Complaints Management Policy and Procedure

1.Scope

The General Code of Conduct for Authorised Financial Services Providers and Representatives (“The Code”) issued under the Financial Advisory and Intermediary Services Act, 2000 (Act 37 of 2002) (“FAIS”), requires financial service providers to maintain an internal complaints resolution system and procedures. Further to this the Treating Customers Fairly (“TCF”) principles details additional procedures to be followed.

This policy details our commitment to effective complaints resolution and the procedures implemented to provide both our clients and prospective clients with the opportunity to be heard when they feel that they have been treated unfairly, and for RWM to implement corrective action.

2 Purpose

The purpose of this policy is to document our complaints resolution system and procedures, and to assist staff with effectively facilitating/implementing complaints management and corrective action.

3 Background

3.1Types of Complaints

3.1.1 Complaints dealt with by FAIS traditionally related to a financial service rendered by a financial services provider or representative. Relevant complainants alleged that the provider or representative:

• has contravened or failed to comply with a provision of this Act and that as a result thereof, the complainant has suffered, or is likely to suffer, financial prejudice or damage;
• has willfully or negligently rendered a financial service to the complainant which has caused prejudice or damage to the complainant, or which is likely to result in such prejudice or damage; or
• has treated the complainant unfairly.

3.1.2. Complaints in terms of this policy includes the TCF principles and therefore also refers to any of the following categories:

• Product design and pricing (e.g. inadequate or too expensive);
• Lead generation (e.g. no response to lead);
• Sales and on-boarding (e.g. staff conduct);
• Fulfilment (e.g. documents not received);
• Cancellations (e.g. penalties applied);
• Retention (e.g. unable to renew / staff conduct); and/or
• Third parties and where applicable recoveries.