Complaints Framework
Purpose
To ensure complaints are accessible, recorded, investigated, resolved, reported and used to improve customer outcomes.
Scope
This document applies to JB Risk Management Consultants (Pty) Ltd ("JB" or "the Practice"), its directors, employees, contractors, consultants, subcontractors, outsourced service providers and any other person acting for or on behalf of the Practice, to the extent relevant to their role.
Regulatory basis
- Consumer Protection Act 68 of 2008, to the extent applicable to services rendered to clients who are natural persons
- Protection of Personal Information Act 4 of 2013 (POPIA)
- Promotion of Access to Information Act 2 of 2000 (PAIA)
- Electronic Communications and Transactions Act 25 of 2002
- Cybercrimes Act 19 of 2020
The legal register must be reviewed at least annually and whenever a relevant law, conduct standard, directive, exemption, guidance note or licence condition changes.
Definition and access
A complaint is an expression of dissatisfaction that alleges, expressly or by implication, that JB Risk Management Consultants (Pty) Ltd ("JBRMC"), its service, advice, deliverables, conduct or failure has caused or may cause loss, material distress, prejudice or an unfair outcome, and seeks a response or redress. A complaint is accepted through any reasonable channel and is not rejected merely because the client uses informal language.
Complaint principles
- Free and easy access.
- Impartial and competent investigation.
- Prompt acknowledgement and regular progress updates.
- Plain-language reasons supported by evidence.
- Appropriate redress and correction where the complaint is upheld.
- Clear internal review and external escalation rights.
- No retaliation, obstruction or unreasonable barrier.
- Root-cause analysis and governing-body reporting.
Process flow
- Receive and protect — Any staff member. Recognise the complaint, preserve records and send it to the complaints owner immediately.
- Acknowledge and log — Complaints owner. Provide reference, contact person, process, information needed and expected timing.
- Classify and prioritise — Complaints owner / compliance. Categorise by outcome, service line, issue, vulnerability, severity and reportability.
- Investigate — Independent competent person. Review the engagement file, correspondence, deliverables, communications, system records, scope of work and any third-party evidence.
- Decide and redress — Authorised decision-maker. Reach a fair decision, approve redress and correct the underlying issue.
- Communicate outcome — Complaints owner. Give reasons, redress, implementation timing and escalation rights in writing.
- Close and learn — Compliance / owner. Confirm commitments, update register, identify root cause and track remediation.
Service standards
- Acknowledgement: As soon as possible, normally within 1 business day. Personal response; automated receipt is supplementary.
- Information request: With acknowledgement or promptly after assessment. Request only relevant information and assist vulnerable clients.
- Progress update: At least every 10 business days or earlier if promised. Explain delay and revised date.
- Final response: As soon as reasonably possible and within the applicable legal or engagement-letter standard. Complete reasons, redress and escalation rights.
- Urgent / high-risk complaint: Immediate triage. Protect client relationships, data, limitation periods and regulatory duties.
Complaint categories
- Advice and engagement scope: Suitability, disclosure, scoping, deliverable specification and engagement letter/mandate terms
- Deliverable quality and performance: Framework, policy, register or report quality, and whether the deliverable met the agreed brief and standard
- Service and engagement management: Delay, communication, scheduling, responsiveness and project management
- Fees and billing: Incorrect invoice, scope-creep charges, billing disputes and refunds
- Staff conduct and professionalism: Behaviour, competence or professionalism of consultants or representatives
- Confidentiality and data privacy: Unauthorised access, disclosure, marketing or data-quality issue
- Complaint handling: Accessibility, delay, unfairness, non-communication or escalation failure
External escalation details
As a compliance consulting practice, JBRMC is not subject to an industry ombud scheme. Unresolved complaints may be referred to the Information Regulator (for privacy-related complaints under POPIA/PAIA), a relevant professional or industry body of which JB is a member, or pursued through the dispute-resolution or legal-recourse provisions of the applicable engagement letter. The operational complaint template must state the correct escalation route and verified contact details before issue.
Roles and accountability
- Director: Ensure an effective framework, approve redress authority and review trends.
- Complaints owner: Log, coordinate, communicate and maintain the register.
- Investigator / decision-maker: Investigate impartially and decide within delegated authority.
- Compliance: Monitor categorisation, fairness, timeframes, root causes and reportability.
- Consultant / staff: Recognise, preserve and refer complaints immediately; assist the investigation.
- Subcontractor / outsourced provider: Provide evidence and cooperate under the applicable agreement.