Complaints Policy

At JL UNIQUE SOLUTIONS PTY LTD., our utmost priority is ensuring your complete satisfaction as our valued client. Throughout the claims process, you will have a dedicated agent assigned exclusively to handle your case and address any inquiries you may have. To ensure ease of communication, we recommend saving the contact phone number and email of your assigned agent in your phone’s contact list for quick reference. Rest assured, we are committed to providing you with exceptional service and support every step of the way.

Our Contact Information:

JL UNIQUE SOLUTIONS PTY LTD.

Attn: Claims Management / Complaints

Office Address: Design Quarter. 4 Leslie Ave. Fourways. Sandton William Nicol Dr & Leslie Ave, Magaliessig, Sandton, 2067

Email: [email protected]

Complaint Handling Department

The Complaint Handling Department is a dedicated team that will be looking into your issues and assuring the receipt of your complaint within a span of ten business days. Be advised that formal complaints can be sent to the following email: [email protected].

1. COMPLAINTS POLICY & PROCEDURE

This document sets out JL UNIQUE SOLUTIONS PTY LTD. (“JNL”) Complaints Procedure which complies with the FCA Sourcebook DISP. As a firm we are committed to treating our customers fairly and we will seek to respond to all complaints received promptly and fairly taking into consideration FCA’s Principle 12, Consumer Duty. For our complaints policy we will take into consideration the Consumers understanding and be mindful of whether or not we have already assessed them to be vulnerable (see Vulnerable Customers Policy). In addition we also need to consider what support the Customer requires when we try to deal with their complaint.

In order to ensure that complaints are fairly, consistently and promptly dealt with, the Director must be consulted in all cases, and any proposed course of action or correspondence signed off by the Director. The Director will be responsible for ensuring that any complaint is properly investigated and is done so competently, diligently and impartially and that the required timetable set by the FCA rules is adhered to.

In the event that a complaint identifies a systemic, recurring or specific problem, the Director will seek to resolve it via discussion with the team members and consumer facing staff, providing a revised written policy/methodology to avoid the repeat of any mistakes made and the implementation of any conclusions arrived at.

1.1 INVESTIGATING, ASSESSING AND RESOLVING COMPLAINTS

Our obligations under DISP are that, upon receipt of a complaint, we must:

1. investigate the complaint competently, diligently and impartially, obtaining additional information as necessary.
2. check the history file of the Customer to see if they have been assessed as vulnerable, decide on what additional support measures must be taken to ensure that the relevant form of support is provided and adequately address the Customers vulnerability, e.g., the provision of a translator if the Customer does not speak English particularly well.
3. provide the Customer with a Toll-free telephone number to call us on, so that no charges are incurred.
4. assess fairly, consistently and promptly taking into account all relevant factors:
   • the subject matter of the complaint.
   • whether the complaint should be upheld.
   • what remedial action or redress (or both) may be appropriate.
   • if appropriate, whether we have reasonable grounds to be satisfied that another respondent may be solely or jointly responsible for the matter alleged in the complaint.
5. offer redress or remedial action when we decide this is appropriate.
6. explain to the complainant promptly and, in a way that is fair, clear and not misleading, our assessment of the complaint, our decision on it, and any offer of remedial action or redress;
7. and comply promptly with any offer of remedial action or redress accepted by the complainant.

1.2 TIME BARRED COMPLAINTS

If we receive a complaint which is outside the time limit of 6 years for referral to the Financial Ombudsman Service, we may reject the complaint without considering the merits of the complaint. If we choose to reject a complaint, we must explain this to the complainant in a final response letter. However before we do this we will consider the vulnerability of the Customer and in some cases where we feel that the Customer has a serious vulnerability and if we were to dismiss the case due to time limitations it may cause harm to the Customer, we may decide to review the case if possible and offer to resolve the issue raised.

1.3 FORWARDING AND FORWARDED COMPLAINTS

If we receive a complaint but we are satisfied that the complaint actually relates to another firm, or that the complaint relates to us and another firm jointly, we will refer the matter on to that firm so that they can consider the customer’s complaint. We will do this promptly and tell the client what we have done. We will also provide the client with the other firm’s contact details.

If we receive a forwarded complaint, it will be dealt with in accordance with this policy with the time frames applying from the date the forwarded complaint was received by us.

2 COMPLAINT HANDLING

2.1 IDENTIFY THE COMPLAINT

A complaint will involve an allegation from a customer or potential customer that they have suffered financial loss, distress or material inconvenience as a direct result of JNL’s provision or failure to provide a claims management service. In the majority of cases, we expect that the issue raised will be that we did not achieve the expected level of recovery of the Customer’s money or that we took a decision which prevented the Customer from receiving the amount they expected. . In these cases, it is important that the Customers case file is complete and clearly provides an explanation of decisions taken and records any authority given by the Customer to accept an offer of redress.

If the member of staff that receives a complaint is unsure what action needs to be taken regarding the complaint, please refer it to the JNL Director.

In the event that a customer wishes to make a complaint, this can be made verbally, by telephone or in person, or via a written communication delivered in person, via post, e-mail, SMS or fax. In the first instance, the complaint should be handled by the team manager responsible for the account. Once the team manager has decided whether or not the complaint should be upheld with the relevant evidence from the case file, the team manager must present the case to the Director to sign off on the proposed response to the Customer. The Director will review the case notes and proposed response and will revert to the team manager of whether or not the response is adequate or whether it needs to be revised or reconsidered.

2.2 COMPLAINTS RESOLVED WITHIN 10 BUSINESS DAYS

When we receive a complaint we will send out an acknowledgment of receipt of the complaint within 3 Business Days. If the case file does not state whether or not the Customer has a vulnerability, we will also ask the Customer to inform us of any disabilities that they may have and whether they require additional support when we contact them. We will seek to resolve any complaints received as quickly as possible with a view to reaching agreement with the complainant within 10 business days of receipt. In the case of resolved complaints a note will be made in the customers file of any agreed course of action together with any copy of correspondence. We will then promptly send the complainant a summary resolution communication which includes the following detail:

1. refers to the fact that the complainant has made a complaint and informs the complainant that we now consider the complaint to have been resolved.
2. informs the complainant that if he subsequently decides that he is dissatisfied with the resolution of the complaint he may be able to refer the complaint to the Financial Ombudsman Service but must do so within 6 months, otherwise the Ombudsman will not have our permission to consider the complaint and so will only be able to do so in very limited circumstances.
3. provides the website address of the Financial Ombudsman Service and refers to the availability of further information on the website of the Financial Ombudsman Service.

2.3 PROCESS FOR COMPLAINTS NOT RESOLVED WITHIN 10 BUSINESS DAYS

In the event that a complaint is not capable of resolution by the close of business on the tenth business day following the day on which it was received then the team manager must provide a brief written explanation of the substance of the complaint which should be provided together with any written correspondence from the customer concerned for further consideration by the Director. At this point in time, an entry should be made in the Complaints Register and the date of receipt of the complaint recorded in the Complaints Log, an example of the format of which appears in Appendix A.

If the complaint has not been resolved by the close of business on the tenth business day, we must ensure that a copy of these internal procedures are sent to the customer making it clear that we have passed your complaint to the Director for further consideration . The name and job title of the person handling the complaint must be advised to the customer.

2.3.1 INVESTIGATION OF THE COMPLAINT

Initial investigation of any complaint will be dealt with by the original member of staff who dealt with the customer, if they no longer work for JNL then another team member will be assigned to review the complaint pending a final review and signature of the Director

2.3.2 AFTER 4 WEEKS

If a complaint has not been resolved within 4 weeks of being received, unless the customer has already indicated in writing acceptance of a response by the company (provided that the response informed the customer how to pursue his complaint if he remained dissatisfied), and in the event that a final response has not been issued, a holding response must be sent to the customer explaining why the company is not yet in a position to resolve the complaint and indicating when the company will make further contact (which must be within 8 weeks of receipt of the complaint)

2.3.3 FINAL RESPONSE

A Final Response must be made within 8 weeks of receiving the complaint.

This response sets out the final view of the company on the complaint, dealing directly with the issues the customer has raised.

It will summarise the complaint and summarise the outcome of the investigation.

The written final response must either:

1. Accept the complaint and offer appropriate redress. We must include a clear explanation of how we have arrived at this offer.
2. Reject the complaint giving the reasons behind this decision.
3. A combination of a) and b)

We must inform the customer that they have a further 8 weeks from the date of our response to respond until we consider the complaint closed.

A complaint will be deemed to be closed where the company has sent a final response or where the customer has indicated in writing acceptance of the company’s earlier response.

2.3.4 CONTENT OF FINAL RESPONSE LETTER

Our Final Response Letter must provide the complainant with full details of our understanding of the reasons for the complaint, our investigation into the circumstances behind the complaint, detailing relevant facts, our findings and whether the complaint is being upheld or not and whether any redress payment is to be offered. We will also outline any additional measures we have taken when taking into consideration any vulnerabilities that we perceived from our contact with the customer or which the customer informed us of.

Our Final Response to the client must include the following text as applicable:

• a) Where we do not agree to waive the six-month time limit for the complaint to be referred to FOS

“You have the right to refer your complaint to the Financial Ombudsman Service, free of charge – but you must do so within six months of the date of this letter.

If you do not refer your complaint in time, the Ombudsman will not have our permission to consider your complaint and so will only be able to do so in very limited circumstances. For example, if the Ombudsman believes that the delay was as a result of exceptional circumstances.

• b) The complaint was received outside of the time frames for a complaint to be referred to FOS and we do not consent to waive such time limit.

“You have the right to refer your complaint to the Financial Ombudsman Service, free of charge.

The Ombudsman might not be able to consider your complaint if:

• what you are complaining about happened more than six years ago, and
• you are complaining more than three years after you realised (or should have realised) that there was a problem.

We think that your complaint was made outside of these time limits, but this is a matter for the Ombudsman to decide. If the Ombudsman agrees with us, they will not have our permission to consider your complaint and so will only be able to do so in very limited circumstances (see below).

If you do decide to refer your complaint to the Ombudsman, you must do so within six months of the date of this letter.

If you do not refer your complaint to the Ombudsman within six months of the date of this letter, the Ombudsman will not have our permission to consider your complaint and so will only be able to do so in very limited circumstances.

The very limited circumstances referred to above include, where the Ombudsman believes that the delay was as a result of exceptional circumstances.”

• c) Where the complaint was received outside the time 6- or 3-year time limits and we do not consent to waive those time limits but do consent to waive the six-month time limit

The time limit for referring complaints to the Ombudsman is usually six months but we will consent to the Ombudsman considering your complaint even if you refer the complaint later than this.”

• d) We consent to waive all time limits.

“You have the right to refer your complaint to the Financial Ombudsman Service, free of charge. Although there are time limits for referring your complaint to the Ombudsman, we will consent to the Ombudsman considering your complaint even if you refer the complaint outside the time limits.”

Our Final Response letter must also include The Financial Ombudsman Service Leaflet

2.4 RESOLUTION

Where a complaint has been resolved, a final response should be issued to the customer, unless it was resolved by the close of business on the business day following receipt, in which case no letter need be sent. A final response is a written response from the company which accepts the complaint and, if appropriate, offers redress (appropriate redress may not involve financial redress, it may, for example, simply involve an apology); or offers redress without accepting the complaint or rejects the complaint and gives reasons for doing so, and which informs the customer that, if he remains dissatisfied with the company’s response, he may now refer his complaint to the Financial Ombudsman Service (“FOS”) which, should he wish to do so, must be done within 6 months.

2.5 RECORD KEEPING

A record of the complaint must be retained by the company for 3 years from the date of the receipt of the complaint. A report must be made to the FCA twice a year, as at 31 March and 30 September via the FCA’s Firms online electronic reporting system. This report specifies the total number of complaints received by the firm which were not settled by the close of business on the third business day after the receipt of the complaint in accordance with rule DISP 1.5.4.

2.6 STAFF ACKNOWLEDGMENT & RESPONSIBILITY

All staff are required to sign a copy of these internal complaints procedures to confirm that they have received, read and agree to be bound by the requirements placed upon them by these procedures as part of their contract of employment. Failure to comply with this policy may result in disciplinary action.