Complaints Policy

1. Purpose

The purpose of this Complaints Policy is to outline the procedures and principles to be followed by Comofx (Pty) Ltd (hereinafter referred to as "the Company") in addressing and resolving complaints from clients in accordance with the requirements of the Financial Advisory and Intermediary Services (FAIS) Act in South Africa.

2. Definitions

• Complaint: Any expression of dissatisfaction made by a client in relation to the Company's services or activities.
• Compliance Officer: The individual designated by the Company to oversee compliance with FAIS requirements.
• FAIS Act: The Financial Advisory and Intermediary Services Act, 2002 (Act No. 37 of 2002) as amended.
• Representative: Any natural person who provides financial services on behalf of the Company and is authorized in terms of the FAIS Act.

3. Scope

This policy applies to all complaints received from clients, regardless of the nature of the financial service provided.

4. Complaints Handling Procedure

4.1 Receipt of Complaint

• All complaints should be submitted in writing, either electronically or in hard copy at complaints@comofx.com or via the form on the Comofx website.
• Clients can submit complaints to the Company's designated complaints email address, postal address, or through any other prescribed channel.
• The Compliance Officer is responsible for acknowledging receipt of the complaint within seven (7) business days.

4.2 Investigation and Resolution

• The Compliance Officer or an appointed designated person will investigate the complaint promptly.
• A written response addressing the complaint will be provided to the client within thirty (30) business days, unless exceptional circumstances warrant an extension, in which case the client will be informed of the delay.
• The response will include an explanation of the Company's findings and any proposed remedies or corrective actions.

4.3 Escalation

If the client is not satisfied with the response received, they may escalate the complaint to the relevant Ombudsman or regulatory authority as prescribed by the FAIS Act.

5. Engagement with Ombud and reporting

Should your complaint be referred to the Ombud, the following must be kept in mind:

• The FSP is required to be provided with a six-week period within which to resolve any complaint, before the FAIS Ombud will have jurisdiction.
• The FAIS Ombud will not adjudicate in matters where the claim is in excess of R800 000.
• If you already instituted an action in a court of law in respect of this complaint the Ombud will not consider the complaint.
• If the complaint was not resolved through conciliated settlement, the Ombud may make a determination that has the same legal status of a civil court judgement.
• An award of costs may be made against the person complained against.
• An award of costs may be made against a complainant if the conduct of the complainant was improper or unreasonable, or if the complainant caused an unreasonable delay in the finalisation of the investigation.

6. Record Keeping

• The Company will maintain a comprehensive record of all complaints received, including details of the investigation, resolution, and communication with the client.
• Records will be retained for the duration specified by the FAIS Act.

7. Training and Awareness

All representatives and staff involved in handling complaints will receive training on the Company's complaints policy and relevant FAIS Act provisions.

8. Regular Review

This Complaints Policy will be reviewed periodically to ensure its continued effectiveness and compliance with the FAIS Act.

9. Contact Information

Clients will be provided with contact information for the Company's designated complaints contact person.

10. Conclusion

This Complaints Policy is designed to ensure that Comofx handles and resolves complaints in a fair, transparent, and compliant manner with the requirements of the FAIS Act. Clients are encouraged to use this process to address any concerns they may have with the Company's services.