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Complaints Management Policy

Document amended January 20, 2023

1. Introduction

Cowrywise Financial Technology Limited (“Cowrywise” or the “Company”) is committed to conducting business professionally, fairly and with integrity. At the core of the Company’s existence is client obsession and satisfaction, whilst also ensuring that its affairs are in accordance with all relevant laws, rules and regulations.

The Complaints Management Policy (“Policy”) sets out the principles and procedures for handling complaints from customers and seeks to ensure that the complaints are resolved effectively and promptly. Complaint, as used in this Policy, refers to an expression of dissatisfaction from a customer to the Company, with respect to the quality of products or services offered by the Company.

2. Purpose & Objectives

The purpose of this Policy is to ensure prompt and efficient management of complaints to the satisfaction of our customers. This Policy shall apply to all employees, including senior Management staff of the Company.

The objectives of this Policy, amongst others, are:

  • a. to ensure complainants/customers are provided with relevant access to the Company’s Complaints Management Policy;
  • b. to ensure that complaints are accurately identified and resolved, with a view to promoting the Company’s efficiency and also providing satisfaction to the complainants/customers;
  • c. to entrench complaints management culture into customer experience to ensure brand protection; and
  • d. To ensure compliance with the Securities and Exchange Commission’s Rules on Complaints Management Framework (“SEC Complaints Management Framework”).
3. Applicability

This Policy shall be applicable to all employees and customers of Cowrywise.

4. Document Owner

The Compliance Team shall be responsible for this Policy. Where there are any questions with respect to the Policy, please contact:

Email: compliance@cowrywise.com

Phone: +234 201 330 3916

5. Complaints Channels

Complaints can be reported verbally, via e-mail (support@cowrywise.com), correspondence and/or via social media

6. Principles Governing Complaints Management
  • All complaints shall be promptly and effectively attended to; no complaint shall be ignored, suppressed or rejected by any staff or unit
  • The complaints channels shall be monitored for efficiency
  • Complaints received shall be immediately documented in the complaints register maintained by the Company.
  • Complaints shall be regarded as resolved or closed upon the resolution being communicated to the customer and a receipt of confirmation from the customer. However, where no feedback or confirmation is received from the customer within five (5) working days of the resolution being communicated to the customer, such complaint shall be deemed as closed.
  • Complaints shall be handled on an individual basis, in an equitable, objective and unbiased manner, taking into consideration, all facts received from the customer.
  • All communication regarding the complaints process shall be transparent, easily understandable and readily available to customers through appropriate materials and on the website
  • The complaints register shall be made available to the Compliance team and Managing Director at all times.
7. Timeline For Resolution Of Complaints
  • The Company’s policy shall be to resolve all complaints within and no later than ten (10) working days from the date the complaint is received, in accordance with the SEC Complaints Management Framework
  • In accordance with the SEC Complaints Management Framework, complaints not resolved within the above stated timeframe may be referred to the relevant Competent Authority, being the Fund Managers Association of Nigeria (FMAN), within two (2) working days either by the Company or the complainant.
  • Where the complainant is not satisfied with the decision of the Competent Authority, he/she has the right to refer the complaint to the SEC within two (2) working days of not being satisfied with the Competent Authority’s decision.
  • Customers may not lodge a complaint with the relevant Competent Authority or SEC in the first instance. As such, all complaints shall be immediately forwarded to the Company.
8. Retention OF Compliant Records

All complaint records and supporting documents shall be maintained for a period of five (5) years from the date of lodging the complaint, whether or not same has been resolved. All information regarding complaints shall be recorded in a format that is accessible to customers and the SEC, upon request.

9. Register of Complaints

In accordance with the SEC Complaints Management Framework, the Company shall maintain an electronic complaints register, which shall contain the following details:

  • a. Name of complainant
  • b. Date of complaint
  • c. Nature of complaint
  • d. Complaints details in brief
  • e. Remarks/comments

The Company shall update the complaints register on a monthly basis and send a status report to the SEC on a quarterly basis.

Notwithstanding the above, the Company’s policy shall be to record every complaint in the complaints register within twenty-four (24) hours, with clear identification of the issues to ensure swift resolution.

10. Review

This Policy shall be reviewed every two (2) years or on an as needed basis, whichever is earlier.