Dispute Resolution Process

Updated on

January 15, 2024

SECTION A – INTRODUCTION

1. PURPOSE

1.1 The purpose of Speedle Pty Limited (“Speedle’s”) Dispute Resolution Policy (“Policy”) is to ensure Consumer Complaints in respect of financial services are dealt with promptly, fairly and consistently.

1.2 This Policy represents Speedle’s commitment to effective and efficient Complaints handling and to fair and transparent dealings in the financial marketplace.

1.3 The standards and requirements set out in the ASIC Corporations, Credit and Superannuation (Internal Dispute Resolution) Instrument 2020/98 as outlined in this Policy are enforceable.

2. POLICY STATEMENT

2.1 Speedle must have a Dispute Resolution system that consists of:

(a) an Internal Dispute Resolution (“IDR”) process that complies with the standards and requirements made or approved by ASIC that cover Complaints made by Consumers in relation to the credit services provided; and

(b) membership of AFCA.

2.2 The benefits of effectively resolving Consumer Complaints through an IDR system with broad coverage include:

(a) the opportunity to resolve Complaints quickly and directly;

(b) the promotion of trusted relationships between Speedle and its Consumers;

(d) a greater understanding of the key drivers of Complaints;

(e) the ability to identify emerging issues and inform product and service delivery improvements; and

(f) reduced AFCA fees and future remediation costs.

2.3 Speedle takes a proactive approach to identifying and resolving Complaints. It is better for Speedle and its Consumers that a Complaint is dealt with at the earliest possible stage because it:

(a) prevents Complaints from becoming entrenched;

(b) preserves Consumer relations;

(d) may improve customer satisfaction.

2.4 When reviewing and establishing this Policy, Speedle has taken into account:

(a) the size of its business and the number of people in the organisation;

(b) the products and services offered and the volume and size of transactions Speedle is responsible for;

(d) the diversity and structure of its operations; and

(e) the likely number and complexity of Complaints.

3. AIMS

3.1 This Policy aims to resolve minor Complaints during the Consumer’s initial contact with Speedle.

3.2 To action all other Complaints, however received, within 21 calendar days of them being received.

3.3 To resolve all Complaints and provide an IDR response no later than thirty (30) calendar days after receipt of a Complaint.

4. DEFINITIONS

4.1 AFCA means the Australian Financial Complaints Authority, an Australian Securities and Investments Commission (“ASIC”) approved EDRS.

4.2 Complaint means an expression of dissatisfaction made to or about an organisation, related to its products, services, staff or the handling of a Complaint, where a response or resolution is explicitly or implicitly expected or legally required.

4.3 Consumer means a Consumer as defined by section 5 of the NCCP Act and for the purposes of this Policy, includes Small Businesses.

4.4 EDRS means External Dispute Resolution Scheme.

4.5 IDR Response means a written response to the Consumer informing them of:

(a) the final outcome of their Complaint at IDR (including either confirmation of actions taken by Speedle to fully resolve the Complaint or reasons for Speedle’s rejection or partial rejection of the Complaint;

(b) their right to take their Complaint to AFCA if they are not satisfied with Speedle’s with the outcome at (a); and

4.6 Speedle means Speedle Pty Limited.

4.7 NCCP Act means the National Consumer Credit Protection Act 2009 (Cth).

4.8 Small Business means, for the purposes of dispute resolution, a business that had less than one hundred (100) employees at the time of the act or omission by Speedle that gave rise to the Complaint. A small business includes a primary producer, if that primary producer is also a small business.

4.9 Unreasonable Consumer Conduct means behaviour which because of its nature or frequency raises substantial health, safety, resource or equity issues for Speedle, its employees and representatives, other Consumers or the particular Consumer themselves.

5. DEFINITION OF COMPLAINT

5.1 Speedle must deal with expressions of dissatisfaction that meet the definition of Complaint as specified in section 4.

5.2 The following expressions of dissatisfaction are included in the definition of Complaint:

(a) posts on a social media channel or account owned or controlled by Speedle that is subject of the post, where the author is both identifiable and contactable; and

(b) Complaints about a matter that is subject of an existing remediation program or about the remediation program itself.

5.3 Speedle does not limit its categorisation of Complaints to those expressions of dissatisfaction where a response or resolution is explicitly expected. Speedle also categorises expressions of dissatisfaction where a response or resolution is ‘implicitly expected’ as a Complaint.

6. SPEEDLE’S COMMITMENT TO IDR

6.1 Speedle’s Director ensures they:

(a) have adequate oversight of Speedle’s IDR processes;

(b) provide adequate resources to Speedle’s employees who have responsibility for managing Complaints including but not limited to providing ongoing training and appropriate human resources;

(d) implement IT systems and reporting procedures to ensure timely and effective Complaint management and monitoring; and

(e) establish clear roles, responsibility and authority for the management and resolution of Complaints.

7. COMPLAINTS MANAGEMENT POLICY

7.1 Speedle must ensure that Speedle’s Complaints Management Policy is available free of charge. Speedle’s Complaints Management Policy is available on its website.

7.2 If the Complaints Management Policy is requested in a particular form, Speedle takes such steps as are reasonable to provide the Complaints Handling Policy in the form requested.

SECTION B – PROCEDURES: RECEIVING COMPLAINTS

8. ENABLING COMPLAINTS

8.1 Speedle publicises information about how and where Complaints can be made by:

(a) publishing its Complaints Management Policy on Speedle’s website and making the Complaints Management Policy available in hard copy free of charge upon request;

(b) including information about the IDR process in product welcome packs;

(d) providing training to all staff about Speedle’s IDR process.

8.2 Where appropriate, Speedle makes its IDR process accessible for Consumers with disabilities or language difficulties by:

(a) Speedle proactively identifying Consumers who might need additional assistance;

(b) ensuring that information provided to the public about Speedle’s IDR process is available in a range of languages and formats (including large print, Braille or audiotape);

(d) offering translation services to Consumers or making staff available who are cross-culturally trained.

8.3 Speedle offers multiple Complaint lodgement methods including:

(a) telephone number;

(b) email;

(d) social media platforms owned or controlled by Speedle;

(e) in person; or

(f) online.

8.4 Speedle allows representatives of the Consumer to lodge Complaints on the Consumer’s behalf and accepts authorities from representatives lodging Complaints on behalf of Consumers. In these circumstances, Speedle does not contact the Consumer directly, unless:

(a) the Consumer requests direct communication with Speedle;

(b) Speedle reasonably believes the representative is not acting in the Consumer’s best interests;

(c) Speedle reasonably believes the representative is acting in a deceptive or misleading manner with the Consumer and/or Speedle;

(d) Speedle reasonably believes the representative is not authorised to represent the Consumer; and

(e) at the time insert defined company name] is dealing with the Complaint, the representative has been excluded by AFCA from representing Consumers in relation to a Complaint lodged with AFCA.

9. RECEIVING COMPLAINTS

9.1 Speedle’s employees must immediately refer Consumers wishing to make a Complaint to the Complaints Officer. This ensures that wherever possible, the Complaint is investigated by a staff member not involved in the subject matter of the Complaint.

9.2 On receiving a Complaint, the following information must be recorded:

(a) Date of Complaint;

(b) Name of Consumer;

(d) Contact details of Consumer;

(e) Format of Complaint (phone / email / letter / fax);

(f) Preferred contact method of Consumer (phone / email / letter / fax);

(g) Details of the Complaint; and

(h) Classification of the Complaint (Refer to section 11).

10. COMPLAINTS RECEIVED OVER THE PHONE

10.1 The following procedure must be followed when a Complaint is received orally:

(a) Identify yourself, listen, record details and determine what the Consumer wants;

(b) Confirm the details received;

(d) Explain the courses of action available;

(e) Do not attempt to lay blame or be defensive;

(f) Resolve the Complaint if possible or commit to do something immediately, irrespective of who will ultimately handle the Complaint;

(g) Don’t create false expectations;

(h) Inform the Consumer of the name and contact details of the person who will be formally dealing with the Complaint (i.e. the Complaints Officer);

(i) Refer the matter immediately to the Complaints Officer (even if you resolved the matter); and

(j) Record the details in the Complaints Register.

11. CLASSIFICATION OF COMPLAINTS

11.1 All Complaints must be classified by Speedle and then analysed to identify systemic, recurring and single incident problems and trends. Complaints should be prioritised according to the urgency and severity of the issues raised. Examples of matters that should be prioritised include where:

(a) the Consumer is experiencing domestic or financial abuse;

(b) the Consumer has a serious or terminal illness; or

11.2 Level 1 – the least serious Complaints. The Complaint could not be resolved at first contact with the Consumer. Some Complaints at this level require the assistance of other employees at Speedle (e.g. Information Technology and Investment Research). The Complaint can be resolved without escalating it to the Director.

11.3 Level 2 – more serious Complaints. The Director must be informed of the Complaint and may provide input where necessary to help resolve the Complaint.

11.4 Level 3 – the most serious Complaints. This type of Complaint requires the involvement of the Director.

12. RESPONSIBILITY FOR AND INVESTIGATION OF COMPLAINTS

12.1 At first instance the Complaints Officer is responsible for dealing with Complaints.

12.2 If the Complaints Officer is unable to resolve the Complaint within 21 days, the details of the Complaint must be immediately forwarded to the Director who has overall responsibility for Speedle’s IDR process.

12.3 The Director is to review the circumstances involving the Complaint and attempt to provide the Consumer with an IDR Response to the Complaint (Refer sections 16 and 17 below).

SECTION C – PROCEDURES: RESPONDING TO COMPLAINTS

13. RESPONDING FLEXIBLY

13.1 Speedle deals with Complaints with as little formality as possible to ensure that Consumers are not restricted in their access to Speedle’s IDR process.

14. ACKNOWLEDGING COMPLAINTS

14.1 Once the Complaint is received, the Complaints Officer must acknowledge receipt of the Complaint within twenty-four (24) hours (or one (1) business day) of receiving the Complaint, or as soon as practicable. The Complaints Officer must attempt to resolve the Complaint within thirty (30) calendar days of it being received.

14.2 When selecting a method to acknowledge a Complaint, Speedle takes into account the method used by the Consumer to lodge the Complaint and any preferences the Consumer has expressed about receiving communication from Speedle. Speedle may acknowledge Complaints:

(a) verbally; or

(b) in writing (including by email, mail or social media channels).

14.3 Please refer to Appendix 2 for a template Complaint Acknowledgement.

15. COMPLAINTS CLOSED WITHIN FIVE (5) BUSINESS DAYS OF RECEIPT

15.1 An IDR Response (refer section 16 below) is not required where a Complaint has been closed within five (5) business days of receipt because:

(a) Speedle has resolved the Complaint to the Consumer’s satisfaction and this is either:

(i) confirmed verbally or in writing by the Consumer; or

(ii) a reasonable view to take given the circumstances; or

(b) Speedle has given the Consumer an explanation and/or apology when it can take no further action to reasonably address the Complaint.

15.2 A written IDR Response must be provided even where a Complaint is closed within five (5) business days if:

(a) the Consumer requests a written response; or

(b) the Complaint is about hardship.

16. IDR RESPONSES

16.1 Complaints referred to the Complaints Officer must be responded to in the same manner they are received unless otherwise requested by the Consumer. For example, a telephone Complaint must be initially responded to with a telephone call.

16.2 The time and date of all telephone calls to the Consumer made in connection with a Complaint must be recorded with other details about the Complaint outlined in section 9.2 of this Policy.

16.3 An IDR Response must be provided to the Consumer upon resolving a Complaint. The written communication must inform the Consumer of:

(a) the final outcome of their Complaint at IDR, including either:

(i) confirmation of the actions taken by Speedle to fully resolve the Complaint; or

(ii) reasons for the rejection or partial rejection of the Complaint;

(b) their right to take the Complaint to AFCA if they are not satisfied with the IDR Response; and

16.4 If Speedle rejects or partially rejects the Complaint, the IDR Response must clearly set out the reasons for the decision by:

(a) identifying and addressing the issues raised in the Complaint;

(b) setting out Speedle’s finding on material questions of fact and referring to the information that supports those findings; and

(c) providing enough detail for the Consumer to understand the basis of the decision and to be fully informed when deciding whether to escalate the matter to AFCA or another forum.

16.5 Please refer to Appendix 3 for a template IDR Response.

17. TIMEFRAMES FOR IDR RESPONSES

17.1 Speedle must provide an IDR Response (in accordance with section 16) to the Consumer within the timeframes noted in the below table:

17.2 Type of Complaint / Maximum Timeframe to provide IDR Response / Further Detail

Complaints involving default notices = No later than twenty-one (21) calendar days after receiving the Complaint = Section 18

Complaints involving applications for hardship notices or a request for postponement of enforcements proceedings made = No later than twenty-one (21) calendar days after receiving the Complaint.

Exceptions apply where Speedle does not have sufficient information to make a decision or if an agreement is reached with the Consumer = Section 19

All other complaints = No later than thirty (30) calendar days after receiving the Complaint.

18. COMPLAINTS INVOLVING DEFAULT NOTICES

18.1 A Complaint may involve a default notice where the Consumer:

(a) alleges that the default notice was not served;

(b) disputes the amount specified in a default notice or whether the default notice was rectified;

18.2 Speedle must give the Consumer a default notice before commencing enforcement proceedings to recover money, take possession of property or sell property. The default notice must

(a) inform the Consumer that they must remedy the default within thirty (30) calendar days; and

(b) substantially meet the pro forma notice requirements in Form 12A and Form 18A of the National Consumer Credit Protection Regulations 2010 (Cth).

18.3 Speedle must refrain from commencing or continuing legal action, including enforcement proceedings, against a Complainant, except where the statute of limitations is about to expire. This only applies while:

(a) the Complaint is being handled by Speedle’s IDR process; and

(b) for at least fourteen (14) calendar days thereafter to allow the Consumer to lodge their Complaint with AFCA (where the Complaint cannot be resolved by Speedle’s IDR procedures.

19. COMPLAINTS INVOLVING HARDSHIP OR POSTPONEMENT REQUESTS

19.1 Speedle treats Complaints involving hardship notices or postponement requests as urgent matters and these are prioritised over other Complaints.

19.2 Speedle’s Hardship Policy provides further information regarding how Speedle deals with hardship notices, including how to identify and respond to hardship notices.

19.3 Speedle’s Complaints Officer is responsible for ensuring the following occurs within twenty-one (21) calendar days of receiving a Complaint involving a hardship notice or postponement request:

(a) consider and determine whether to agree to:

(i) a change in the terms of the credit contract/consumer lease between Speedle and the complainant for hardship (pursuant to section 72 and section 177B of the National Credit Code); or

(ii) a request to postpone enforcement proceedings.

19.4 Where additional information is required from the Complainant:

(a) Where Speedle requires further information about a hardship notice, the Complaints Officer is responsible for ensuring Speedle requests the additional information with twenty-one (21) calendar days of receiving a Complaint.

(b) Where Speedle has requested additional information from the Complainant, the Complainant has twenty-one (21) calendar days to respond to this request for information.

(c) Additional time to provide an IDR Response is permitted where the credit contract/consumer lease was entered into after 1 March 2013. The additional time is up to:

(i) twenty-eight (28) calendar days from when the additional information was requested, but not received; or

(ii) twenty-one (21) calendar days from when the additional information was received by Speedle.

19.5 If the Complaint cannot be resolved within the required timeframe, the Consumer must be referred to AFCA.

19.6 Where Speedle has reached an agreement with the Complainant about a hardship notice or postponement request, Speedle’s Director will confirm in writing:

(a) the terms of change to the credit contract/consumer lease; or

(b) the conditions of postponement of enforcement proceedings;

within thirty (30) calendar days of the agreement being reached.

19.7 Speedle must inform the Complainant of their right to complain to AFCA and provide AFCA’s contact details where Speedle:

(a) does not agree to a change in the terms of a credit contract/consumer lease or to negotiate a postponement of enforcement proceedings; or

(b) where an agreement has been reached per section 19.6, within thirty (30) calendar days of the agreement being reached.

20. COMPLAINT MANAGEMENT DELAYS

20.1 Speedle is not required to provide a Consumer with an IDR Response within the IDR timeframe where:

(a) there has been no reasonable opportunity to provide the IDR Response within the IDR timeframe because:

(i) the resolution of the Complaint is particularly complex, for example, the individual Complaint is about a transaction or event that occurred more than six (6) years ago and requires reconstruction of account information; and/or

(ii) circumstances beyond Speedle’s control are causing Complaint management delays, for example, the Consumer is waiting on a medical appointment that Speedle reasonably requires the Consumer to attend or the Consumer is unable to respond to Speedle due to illness or absence; and

(b) an IDR Delay Notification has been sent to the Consumer prior to the expiry of the IDR timeframe (ie: thirty (30) calendar days).

Note: Complaint management delays caused by authorised representatives of Speedle is not a valid reason for Speedle to have not provided an IDR Response within the required timeframe.

20.2 The IDR Delay Notification must inform the Consumer about:

(a) the reasons for the delay;

(b) their right to complain to AFCA if they are dissatisfied; and

20.3 Please refer to Appendix 4 for a template IDR Delay Notification.

20.4 The exceptions to providing an IDR Response outlined in 20.1 and 20.2 do not prevent the Consumer from escalating their Complaint to AFCA and do not affect AFCA’s ability to register a Complaint.

SECTION D – RECORD KEEPING

21. COMPLAINTS REGISTER

21.1 A Complaints Register is to be compiled and managed by the Complaints Officer.

21.2 A copy of the Complaints Register is to be provided to the Director on a quarterly basis for review.

21.3 The Complaints Officer must maintain a soft copy record of the Complaints Register.

22. COMPLAINTS DATA

22.1 Speedle must provide reports about Complaint’s data on a quarterly basis to Speedle’s Director and senior management.

22.2 These reports should include:

(a) the number of Complaints received;

(b) the number of Complaints closed;

(d) the time taken to acknowledge Complaints;

(e) the time taken to resolve or finalise Complaints;

(f) Complaint outcomes, including:

(i) the number of Complaints resolved;

(ii) the number of Complaints unresolved;

(iii) the number of Complaints that were abandoned or withdrawn; and

(iv) details of amounts paid to Consumers to resolve Complaints;

(g) possible systemic issues identified;

(h) the underlying causes of Complaints;

(i) Complaint trends;

(j) the number of Complaints escalated to AFCA; and

(k) recommendations for improving products or services.

23. REPORTING TO ASIC

23.1 Speedle must lodge their IDR data with ASIC by 31 January and 31 July each year, for the reporting periods of 1 January to 30 June and 1 July to 31 December respectively.

23.2 Complaints that must be included in an IDR data report include:

(a) any complaints required to be covered by Speedle’s IDR procedures; and

(b) any complaints that were:

(i) made in the reporting period; and

(ii) not closed as at the start of the reporting period.

23.3 Speedle must also report a complaint if Speedle has reopened a previously closed complaint.

23.4 The Complaints Officer collates the IDR data for each reporting period in the template provided by ASIC to ensure that the IDR data passes ASIC’s verification.

23.5 The Complaints Officer is responsible for lodging Speedle’s IDR data CSV file with ASIC via the Regulatory Portal within the required time frame.

24. IDENTIFYING AND RECORDING SYSTEMIC ISSUES

24.1 The Complaints Officer aims to identify any systemic issues or recurring Complaints as a result of compiling the Complaints Register.

24.2 Where any systemic issues or recurring Complaints are identified, these are notified to the Director by preparing a report to accompany the Complaints Register. The report must include metrics and analysis of Consumer Complaints including the systemic issues identified through those Complaints. This encourages the identification of compliance issues or risks, which can be investigated to determine their causes and then rectified.

24.3 The Director must ensure that prompt action is taken to rectify systemic issues and:

(a) identify affected Consumers; and

(b) provide fair remediation to affected Consumers.

24.4 Speedle must:

(a) encourage and enable staff to escalate potential systemic issues identified from individual Complaints;

(b) regularly analyse Complaint data to identify systemic issues;

(d) report internally on the outcome of investigations, including actions taken, in a timely manner.

24.5 Where any systemic issue results in a breach of Speedle’s obligations under its AFSL, the Corporations Act or any other financial services laws; the breach is reported by the Compliance Officer in accordance with Speedle’s Breaches and Incidents Reporting Policy.

25. COMPLIANCE AUDITS

25.1 Speedle must undertake compliance audits at least annually, unless the number of Complaints is very small.

SECTION E – REMEDIES

26. TYPES OF REMEDIES AVAILABLE FOR RESOLVING COMPLAINTS

26.1 If the Complaints Officer is of the opinion that a Complaint requires a remedy, the matter must be referred to the Director to make a determination. The Director is appropriately authorised to determine and approve any remediation to be paid to Consumers.

26.2 In determining the appropriate remedy, the Director considers a broad range of remedies to facilitate the fair and efficient resolution of the Complaint, including:

(a) an explanation of the circumstances giving rise to the Complaint;

(b) an apology;

(d) a refund or waiver of a fee or charge;

(e) a goodwill payment;

(f) a compensation payment;

(g) a waiver of debt;

(h) correcting incorrect or out of date records;

(i) changing the terms of a contract; and

(j) undertaking to set in place improvements to Speedle’s systems, procedures or products.

27. CLOSING COMPLAINTS

27.1 Speedle should record the Complaint outcome, Complaint remedy and financial compensation amount (if any).

27.2 Speedle must ensure that Complaint resolution outcomes are implemented in a timely manner when a Complaint is closed.

SECTION F - EXTERNAL DISPUTE RESOLUTION

28. AUSTRALIAN FINANCIAL COMPLAINTS AUTHORITY

28.1 Speedle is a member of AFCA. Speedle’s AFCA membership number is 99505. If membership with AFCA is changed or cancelled, Speedle must notify ASIC within ten (10) business days of the change.

28.2 Where Speedle has failed to renew its AFCA membership or where its AFCA membership has been cancelled because of failure to pay membership fees, non-compliance with the Terms of Reference or decision of AFCA, Speedle will prepare a written report to ASIC within three (3) business days of the change.

28.3 The Compliance Officer ensures Speedle’s AFCA membership is renewed on the appropriate date.

28.4 Speedle liaises with AFCA and ensures full cooperation with it.

28.5 Speedle must provide details about how a Consumer can access AFCA in a range of documents including:

(a) its website;

(b) Financial Services Guides;

(d) Periodic Statements (including exit statements).

SECTION G – CONCLUSION

29. DUTY OF CARE TO CLIENTS AND STAFF

29.1 The Director is responsible for ensuring Speedle’s IDR process does not involve the release of information in relation to:

(a) Speedle generally;

(b) Consumers or Speedle’s employees’ individual information;

that contravenes the privacy laws, any of Speedle’s policies in relation to confidential information or the contractual obligations of Speedle. Further information and advice on this matter can be obtained from the Director.

29.2 Reponses to IDR matters that contain personal information about a Consumer or an employee of Speedle’s must be provided to the Director for final approval, prior to publication or release.

29.3 The Director must ensure express consent has been obtained from the Consumer prior to disclosing any personal information.

30. OUTSOURCING

30.1 Where Speedle outsources part, or all, of its IDR process, Speedle must:

(a) have measures in place to ensure that due skill and care is taken in choosing suitable service providers;

(b) monitor the ongoing performance of service providers; and

(c) appropriately deal with any actions by service providers that breach service level agreements or fall short of their obligations.

30.2 Speedle’s outsourcing procedures are included in its Outsourcing Policy.

31. TRAINING

31.1 Employees of Speedle who deal with Consumers, not just Complaints handling staff, need to have an understanding of the IDR process. Consequently, all employees of Speedle receive targeted induction and ongoing training about the IDR process. This training is scheduled and conducted at the discretion of the Compliance Officer.

31.2 Training includes the following topics:

(a) Speedle’s IDR process and applicable policies;

(b) the requirements of RG271;

(d) any changes to Speedle’s products and services which may impact Consumers and lead to expressions of dissatisfaction;

(e) how to identify Consumers who may need additional assistance;

(f) dealing with Unreasonable Consumer Conduct;

(g) effective communication and negotiation techniques;

(h) effective written communications;

(i) Complaint data capture and internal reporting;

(j) issue identification and analysis; and

(k) identifying and escalating systemic issues, including reporting lines.

32. RESOURCES

32.1 The Director at all times ensures there are adequate resources for IDR processes to operate effectively and efficiently. The Director conducts an annual review of the resources allocated to Speedle’s IDR process to ensure they are adequate.

32.2 To ensure adequate systems are in place to handle Complaints promptly, fairly and consistently, the Director:

(a) reviews IDR processes on a regular basis and provide additional resources without delay where required;

(b) ensures at all times, there is an established contact point for Consumers;

(c) ensures personnel involved in handling Complaints are adequately trained and competent to deal with Complaints, including the authority to settle Complaints or have ready access to someone with the necessary authority; and

(d) ensures there is appropriate documentation, specialist support, materials and equipment, computer hardware and software, and finances to assist with the IDR process.

33. DOCUMENT RETENTION AND AUDIT

33.1 Directors, officers and employees of Speedle are required to retain copies of all Complaints handling documents in accordance with Speedle’s Document Retention Policy. These files are maintained at the premises of Speedle. A copy must also be provided to the Compliance Officer for storage and inspection by ASIC as required.

34. POLICY REVIEW

34.1 This Policy is reviewed on at least an annual basis by the Compliance Officer, having regard to the changing circumstances of Speedle. The Compliance Officer then reports to the Director on compliance with this Policy.

35. LEGISLATIVE BASIS

35.1 This Policy gives effect to the reforms introduced by the Treasury Laws Amendment (Putting Consumers First – Establishment of the Australian Financial Complaints Authority) Act 2018 and complies with ASIC Regulatory Guide 271: Internal Dispute Resolution and Speedle’s obligations under section 47(1)(h) of the National Consumer Credit Protection Act 2009 (Cth).

35.2 This Policy has been developed in accordance with the principles outlined in Australian Standard AS/NZS 10002: 2014.

Issued by Speedle Pty Limited – 15 January 2024

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