Complaints Policy

OSO Money is the trading name of the regulated business providing foreign exchange and international payment services.

I. Purpose

The FAIS General Code of Conduct requires a financial services provider (FSP) to establish, maintain and operate an adequate and effective complaints management framework to ensure the effective resolution of complaints and the fair treatment of complainants.

Treating Customers Fairly (TCF) Outcome 6 provides that customers should not face unreasonable post-sale barriers to change a product, switch providers, submit a claim or lodge a complaint.

This document sets out the complaints procedure that OSO Money will follow in order to receive, investigate, resolve and record complaints in accordance with applicable legislative and regulatory requirements.

This Complaints Policy applies to OSO Money (Pty) Ltd, reference/registration number 26368, operating under the trading name OSO Money in relation to its foreign exchange and international payment services.

II. Objectives

The objectives and key principles of OSO Money’s Complaints Management Framework are to:

• provide a consistent, high-quality, fair and accountable approach to complaints;
• ensure complaints are investigated and resolved appropriately and within applicable regulatory timelines;
• support the fair treatment of customers;
• identify conduct risks, recurring issues and opportunities for improvement; and
• maintain appropriate records and management information relating to complaints.

All complaints will be handled in line with applicable regulatory requirements and Treating Customers Fairly outcomes.

III. Definitions

“Client query” means a request to OSO Money or its service supplier for information regarding financial products, financial services or related processes, or to carry out a transaction or action in relation to such product or service.

“Complainant” means a person who submits a complaint, including a client or a person acting on behalf of a client or other person with a direct interest in the relevant agreement, financial product or financial service.

“Complaint” means an expression of dissatisfaction relating to a financial product or financial service provided or offered by OSO Money which indicates or alleges that OSO Money or its service supplier has contravened or failed to comply with an agreement, law, rule or applicable code of conduct; that maladministration or wilful or negligent action or failure to act has caused harm, prejudice, distress or substantial inconvenience; or that the person has been treated unfairly.

“Compensation payment” means a payment, monetary benefit or service made by or on behalf of OSO Money to compensate a complainant for a proven or estimated financial loss where OSO Money accepts liability for the loss.

“Goodwill payment” means a payment, benefit or service made as an expression of goodwill aimed at resolving a complaint where OSO Money does not accept liability for the financial loss complained of.

“Rejected” means a complaint that has not been upheld and that OSO Money regards as finalised after advising the complainant that it does not intend to take further action, including complaints regarded as unjustified or invalid or where the complainant does not accept or respond to OSO Money’s proposals to resolve the complaint.

“Reportable complaint” means a complaint other than one that is upheld immediately by the person initially receiving it, upheld within OSO Money’s ordinary client-query process within five business days, or submitted in a manner that does not provide OSO Money a reasonable opportunity to record the prescribed details.

“Upheld” means a complaint finalised wholly or partially in favour of the complainant, where the complainant has explicitly accepted that the matter is resolved, or it is reasonable for OSO Money to assume such acceptance, and any undertakings made to resolve the complaint have been or will be met within an acceptable timeframe.

IV. Review

OSO Money will regularly review its Complaints Management Framework and document material changes. The framework will be reviewed at least annually and whenever changes in the business, products, services or applicable regulatory requirements materially affect complaints management.

V. Complaints Process Overview

1. Receive the complaint in writing.
2. Record the complaint in the Complaints Register or appropriate complaints management system.
3. Allocate a responsible person.
4. Classify and categorise the complaint, including the relevant TCF outcome where applicable.
5. Acknowledge the complaint.
6. Investigate and analyse the complaint.
7. Resolve the complaint and communicate the outcome.
8. If unresolved to the complainant’s satisfaction, explain applicable internal escalation and Ombud rights.
9. Discuss complaints and trends with management.
10. Implement appropriate remedial actions and improve systems and processes.

VI. Allocation of Responsibilities

OSO Money will identify the roles and responsibilities of persons involved in the complaints process. Responsibilities will be allocated to appropriately trained and authorised personnel, with suitable escalation to senior management where required.

VII. Complaints Management

The responsible senior individual / Key Individual of OSO Money is responsible for effective complaints management and for overseeing the implementation and effectiveness of the Complaints Management Framework.

VIII. Decision Making

Personnel responsible for making decisions or recommendations on complaints must be adequately trained; have an appropriate mix of experience, knowledge and skills in complaints handling, fair treatment of customers and relevant legal and regulatory matters; be free from conflicts of interest; and be adequately empowered to make impartial decisions or recommendations.

IX. Categorisation of Complaints

At a minimum, complaints will be categorised by reference to:

• the design of a financial product, financial service or related service, including fees or charges;
• information provided to clients;
• advice or intermediary services, where applicable;
• financial product or financial service performance;
• client service;
• complaints handling; and
• other categories relevant to OSO Money’s business model, foreign exchange and international payment services, products, services and client base.

X. Complaints Resolution Process

1. A complaint should be submitted to OSO Money in writing using the contact details in this Policy. Complaints may be submitted by email to [email protected] or through the complaints channel made available by OSO Money.

If a complaint is initially submitted telephonically, OSO Money may request the relevant details in writing.

The complainant should provide sufficient information to enable OSO Money to investigate, including, where applicable:

• name and surname;
• account or client reference;
• identification or passport details where reasonably required for identification;
• contact details;
• details of the relevant OSO Money contact person, if any;
• complaint category; and
• a brief description of the complaint and the outcome sought.

2. Upon receipt, OSO Money will:

• acknowledge complaints within 24 hours where reasonably practicable;
• communicate the availability and contact details of the relevant Ombud services at applicable stages of the client relationship;
• communicate in plain language;
• provide, wherever feasible, a single point of contact;
• explain the complaints process, responsible contact, applicable timelines, internal escalation and relevant Ombud escalation rights;
• follow up telephonic acknowledgements in writing; and
• provide a complaint reference number.

3. Details of the person allocated to the complaint will be provided within 48 hours where reasonably practicable.

4. Responsible personnel will analyse the complaint and determine the appropriate classification and handling.

5. Potential complaints will be captured, classified and escalated as required. Where a third party acts on behalf of a complainant, OSO Money may require appropriate written authority, consent or power of attorney before discussing confidential information with that third party.

6. All complaints will be prioritised according to their nature, urgency, potential client impact and regulatory significance.

Routine complaints should ordinarily receive a response within 15 working days.

Serious or urgent complaints should ordinarily receive a response within 5–10 working days where practicable, subject to complexity and any applicable prescribed timeframe.

Complaints received from authorities or an Ombud will be handled by the responsible senior person and answered within the stipulated regulatory or Ombud timeframe.

7. Reportable complaints will be categorised and linked to the applicable TCF outcome where relevant.

8. Complaints will be grouped and analysed to identify client impact, conduct risks, root causes and trends.

XI. TCF Categorisation

Complaints will be considered against the relevant Treating Customers Fairly outcomes, including:

• TCF Outcome 1 – management and governance-related complaints;
• TCF Outcome 2 – complaints relating to product or service design, features and charges;
• TCF Outcome 3 – inaccurate, misleading, confusing or unclear information provided to clients;
• TCF Outcome 4 – unsuitable, inappropriate or conflicted advice, where applicable;
• TCF Outcome 5 – product performance and service-related issues; and
• TCF Outcome 6 – product accessibility, changes, switches and complaints-handling barriers.

OSO Money will apply the TCF framework only to the extent relevant to its products, services and regulatory obligations.

XII. Timelines, Investigation and Root Cause Analysis

OSO Money will endeavour to resolve complaints within 30 days of receipt, depending on the complexity of the complaint and subject to any applicable prescribed regulatory timelines.

OSO Money will analyse the root cause of complaints to prevent recurrence where possible, identify relevant internal and external facts, and ensure escalated or reviewed complaints are handled impartially.

Clients may escalate complaints that are not resolved to their satisfaction. Escalations will, where appropriate, be allocated to an impartial and suitably senior person.

Complaint procedures will not impose unnecessarily complicated or burdensome administrative requirements on complainants.

XIII. Records, Monitoring and Management Information

OSO Money will maintain accurate, efficient and secure records of complaints and complaints-related information.

For each reportable complaint, records will include, where applicable:

• relevant details of the complainant and subject matter;
• evidence, correspondence and decisions;
• complaint categorisation;
• progress and status, including applicable timelines;
• whether the complaint was upheld or rejected and the reasons;
• internal escalations;
• Ombud referrals and outcomes;
• compensation and goodwill payments; and
• outstanding complaints.

Complaints information will be reviewed and analysed on an ongoing basis and used to manage conduct risks, improve client outcomes and prevent recurrence of errors or poor outcomes.

The complainant will be kept appropriately informed of progress and material delays.

XIV. Management Review and Remedial Action

Complaints will be discussed with management on an appropriate regular basis, including where a complaint or trend warrants immediate attention.

The responsible senior individual / Key Individual will ensure that relevant employees have access to this Complaints Policy and are appropriately trained.

Complaints will be used as management information to identify risks, improve systems and processes, and prevent recurrence of poor client outcomes. The Complaints Register will be updated and applicable reporting obligations will be observed.

XV. Representatives and Service Suppliers

OSO Money will take reasonable steps to ensure that representatives and service suppliers involved in providing services to clients have appropriate complaints processes. Complaints relating to a representative or service supplier will be referred to the relevant responsible function for investigation and resolution, as appropriate.

XVI. Decisions Relating to Complaints

Where a complaint is upheld, any commitment by OSO Money to make a compensation payment, goodwill payment or take other remedial action will be carried out without undue delay and within any agreed or applicable timeframe.

Where a complaint is rejected, OSO Money will provide clear and adequate reasons and inform the complainant of applicable escalation or review processes, including relevant time limits.

XVII. Complaints Escalation and Review

Complaints may be escalated internally where they are complex, unusual, unresolved or otherwise require review. The initial complaint handler may refer the matter to the responsible senior individual / Key Individual or another appropriately senior and impartial person.

Where a complainant remains dissatisfied, OSO Money will provide information on applicable external escalation or Ombud processes and will not impede or unduly delay the complainant’s right to approach the relevant Ombud.

XVIII. Communication with Complainants

OSO Money will ensure that its complaint processes are transparent, visible and accessible through channels appropriate to its clients.

No charge will be imposed for using OSO Money’s complaints process.

Communications will be in plain language and will explain:

• what information is required;
• where, how and to whom a complaint should be submitted;
• expected turnaround times;
• the complainant’s relevant responsibilities;
• the progress of the complaint;
• reasons for material delays and revised timelines; and
• OSO Money’s decision and applicable escalation rights.

XIX. Communication with Ombud and Authorities

OSO Money will clearly and transparently communicate the availability and contact details of relevant Ombud services at applicable stages of the client relationship.

OSO Money will endeavour to resolve complaints through its internal process before a final determination or ruling is made by an Ombud, without impeding or unduly delaying access to an Ombud.

OSO Money will maintain open and honest communication and cooperation with any relevant Ombud.

Where OSO Money is required to report to a designated authority, it will do so in accordance with the applicable requirements and stipulated timelines.

XX. Contact Details

OSO Money (Pty) Ltd
Reference / Registration No.: 26368
Trading name: OSO Money
Email: [email protected]
Address: Suite D1, Nautica Building, 13 Beach Road, Cape Town, Western Cape, 8005, Republic of South Africa