Complaints Policy & Process

1. How to Lodge a Complaint

1. As a customer or prospective customer, if you have a complaint against Minit Money, it must be submitted to us in writing. It can be submitted either by hand or via email at the contact details provided in this document.

2. ​You should provide sufficient detail regarding the complaint.

3. The complainant must include their full name, identity number, and cell phone number for identification purposes.

4. We will keep a record of the complaint and maintain such record for 5 (five) years, as required by legislation.

2. Who Will Handle Your Complaint?

1. Once your complaint has been received, it will be allocated to and dealt with by adequately trained staff.

2. The person responsible for your complaint will provide you with their contact details and the reference number of your complaint (if applicable).

3. The Key Individual will have oversight over the complaints allocated to various personnel, and you may direct any queries to the Key Individual whose details are recorded in this document.

3. Receive & Classify

1. We will ensure that all potential issues are captured and classified for escalation, review, and action as required.

2. Any complaint, issue, or negative customer interaction must be documented in writing and logged and classified for action.

3. A third party acting on behalf of a complainant must deliver a certified or original consent or power of attorney to act on their behalf. Should such a third party fail to deliver consent or power of attorney, no further dealings will be pursued with that party until the proper authority is obtained. The complaint will, however, be taken up directly with the complainant on whose behalf the complaint is made.

4. All complaints must be formally logged using the following system: The process adopted to log complaints, whether manual or via a computer database system:

   • All formal complaints must be submitted in writing and emailed to complaints@minitmoney.com or delivered by hand to Minit Money’s offices located at Workshop 17, The Bank Building, Craddock Avenue, Rosebank, Johannesburg, South Africa 2196.

   • Complaints must include the complainant’s full name, identity number, and cell phone number.

   • Upon receipt of the complaint, the Complaints Manager will review it and acknowledge receipt by way of a formal letter (as attached to the end of this document marked as Annexure A), via email within 48 (forty-eight) hours of receiving the complaint. This letter will contain a complaint reference number that should be used in all correspondence.

   • Within 72 (seventy-two) hours, the details of the individual handling the complaint will be sent to the complainant.

   • The complaint will be classified according to a risk rating as described below, and the complainant will be informed of the expected turnaround time to resolve the complaint based on the risk level.

   • The complaint will be investigated and, if possible, resolved.

   • Should the outcome of the complaint be unfavorable towards the complainant, a formal letter (as attached to the end of this document marked as Annexure B) will be sent to the complainant via email, indicating the unfavorable outcome and providing the complainant with the details of the FAIS Ombud should the

4. Risk

All complaints will be prioritized as follows:

1. Risk 1 – Routine complaints with potential low business impact. This requires a response to the customer within 15 working days.

   1. Routine complaints have the potential to become serious or official complaints if disregarded or ignored by a financial services provider.

   2. The staff member logging the complaint should review the complaint and its priority with the Key Individual before proceeding to the next step.

   3. The Key Individual will decide on the appropriate person(s) to carry out subsequent steps, including the investigation

2. Risk 2 – Urgent complaints with serious business impact. This requires a response to the customer within 5–10 working days.

   1. Serious complaints include those logged on media platforms, received from legal advisors, or that immediately evidence a contravention of legislation requirements, such as failure to conduct a proper needs analysis.

   2. These complaints may cause reputational harm to a financial services provider and/or financial loss to a customer.

   3. These complaints should ideally be handled by the Key Individual or a suitable senior person delegated by the Key Individual.

   4. Complaints from third parties and/or legal advisors will be responded to within 24 hours, acknowledging receipt of the complaint and further requesting authority to act on the complainants’ behalf, such as a power of attorney or consent from the complainant.

   5. No information will be divulged to a third party who does not have the proper authority to act on a complainant’s behalf.

3. Risk 3 – Urgent official complaints received from regulators, e.g., FAIS Ombud. The regulator usually stipulates a response time of 30 days from receipt of the complaint.

   1. Official complaints should be handled by the Key Individual.

   2. The investigation of the complaint may be delegated to a suitable senior person selected by the Key Individual, who may collate the required draft response and attachments.

   3. The Key Individual will ultimately be responsible for compiling the response to the regulator.

   4. The response to the regulator should be made within the stipulated turnaround time.

5. Categorisation

1. Complaints will be categorised according to their nature, e.g., service, product-related, features, performance, advice given, etc.

2. These categories are then narrowed down to the impact on customers. The impact of the complaint is measured by further categorising it according to the following TCF Outcomes:

   1. TCF Outcome 1 – Complaints relating to the design of a product or service, including product features and charges.

   2. TCF Outcome 2 – Complaints related to unsuitable or inaccurate, misleading, confusing, or unclear information provided to a customer throughout the life cycle of a product. This could include advice, product information, and information provided in advertising or marketing material about a product or service rendered, etc. These disclosures include the conflict of interest disclosures required by the General Code of Conduct of FAIS (Code), Sections 4 and 5 of the Code, or any other disclosure requirements in terms of the Code or other legislation.

   3. TCF Outcome 3 – Complaints relating to advice given to a customer by an advisor that was misleading, inappropriate, and/or tainted with undisclosed conflicts of interest. Inappropriate advice resulting from a lack of knowledge, skill, or experience on the part of the advisor regarding the product or service rendered would also be included here. The failure to conduct a needs analysis and consider the customer’s financial position, goals, or life stage would amount to a contravention of suitable advice requirements, and any complaint associated with this would fall into this category.

   4. TCF Outcome 4 – Complaints pertaining to product performance and service-related issues. This includes complaints related to a customer’s disappointment with limitations in a product or service performance of which they were unaware, as well as the inability of a product to meet a customer’s expectations. Complaints related to a product supplier’s exercise of a right to terminate a product or amend its terms will also be included in this category.

   5. TCF Outcome 5 – Complaints relating to product accessibility, changes or switches, complaints handling, and claims will be categorised here.

3. Other categories may be developed that are appropriate to this outcome and will be incorporated into the policy and attached complaint register.

6. Acknowledge

1. All complaints must be acknowledged within 24 hours of receipt.

2. Where an acknowledgment is made telephonically, it will be followed up with a written response, either by SMS or email.

3. A complaint reference number will be dispatched to the complainant upon acknowledgment of the complaint.

4. The details of the person allocated to the complaint will be dispatched to the complainant within 48 hours of receipt.

7. Investigate

1. The investigation will be driven by analyzing the root cause of the complaint to enable appropriate resolution and to avoid, if possible, its recurrence.

2. This may require the identification and clarification of both internal and external key facts.

3. Should a complaint relate to product features or services handled solely by a product supplier, this matter will be escalated and appropriately dealt with in conjunction with the product supplier, ensuring that it is resolved to the satisfaction of the complainant.

4. All areas of interaction and communication will be documented, and where appropriate, consent will be obtained from the complainant to ensure that no personal information is divulged or processed without the complainant’s knowledge or consent.

5. During the investigation process, the complainant will be kept appropriately updated on the progress of the investigation.

8. Resolve & Confirm

1. Ensure that the proposed resolution meets Treating Customer Fairly outcomes, does not prejudice the financial services provider or complainant, and does not involve any unnecessary legal or financial implications.

2. The proposed action will be documented and discussed, and agreed upon with the Complaints Manager and/or affected Key Individual and Representative.

3. The signed-off resolution will then be discussed and reviewed with the complainant to ensure fairness and clarity, further ensuring that the resolution addresses the root cause of the complaint.

4. The review should include recognition and documentation of any underlying issues that contributed to the complaint, along with recommendations for actions to prevent further occurrence.

9. Respond To Customer

1. The details of the findings and proposed resolution should be clearly explained (in written or verbal form as appropriate) to the customer – within the agreed timescales.

2. Where a complaint cannot be addressed within three weeks by the financial services provider, a written acknowledgement of the complaint, with contact details of the FAIS Ombud, must be sent to the complainant.

3. If within 6 (six weeks) of receipt of a complaint, Minit Money (Pty) Ltd has been unable to resolve the complaint to the satisfaction of a complainant, the complainant may:

   1. refer the complaint to the Office of the FAIS Ombud if he/she wishes to pursue the matter; and

   2. the complainant MUST do so within 6 (six months) of receipt of such notification.

10. Follow Up & Review

1. Complaints will be diarised to ensure they remain within the appropriate turnaround times.

2. Should a complaint exceed the turnaround time due to unforeseen and reasonable circumstances, the complainant will be kept appropriately informed of the reasons for the delay, and a speedy resolution will continuously be sought.

3. A complainant will be kept appropriately informed throughout the complaints process regarding the resolution being sought.

4. Upon resolution of the complaint, a follow-up will be conducted to ascertain whether the customer was satisfied with the complaints handling process and the resolution sought, and whether the resolution was proper and fair.

5. Any negative responses will be addressed in the monthly review of complaints.

11. Quality Assurance & Close

1. The Key Individual will ensure that all employees of Minit Money (Pty) Ltd have access to the complaints resolution manual.

2. Customers will be made aware of the complaints resolution manual and will have access to it upon request.

3. All complaints will be reviewed monthly and used as TCF Management Information to improve overall TCF outcomes.

4. All complaints will be actioned with the aim of preventing recurrence, where feasible.