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Your information, including Personal Data, may be transferred to and maintained on computers located outside of your province, country or jurisdiction where the data protection laws may differ from those in your jurisdiction. If you are located outside South Africa and choose to provide information to us, please note that we transfer the data, including Personal Data, to our service providers in South Africa and process it there.

You consent to this Privacy Policy by your navigation of our website followed by your submission of such information and in the alternative, continued use of our Service represents your agreement to the transfer of information.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Legal Requirements

We may disclose your Personal Data in good faith when we believe that such action is necessary:

To comply with a legal obligation

To protect and defend the rights or property of Trigger Business Process Outsourcing SA(Pty) Ltd

To prevent or investigate possible wrongdoing in connection with the Service

To protect the personal safety of users of the Service or the public

To protect against legal liability

The security of your data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Our Service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18 unless required to do so by law and as part of an expressly stated mandate. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take steps to remove that information from our servers.

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page under a sequential version number and effective date.

We will let you know via a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Trigger BPO SA (Pty) Ltd Reg no:2021/400710/07 is a business process service provider, offering infrastructure, people, and process management for our client base. Ashley Van Niekerk is a key individual of the FSP and as such participates in the decision making and management of the organisation.

POLICY STATEMENT

The company welcomes complaints and looks upon them as an opportunity to learn, adapt, improve and better service delivery. This policy is intended to ensure that complaints are dealt with properly and that all complaints or comments by customers are taken seriously.

The company supports the concept that most complaints, if dealt with early, openly and honestly, can be resolved between the complainant and the company. If this fails, dissatisfied clients’ complaints will be referred to the relevant Ombud, which may lead to reputational risk and loss of profit for the company.

The aim is therefore to ensure that the complaints procedure is properly and effectively implemented, and that customers are confident that their complaints and concerns are listened to and acted upon promptly and fairly.

COMPLAINTS MANAGEMENT FRAMEWORK

1. Definitions
2. Complaints management process
   • Procedure for lodging a complaint
3. Allocation of responsibilities
4. Categorisation of complaints
5. Complaints escalation and review process
6. Decisions relating to complaints
7. Record keeping, monitoring and analysis of complaints
8. Communication with complainants

1. Definitions:

“Client query” means a request to the company or the company’s service supplier by or on behalf of a client, for information regarding the company’s financial products, financial services or related processes, or to carry out a transaction or action in relation to any product or service.

“Complaint” means an expression of dissatisfaction by a person to a company or, to the knowledge of the company, to the company’s service supplier relating to a financial product or financial service provided or offered by a financial services provider (FSP) which indicates or alleges, regardless of whether such an expression of dissatisfaction is submitted together with or in relation to a client query, that –

• the FSP or its service provider has contravened or failed to comply with an agreement, a law, a rule, or a code of conduct which is binding on the FSP or to which it subscribes;
• the company or its service provider’s maladministration or willful or negligent action or failure to act, has caused the complainant harm, prejudice, distress or substantial inconvenience; or
• the company or its service provider has treated the complainant unfairly

 “Complainant” means a person who submits a complaint and includes a –

• Client;
• Person nominated as the person in respect of whom a product supplier should meet financial product benefits or that persons’ successor in title;
• Person whose life is insured under a financial product that is an insurance policy;
• Person that pays a premium or an investment amount in respect of a financial product;
• Member;
• Person whose dissatisfaction relates to the approach, solicitation marketing or advertising material or an advertisement in respect of a financial product, financial service or related service of the company,

who has a direct interest in the agreement, financial product or financial service to which the complaint relates, or a person acting on behalf of a person referred to in (a) to (f).

“Compensation payment” means a payment, whether in monetary form or in the form of a benefit or service, by or on behalf of the company to a complainant to compensate the complainant for a proven or estimated financial loss incurred as a result of the company’s contravention, non-compliance, action, failure to act, or unfair treatment forming the basis of the complaint, where the company accepts liability for having caused the loss concerned, but excludes any –

• Goodwill payment;
• Payment contractually due to the complainant in terms of the financial product or financial service concerned; or
• Refund of an amount paid by or on behalf of the complainant to the company where such payment was not contractually due;

and includes any interest on late payment of any amount referred to in (b) or (c).

“Goodwill payment” means payment, whether in monetary form or in the form of a benefit or service, by or on behalf of a company to a complainant as an expression of goodwill aimed at resolving a complaint, where the company does not accept liability for any financial loss to the complainant as a result of the matter complained about.

“Member” in relation to a complainant means a member of a –

• Pension fund as defined in section 1(1) of the Pensions Fund Act, 1956 (Act 52 of 1956);
• Friendly society as defined in section 1(1) of the Friendly Societies Act, 1956 (Act 25 of 1956)
• Medical scheme as defined in section 1(1) of the Medical Schemes Act, 1998 (Act 131 of 1998); or
• Group scheme as contemplated in the Policyholder Protection Rules made under section 62 of the Long-term Insurance Act, 1998, and section 55 of the Short-term Insurance Act, 1998.

“Reportable complaint” means any complaint other than a complaint that has been –

• upheld immediately by the person who initially received the complaint;
• upheld within the FSP’s ordinary processes for handling client queries in relation to the type of financial product or financial service complained about, provided that such process does not take more than five business days to complete from the date the complaint is received; or
• submitted to or brought to the attention of the FSP in such a manner that the FSP does not have a reasonable opportunity to record such details of the complaint as may be prescribed in relation to reportable complaints.

“Upheld” means that a complaint has been finalised wholly or partially in favour of the complainant and that:

• the complainant has explicitly accepted that the matter is fully resolved; or
• it is reasonable for the company to assume that the complainant has so accepted; and
• all undertakings made by the company to resolve the complaint have been met or the complainant has explicitly indicated its satisfaction with any arrangements to ensure such undertakings will be met by the company with a reasonable time acceptable by the complainant.

2. Complaints management process:

The policy seeks to ensure that the following process in terms of complaints is followed

1. Customers are aware of how to complain, and provides a platform for complaints to be registered;
2. Ashley Van Niekerk will be responsible for the administration of the procedure;
3. Every written complaint will be acknowledged in writing within seven working days;
4. Investigations into written complaints are held within 28 days;
5. All complaints will be responded to in writing;
6. Complaints are dealt with promptly, fairly and sensitively with due regard to the concern of the customer;
7. Details of the complaint will be recorded for implementing required changes to the policy of FSP in dealing with customers to mitigate and/or avoid future complaints.

The Board will be responsible for the adoption and regular review of this policy. It will ensure that the policy is readily available to customers and on the company’s website.

The Complaints Management Policy will be readily available to all staff, representatives and service providers involved in marketing, distributing, providing or administering the firm’s products or services or interacting with customers or prospective customers in any way, who will be appropriately and adequately trained on its provisions.

Responsibility for oversight, implementation and monitoring of the CMP is allocated to an individual who has the appropriate level of authority, competence and resources to ensure that the CMP is adhered to fairly, objectively and transparently and that any conflicts of interest are identified and mitigated. This function may be delegated to an appropriately constituted committee, although the senior Key Individual will remain accountable for the delegated function and may assign the responsibility for handling of specific complaints to appropriately trained staff for efficient handling.

Delegation should be to staff who are adequately trained and have an appropriate mix of experience, knowledge and skill in complaints handling, in the relevant complaints subject matter, in the principles of TCF, and in relevant legal and regulatory provisions. The organisational structure will also ensure that such staff are not conflicted and are empowered to make impartial decisions or recommendations.

All employees of the company to whom the responsibility has been assigned to handle the complaint will be aware of the Complaints Resolution Policy and Procedure. Responsibility is placed on all line managers to ensure that their employees are fully aware of and understand this policy.

Complaints Procedure – Lodging a complaint

Complaints should be lodged to:

• Trigger BPO SA (Pty) Ltd
• Email: complaints@triggerps.com
• Address: 11^th floor 19 AM, 19 Ameshoff Street, Braamfontein, 2001
• Postal Address: Trigger Customer Care, P O Box 72361 Parkview 2122

Complaints will be submitted in writing and contain all relevant information. Copies of all relevant documentation must be included.

If the complaint is made via telephone, the employee will request the complainant to lodge the complaint in writing (at least on an e-mail). Investigation of the complaint will only begin once the complaint has been received in writing by the company. The complainant will be advised of this.

Once a complaint has been lodged

• The relevant employee will immediately refer the complaint to the Manager once he/she has received the complaint in writing from the complainant. The employee will also provide the complainant with the contact details of the Manager;
• The Manager will acknowledge receipt of the complaint in writing within 48 hours of receipt of the complaint. The acknowledgement of receipt will include the contact particulars of staff to be involved in the resolution of the complaint as well as indicative and, where applicable, prescribed timelines for addressing the complaint. The complaint will be entered into the complaints register;
• If necessary, further details should be obtained from the complainant;
• After receipt and recording of the complaint, the Manager will forward the complaint as soon as practically possible to the relevant staff appointed to consider its resolution and ensure that:
• The complaint receives proper consideration and appropriate management controls are available to exercise effective control and supervision of the consideration process;
• Immediately on receipt of the complaint, the organisation should launch an investigation and within 28 days should be in a position to provide a full explanation to the complainant, either in writing or by arranging a meeting with the individuals concerned.
• If the issues are too complex to complete the investigation within 28 days, the complainant should be informed of any delays.
• The complainant is informed of the results of the consideration;
• The Manager will inform the complainant of the results of the consideration process within 2 (two) weeks of the date of receipt of the initial complaint from the complainant;
• Where a complaint is resolved in favor of the complainant, the company will ensure that a full and appropriate level of redress is offered to the complainant without any delay;
• Where the complaint is not resolved in favor of or to the satisfaction of the complainant, the Manager will send a letter to the complainant that addresses all the issues and which sets out the reasons for the decision and which states that the complainant may refer the complaint to the relevant Ombud if the complainant wishes to pursue the complaint, together with the contact details of the Ombud; and
• The complainant should do so within 2 months of receipt of such information;
• The company will co-operate fully with the offices of the Ombud to ensure that a suitable redress is provided to the complainant.

3. Allocation of responsibilities:

The Board of directors, or in the absence of a board, the governing body and key individuals of the FSP, excluding a representative, is responsible for effective complaints management and will approve and oversee the effectiveness of the implementation of the FSP’s complaints management framework.

Any person that is responsible for making decisions or recommendations in respect of complaints generally or a specific complaint will –

• Be adequately trained;
• Have an appropriate mix of experience, knowledge and skills in complaints handling, fair treatment of customers, the subject matter of the complaints concerned and relevant legal and regulatory matters;
• Not be subject to a conflict of interest; and
• Be adequately empowered to make impartial decisions or recommendations.

4. Categorisation of complaints:

The FSP will categorise reportable complaints in accordance with the following minimum categories –

• Complaints relating to information provided to clients;
• Complaints relating to advice;
• Complaints relating to financial product or financial service performance;
• Complaints relating to service to clients, including complaints relating to premium or investment contribution collection or lapsing of a financial product;
• Complaints relating to financial product accessibility, changes or switches, including complaints relating to redemptions of investments;
• Complaints relating to complaints handling;
• Complaints relating to insurance risk claims, including non-payment of claims; and
• Other complaints.

The FSP will in addition to the categorisation set out above; consider additional categories relevant to its chosen business model, financial products, financial services and client base that will support the effectiveness of its complaint management framework in managing conduct risks and effecting improved outcomes and processes for its clients.

The company must categorise, record and report on reportable complaints by identifying the category to which a complaint most closely relates and group the complaints accordingly.

5. Complaints escalation and review process

The FSP will establish and maintain an appropriate internal complaints escalation and review process.

Procedures within this process should not be overly complicated, or impose unduly burdensome paperwork or other administrative requirements on complaints.

The complaints escalation and review process should –

• Follow a balanced approach, bearing in mind the legitimate interests of all parties involved including the fair treatment of complainants;
• Provide for internal escalation of complex or unusual complaints at the instance of the initial complaint handler;
• Provide for complainants to escalate complaints not resolved to their satisfaction; and
• Be allocated to an impartial, senior functionary within the FSP or appointed by the FSP for managing the escalation or review process of the insurer.

6. Decisions relating to complaints:

Where a complaint is upheld, any commitment by the FSP will be carried out with undue delay and within any agreed timeframes.

Where a complaint is rejected, the complainant will be provided with clear and adequate reasons for the decision and will be informed of any applicable escalation or review processes, including how to use them and any relevant time limits.

7. Record keeping, monitoring and analysis of complaints:

The FSP will ensure accurate, efficient and secure recording of complaints and complaints-related information.

The following will be recorded in respect of each reportable complaint –

• All relevant details of the complainant and the subject matter of the complaint;
• Copies of all relevant evidence, correspondence and decisions;
• The complaint categorisation; and
• Progress and status of the complaint, including whether such progress is within or outside any set timelines.

The FSP will maintain the following data in relation to reportable complaints categorised in accordance with the categories mentioned in section 4, on an ongoing basis –

• Number of complaints received;
• Number of complaints upheld;
• Number of rejected complaints and reasons for the rejection;
• Number of complaints escalated by the complainants to the internal complaint’s escalation process;
• Number of complaints referred to an Ombud and their outcome;
• Total number of complaints outstanding.

Complaints information recorded in accordance with this subsection will be scrutinised and analysed by the FSP on an ongoing basis and utilised to manage conduct risks and effect improved outcomes and processes for its clients, and to prevent recurrences of poor outcomes and errors.

The FSP will establish and maintain appropriate processes for reporting of the information required above to its governing body or executive management.

8. Communication with complainants

• The FSP will ensure that its complaint processes and procedures are transparent, visible and accessible through channels that are appropriate to the FSP’s clients.
• The FSP will not impose any charge for a complainant to make use of complaint processes and procedures.
• All communications with a complainant will be in plain language.
• The FSP will, wherever feasible, provide clients with a single point of contact for submitting complaints.
• The FSP will disclose to a client:
  1. the type of Information required from a complainant;
  2. where, how and to whom a complaint and related information must be submitted;
  3. expected turnaround times in relation to complaints; and
  4. any other relevant responsibilities of a complainant.
• Complainants will be kept adequately informed of:
  1. the progress of their complaint;
  2. causes of any delay in the finalisation of a complaint and revised timelines; and
  3. the FSP’s decision in response to the complaint.