Complaints Policy
1 - Policy Statement
At Faciit, the interests and well-being of our customers guide every decision we make. It is our firm commitment to consistently treat our customers fairly, honestly, and with integrity at all stages of the customer relationship, including during our complaints handling process.
We actively foster a culture of openness, transparency, and fairness. Our robust complaints procedures are designed not merely to maintain regulatory compliance, but also to ensure that we deliver positive outcomes, prevent customer harm, and continuously improve our customer service practices.
2 - Background
Effective complaints handling is an essential aspect of consumer protection and is central to the regulatory objectives of the Financial Conduct Authority (FCA). The FCA's rules on complaints handling (DISP) outline clear requirements for firms, designed to ensure customers receive fair treatment and that complaints processes are efficient, transparent, and consistent.
The introduction of the FCA Consumer Duty has further heightened regulatory expectations. Firms must now ensure that their complaint handling procedures not only meet DISP requirements but proactively demonstrate that they are structured to achieve good outcomes for consumers, prevent foreseeable harm, and learn from customer feedback.
This Complaints Policy sets out how Faciit meets these requirements and identifies, records, investigates, resolves, and learns from complaints.
3 - Scope
This policy applies to all Faciit employees (including temporary staff, agents, contractors, and consultants) and third-party providers offering services on behalf of Faciit.
Where complaints involve the conduct of third-party providers, Faciit will maintain ultimate responsibility for ensuring these complaints are handled fairly, effectively, and promptly, as required under FCA DISP regulations.
If the complaint is related to an FCA-authorised third-party provider, where appropriate, we may forward the complaint to that third party under the complaint forwarding rules in DISP.
Regulatory Requirements
Faciit complies fully with the FCA's rules, including DISP and the Consumer Duty, requiring firms to handle complaints fairly, consistently, and transparently.
We will provide a full account of decisions within eight weeks if complaints cannot be resolved within three business days, clearly outlining the rationale for outcomes and escalation routes for dissatisfied customers to the Financial Ombudsman Service (FOS).
If we are not able to provide a final response within eight weeks, we will inform the customer of the delay and of the right to then refer the complaint to FOS.
In all final response communications, we will provide details of any deadlines the customer has to refer to FOS, and the fact that such a referral can be made free of charge.
We will provide a copy of our complaints handling procedure on request or when acknowledging a complaint.
4 - Conduct Risk and Complaints
Conduct risk is defined by the FCA as the risk that a firm's behaviour or actions leads to poor outcomes for customers. Faciit is committed to act to deliver good outcomes, proactively avoiding foreseeable customer harm.
Effective complaints handling serves as a critical factor in preventing poor consumer outcomes. Complaints provide Faciit with vital intelligence about customer satisfaction, business conduct, and product effectiveness. This information enables the identification and rectification of issues, preventing the recurrence of harmful practices or inadequate customer experiences.
Faciit's approach to complaints is designed not only to respond fairly and promptly but also to act as an early-warning mechanism to identify, assess, mitigate, and rectify conduct risks before they escalate.
Through detailed root cause analysis, proactive monitoring, and robust management information (MI) reporting, Faciit ensures that complaints drive continuous improvement across all business areas. Complaint insights feed directly into strategic planning, product design, and training programmes, ensuring alignment with regulatory standards and positive consumer outcomes.
Our root cause analysis clearly differentiates between isolated cases and systemic issues. Faciit will assess each root cause, considering if the issues identified may impact other customers or processes, even those who have not yet made complaints. Responsibility for remedial action following root cause analysis will be clearly assigned to specific senior personnel, ensuring effective oversight and implementation.
Senior management at Faciit regularly review complaints data, root cause analysis outcomes, and MI reports to ensure alignment with our regulatory obligations and internal standards. Specific individuals within senior management, including the SMF holder responsible for customer outcomes, maintain active oversight of our complaint-handling processes, providing independent oversight and governance. This ensures continuous identification, management, and mitigation of conduct risks across the organisation.
5 - Definition and Eligibility of Complaints
An eligible complainant is defined by the FCA as (as applicable to Faciit's regulated activities):
- a consumer
- a micro-enterprise
- a charity which has an annual income of less than £6.5 million at the time the complainant refers the complaint to the respondent
- a trustee of a trust which has a net asset value of less than £5 million at the time the complainant refers the complaint to the respondent
- a small business at the time the complainant refers the complaint to the respondent; or
- a guarantor
A complaint is:
"Any expression of dissatisfaction, whether oral or written, whether justified or not, about the firm's provision of (or failure to provide) a financial service, which alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience".
6 - How to Make a Complaint
Customers can make complaints by way of the following:
Customers will always be able to make a complaint to us free of charge.
7 - Complaint Handling and Communication
Upon receipt, each complaint will be immediately logged and passed to an appropriately trained complaints handler. A written acknowledgment will be provided within three working days, detailing how the complaint will be investigated.
Faciit commits to providing complainants with clear, regular updates outlining progress, the investigation stage reached, next steps, and anticipated resolution timelines. Our communications will always be transparent, clear, and concise.
Complaints resolved within three business days will receive a Summary Resolution Communication, clearly outlining the resolution and the complainant's right to escalate the complaint to the FOS.
Investigation and Resolution
Faciit commits to thoroughly investigating all complaints, using impartial personnel who were not directly involved in the original event that is the subject of the complaint. Investigations will include reviewing all relevant documentation, communications, and, if necessary, customer interviews to clarify all relevant issues.
The final response to a complaint will be provided no later than eight weeks from receipt and will include:
- Acceptance or rejection of the complaint, clearly explained
- Detailed reasoning behind the decision
- Offer of appropriate remedial action or financial redress where justified
- Information clearly setting out the complainant's rights for escalation to the FOS, including FOS contact details and standard explanatory materials.
Where the complaint relates to a product or conduct that is solely within the remit of a third-party lender, Faciit will coordinate with the relevant provider to facilitate an appropriate response, but cannot override lending decisions or mandate redress on their behalf.
Root Cause Analysis and Preventing Customer Harm
Post-resolution, Faciit conducts root cause analysis on complaints to identify underlying issues, systemic problems, and the potential risk of recurrence. Outcomes of this analysis inform proactive changes to policies, procedures, staff training, product improvements, and business practices.
Complaint insights are used specifically to prevent foreseeable customer harm, improve products and processes, and ensure robust compliance with FCA principles, including Consumer Duty.
Where our root cause analysis finds a recurring issue that has impacted customers beyond the original complainant, we will investigate the wider impact and, where appropriate, contact affected customers (even those who have not complained) to provide fair remediation. We will monitor complaint outcomes to ensure they are meeting customers' reasonable expectations and no group of customers is being provided with poor outcomes.
8 - Vulnerable Customers
Faciit is committed to identifying and supporting customers in vulnerable circumstances, recognising that vulnerability can arise from various factors, including health issues, life events, financial hardship, or a lack of digital access.
Faciit recognises the diverse circumstances that create vulnerability, such as health issues, significant life events, or financial difficulty. We actively encourage customers to disclose vulnerabilities, ensuring staff are specially trained to ask sensitive questions, provide empathetic responses, and record disclosures appropriately. Faciit offers tailored complaint resolution approaches, adjusting timelines and communication channels to best support vulnerable customers.
To ensure fair treatment and positive outcomes for these customers, we will:
- Proactively encourage disclosure by creating an environment where customers feel comfortable disclosing their vulnerabilities, this includes training staff to ask appropriate questions and handle sensitive information with care
- Offer flexible support options by providing multiple communication channels and adapt our services to meet the specific needs of vulnerable customers, ensuring accessibility and ease of use
- Implement effective monitoring to use data to identify patterns that may indicate vulnerabilities, allowing us to tailor our support and prevent potential harm
By integrating these practices, Faciit aims to uphold the highest standards of customer care, ensuring that vulnerable customers receive the attention and support they need throughout their interactions with us.
9 - Management Information (MI) and Reporting
Faciit regularly generates comprehensive MI reports on complaints handling, including complaint volumes, categories, resolution timescales, outcomes, FOS escalations, root cause analysis findings, and improvement actions. These reports are reviewed monthly by senior management and at least annually by the Board.
10 - Data Protection and Record Keeping
All complaints and related personal data will be securely managed and processed in strict compliance with applicable data protection legislation. Faciit maintains comprehensive records of all complaints handling activities, including correspondence, investigative actions, and resolutions. Records are retained for at least seven years, ensuring effective regulatory supervision can be maintained, and that complaints records can be accessed when required.
11 - Governance and Accountability
Faciit's Senior Manager holding SMF 16 responsibility is accountable for oversight of the complaints management framework, ensuring compliance with FCA rules, (including DISP), and the Consumer Duty. This role includes ensuring effective training, monitoring, compliance audits, and reporting of complaint handling performance to senior management and the FCA.
12 - Policy Review and Approval
This Complaints Policy will be reviewed annually or sooner if regulatory changes occur. Reviews will ensure ongoing compliance with FCA DISP rules, Consumer Duty, and evolving best practice.