteous manner;
d) explain the courses of action available, ie that the complaint will be sent to the Head of the Business Unit and to the Compliance Department;
e) do not attempt to lay blame and do not be too defensive at this stage;
f) ensure that the client is informed that the complaint is receiving attention and the likely response time for the client to receive an update on the progress of the complaint;
g) set a timeframe and take action to gain a resolution within the timeframe; and
h) report the complaint to the Head of the Business Unit and the Compliance Department.
If the client is not satisfied with the outcome, you should advise the client to put their complaint in writing.
Written Complaints
The same procedures as for oral complaints outlined in (a) to (g) should be followed and a written response that we are investigating the complaint should be given immediately.
When a written complaint is received from a client, the employee must give the letter promptly to Compliance. Compliance will require the staff member responsible for the client’s account and/or any other appropriate person to make a report to Compliance on the subject of the complaint.
Specific Business Unit Procedures
The below Business Units need to adhere to the following guidelines:
- RBS Australia
- RBS Group (Australia) Pty Limited
- Equities Business
- RBS Nominees (Australia) Pty Limited
- RBS Funds Management Australia
- The Royal Bank of Scotland N.V., Australian branch
Complaints received by the above entities listed above are required to follow a two-step procedure. First, to attempt to resolve the complaint through internal guidelines (set out above). Secondly, to advise any retail client of their right to utilise the external complaints scheme (see below).
RBS is required to be a member of an external complaint-handling scheme where Financial Services are provided to retail clients, whereby if the internal resolution fails to resolve the complaint, the client has recourse to the external scheme. The client must be informed of their right to utilise the external complaint handling scheme. The scheme, of which RBS is a member, is run by the Financial Ombudsman Service or FOS.
(Please contact the Compliance Department to gain relevant Membership details for your entity).
Complaints Register
The Compliance Department maintains the ‘Complaints Register’ for all client related complaints. RBS is required to keep a Register of all complaints and replies. All complaint details should be forwarded to Compliance as soon as possible.
It can be difficult sometimes to distinguish a complaint from a client’s concern or comment. For practical purposes, Compliance considers there to be a complaint after one level of escalation. So if the matter is not resolved by the business at first instance the matter must be escalated to Compliance. Compliance will ensure complaint details are recorded in the Complaints Register.
Equities
RBS Equities is required to maintain a Register of Complaints under the ASX Business Rules. Any complaints should be promptly reported to the Head of Equities, and the report/letter(s) sent to the Compliance Department who maintains the Register.
RBS Funds Management
RBS Funds Management maintains a separate Complaints Register, which also has details about reportable and non-reportable breaches and other compliance incidents.
Compliance Department contact details
Level 29, RBS Tower
88 Phillip Street
SYDNEY NSW 2000
Contact: Oliver Bainbridge, Director, Regulatory Risk and Compliance
Tel: (02) 8259 6060
Email : oliver.bainbridge@rbs.com
These Guidelines are in accordance with the Australian Standard AS ISO 10002-2006 for Complaints Handling and comply with ASIC’s RG165.
Version: 4.0 1 Jan 2010