Complaints Resolution Policy

Purpose of this policy:

This policy sets out the procedures implemented by Barton Insurance Brokers Proprietary Limited (“Barton”) to handle and respond to clients’ complaints.

Legislation that requires this policy:

Section 17 of the General Code of Conduct for Authorised Financial Service Providers and Representatives, Board Notice 80 of 2003 (General Code), promulgated in terms of the Financial Advisory and Intermediary Service Act, 2002 (FAIS), requires authorised Financial Services Providers (FSPs) to maintain a comprehensive complaints policy for resolution of complaints by clients.

Legislation relevant to this policy:

General Code, specifically sections 16 to 19.

Rules on Proceedings of the Office of the Ombud for Financial Services Providers, Board Notice 81 of 8 August 2003.

1. Receiving and Handling Complaints

Barton is committed to attend to complaints received from clients promptly and effectively, with a view to resolve such complaints internally to the satisfaction of the client. To this end, Barton:

1. a)  Requests that clients who wish to lodge a complaint against Barton, to lodge such a complaint in writing
2. b)  Shall endeavour to handle complaints from clients as soon as possible.
3. c)  Shall handle and resolve as far as possible complaints in a manner which is fair to the client andto Barton, with each complaint receiving due consideration in a process that is managedappropriately and effectively.
4. d)  Shall endeavour to be transparent towards each client by explaining to the clients how thecomplaints procedures within Barton work and by providing regular feedback to that client on the progress in respect of his/her specific complaint.

5. e)  Shall take steps to investigate and respond promptly to such complaints.
6. f)  Shall ensure that full and appropriate redress is offered to the client without delay where acomplaint is resolved in favour of the client.
7. g)  Where the client indicates that a complaint has not been resolved to the client’s satisfaction,shall advise the client of any further steps which may be available to the client in terms of FAIS or any other law.

To ensure that the complaints procedures of Barton is readily available to clients, this policy has been made available on Barton’s Website or on request via email to GC Swanepoel at gcs@barton.co.za or telephone call to 011 532 7200.

2. Complaints contemplated in FAIS

In terms of FAIS, Barton is required to deal with complaints relating to a financial service that Barton or a representative of Barton has rendered. Barton is therefore unable to deal with a complaint relating to a financial product, the rejection of any claim or administrative service received from a product supplier. These complaints must be directed to the complaints department of the relevant product supplier. If a client wishes to lodge a complaint, he/she may contact Barton on the details provided in the paragraph below for assistance.

FAIS further requires that a complaint should allege that Barton or its Representative:

1. a)  Has contravened or failed to comply with a provision of FAIS and that as a result the complainant has suffered or is likely to suffer financial prejudice or damage.
2. b)  Has wilfully or negligently rendered a financial service to the complainant or which is likely to result in such prejudice or damage.
3. c)  Has treated the complainant unfairly

3. Clients’ procedure for lodging a complaint

If a client considers that any Key Individual and/or representative of Barton has provided them with financial advisory or intermediary services that do not comply with FAIS as described above, the client is entitled to lodge a complaint.

To lodge a complaint the client must send his/her complaint in writing to the following addresses:

Physical Address: Barton Insurance Brokers (Pty) Ltd 60 The Valley Road

Parktown Johannesburg 2193

Postal: PO Box 72444 Parkview

2122
Email: gcs@barton.co.za

The complaint must include:

• The clients full name and contact details
• A complete description of the financial services provided by Barton
• A detailed description of the client’s complaint, which should be accompanied by all relevantdocumentation which relate to or support the complaint, and which should include sufficientfacts and dates to enable Barton to deal with the complaint timeously
• The name of the Key Individual and/or representative who rendered the financial services
• The date on which the matter giving rise to the complaint occurred
• The clients preferred method of communication; i.e email or post

4. Barton’s procedure for handling and resolving a complaint

General

Barton will ensure that adequate resources are available to handle and where possible, assist with the resolution of client complaints. In this regard members of staff are specifically trained to handle complaints in accordance with this policy and to have the required knowledge of the applicable provisions of FAIS and the General Code.

Process

Each complaint received by Barton will be acknowledged in writing within three working days. The complaint will be noted in the Barton Complaints Register on the same day that it is received.

The complaint will immediately be brought to the attention of the Key Individual of Barton who will allocate the matter to an appropriate member of staff to resolve without delay.

Complaints of a routine nature will generally be dealt with by members of the client care team with the support of other staff where necessary. Non-routine or serious complaints received will generally be handled by members of staff with the appropriate seniority and the necessary knowledge of the applicable legislation and the product or product supplier. The guidance and input of the Key Individuals of Barton will be sought where necessary.

Complaints are followed up by Barton’s external compliance officer on a regular basis to ensure prompt resolution.

In the event that the complaint has not been resolved to the satisfaction of the client within six weeks of receiving the complaint, Barton will notify the client of the full reasons for the outcome and will provide the contact details of the Ombud for Financial Service Providers (Ombud) and a summary of the provisions of FAIS which are applicable if the client wishes to pursue the matter before the Ombud.

In the event that the complaint cannot be resolved, the complainant may have a recourse to the following, whichever is applicable:

1. a)  Refer the matter to the Ombud within six months of notification that the claim cannot be resolved or within six months of Barton’s failure to deal with the claim
2. b)  See legal advice from an attorney regarding any legal action that may be taken
3. c)  Refer the matter to arbitration or mediation, which requires the consent of Barton

5. Record Keeping

The Barton staff records a record of all complaints received in the complaints register and indicates in such register whether such complaints were successfully resolved. Record of complaints will be kept for at least 5 years from the date on which the complaint was received from the relevant client.

Should a client have any further questions or concerns, please contact Barton on 011 532 7200.

6. ImportantContactDetails

Barton Insurance Brokers (Pty) Ltd

See Paragraph 3 above

Website:

FAIS Ombud Office

Postal address:

Telephone:

Email: Website:

www.barton.co.za

PO Box 74571 Lynwood Ridge
0400
012 470 9080
012 762 5000 info@faisombud.co.za www.faisimbud.co.za

National Consumer Commission

Physical Address:

Telephone: Email: Website:

Building C
South African Bureau of Standards Campus
1 Dr Lategan Road
Groenkloof
Pretoria
0027
012 428 7000
080 000 7081 (For Western Cape Province) complaints@thencc.org.za
protector@westerncape.gov.za (for Western Cape Province) www.thencc.gov.za