Complaints Management Policy

Purpose of this Complaints Policy

In terms of the FAIS General Code of Conduct, SV Capital must have a documented complaints management and resolution procedure that enables the consideration of complaints after suitable investigation and review of the information and circumstances, and delivers on our commitment and legal obligation to treat clients fairly.

What Is a Complaint?

We consider the following laws and codes to be applicable: the FAIS Act, FAIS General Code of Conduct and Fit & Proper Regulations, the Insurance Act and the Policyholder Protection Rules, as well as the FIA Code of Conduct.

A complaint may be lodged by someone representing the client, or even by someone we have marketed to, and includes an individual member of any scheme business we write.

All complaints must be handled in accordance with this policy. However, any complaint received and resolved to the client's satisfaction within five (5) business days will be captured as a "query" in our complaints management system and will not require formal reporting.

Responsibilities

SV Capital has appointed the Client Services Team as the primary team to investigate and resolve any complaints.

The Client Services Team, through their position as client facing, has appropriate access to the necessary records and sufficient authority to investigate and make final decisions to resolve complaints. They have the necessary experience, knowledge, and skills in complaints handling, TCF, our products and services, and the legislative framework.

We do not remunerate the Client Services Team in relation to any outcome or number of complaints resolved.

We will ensure that no cases of conflict of interest arise in the handling of complaints. Should any person handling a complaint determine that they are in a conflicted position, an alternate person will take over the role. This change will be determined by Kagiso Tlouatla.

Categorisation of Complaints

Any complaints received will be recorded in our complaints management system and categorised as follows:

Escalation and Review

Should a complaint not be resolved by the initial complaints handler, it will be escalated to Kagiso Tlouatla. Similarly, should a complainant wish to escalate a complaint beyond the initial complaints handler, it will also be escalated to Kagiso Tlouatla.

When reviewing any complaint, the complaints handler will ensure they take a balanced and fair approach to ensure the interests of all parties are addressed. Should they be unsure, they will liaise with their immediate manager who may then escalate the complaint to Kagiso Tlouatla should they see fit to do so.

Decisions

Where SV Capital commits to any payment in regard to any complaint, we will make the payment within 7 days or within the number of days as agreed with the complainant.

Where we reject a complaint, we will provide the complainant with clear and adequate reasons for the decision, as well as the options they have to take the issue further and the applicable time limits.

Records of Complaints

SV Capital understands the importance of accurate and reliable information regarding complaints and will ensure that records are kept securely as part of our record keeping procedures and POPIA policy.

Our complaints management system records the following for all complaints:

• Name, applicable account/investment number, and contact details of the complainant and their representative
• Copies of all relevant evidence, correspondence, and decisions
• The category of the complaint
• Status of the complaint
• Date stamps of actions including all interactions with complainants

Our complaints management system enables us to draw the following metrics:

• Number of complaints received / decided in favour of the client / rejected
• Reasons for rejected complaints
• Number of complaints escalated by complainants or referred to an Ombud
• Results of complaints referred to an Ombud
• Number and amount of compensation payments and goodwill payments made
• Number of complaints outstanding

This information will be reported to Kagiso Tlouatla at the beginning of the second week of every month. Kagiso Tlouatla and Ayanda Majola will review complaints information at least monthly and take any rectifying action they consider necessary. All complaints records enjoy the protections of our POPIA Policy.

Communication with Complainants

SV Capital is committed to a transparent and accessible complaints process. As such we will:

• Never charge complainants to submit complaints
• Ensure all communications are in plain language
• Provide each complainant with a single contact point for their complaint

To ensure we handle complaints fairly, we will request the complainant to provide the following information in writing via email or our online complaints portal:

• The account number of the investment in question
• The details of the individual who initially dealt with the client (if applicable)
• An explanation of the client's complaint
• An explanation of the client's expectation from us
• Copies of any relevant documents at the client's disposal

Complaints Handling Process

Upon receipt of a complaint, we will follow the process below:

Any extensions to these timeframes are at the discretion of Kagiso Tlouatla, who will liaise directly with the client in such cases.

Engagement with the Ombud

SV Capital is aware of the vital role the various Ombuds and Adjudicators play in creating fair outcomes for policyholders, intermediaries, and providers in the financial services industry. Our engagement with their offices and representatives will always be honest, professional, and transparent.

To ensure our clients have access to the Ombuds, we include their details in our disclosure documents and on our website. We will also provide this information to complainants during the complaints process.

Should a complainant approach the Ombud directly without informing us of their complaint, we will entertain their complaint and follow the procedures described in this policy upon notification by the Ombud.

How to Submit a Complaint