Complaints Handling Policy

Our Complaint Handling Process

The following process relates to complaints that are submitted pertaining to the Bank and/or its subsidiaries and are within the scope of this policy (see Section 2). Please note that, if you are submitting a complaint to a Delivery Partner, Business Support Partner or Finance Provider, you should request a copy of their specific Complaints policy.

When the Bank receives an individual’s complaint about the Bank and/or its subsidiaries and within the scope of this policy, it will endeavour to address the matter immediately, effectively, and in a fair and reasonable manner.

If a resolution cannot be reached within three working days, we will send you a written acknowledgement. This written acknowledgement will:

• Acknowledge that a complaint has been submitted.
• Advise you that the Complaints Manager is reviewing the matter.
• Inform you that the matter will be investigated and that a Final Response will be provided in writing within eight weeks of the complaint being received (although the Bank aims to resolve all matters sooner than this where possible).

From this point forward, the Complaints Manager will assume responsibility for ensuring your complaint is resolved within eight weeks. The Complaints Manager will ensure that the complaint is investigated by the appropriate individuals within this timescale.

Once the matter has been investigated and the Bank’s Customer Relations Team has made a decision regarding the complaint, you will receive a written Final Response from the Complaints Manager.

This Final Response will be provided to you and will:

• Acknowledge all of the concerns within the original complaint.
• Outline the findings of the investigation.
• Clarify whether the complaint was ‘upheld’ or ‘not upheld’.
• Outline the proposed resolution (if applicable).
• Inform you that if you are not satisfied with the Final Response, you have the right to escalate the matter. You must do this within six months of receiving your Final Response.

In exceptional circumstances, the Complaints Manager may not be able to provide you with a Final Response within eight weeks. In these instances, a holding communication will be sent to you in writing.

This holding communication will:

• Inform you of the delay.
• Outline the reasons for the delay.
• Provide an expected response time for sending the Final Response.

Escalations

In the unfortunate event that you remain dissatisfied with the final outcome of your response provided by us you have the right to escalate your complaint.

If complainants are not satisfied with the response to their complaint, they may ask for the complaint to be reviewed by the Bank’s Complaints Escalation Panel. This must be requested in writing and no longer than six months after receipt of your final outcome.

This panel will be composed of at least two of the Bank’s Senior Leadership Team, together with a representative of the Bank’s Risk & Compliance team, who have no direct involvement with the issue(s) under review.

The complainant will be invited to submit any further written submissions to be reviewed by the panel.

The review should normally take place within thirty working days of receipt of the request. If this is not possible, the complainant will be informed of the review date.

The panel can:

• uphold the complaint in whole or in part.
• decide on the appropriate action to be taken to resolve the complaint.
• dismiss the complaint in whole or in part.

The complainant will be notified of the panel’s decision in writing five working days after the review has been completed.

If you are dissatisfied with our response to a data protection complaint, you can request for your complaint to be reviewed by our Data Protection Officer as part of our escalation panel. If you remain dissatisfied with the response, you have the right to refer your complaint directly to the Information Commissioner’s Office (ICO).

Please note, if you have made a complaint directly to one of the Bank’s Delivery Partners, Business Support Partner or Finance Provider, and they are regulated by the FCA, you have the right to refer the complaint to the Financial Ombudsman Service (FOS). You should be aware that FOS will refer the matter back to the relevant party to resolve if you have not engaged with that party in the first instance and there are some circumstances where they may not be able to consider the complaint. Further information in respect of the services available from FOS are available from their website.

You should also be aware FOS can only consider complaints that fall within its jurisdiction, including whether a complainant meets FOS’s definition of a consumer. We are aware some SME lending complaints do not meet this definition, but this depends on individual circumstances, and whether a complaint is within FOS’s remit is a matter for FOS to determine

If your complaint is about a Start Up Loans Business Support Partner who is not regulated by the FCA and does not offer the right to refer your complaint to FOS, you can refer your complaint to the Finance Provider for review.

For Future Fund, if complainants are not satisfied with the response to their complaint, they may request for the complaint to be escalated for review by the Bank’s Chief Risk Officer. The Chief Risk Officer may elect to refer the complaint to the Bank’s Complaints Escalation Panel.

For complaints relating to information held by Cifas, if complainants are not satisfied with the response to their complaint, they will need to escalate directly to Cifas as advised on the Cifas website.

The Bank reserves the right to take any appropriate action to protect itself from any unfounded, malicious or vexatious allegations or complaints.

The Bank Chair has delegated the responsibility for handling complaints in line with this policy and will not respond personally to a complaint brought directly to them. Untrue allegations could lead to legal action for defamation. This policy does not confer any contractual rights and the Bank reserves the right to update this policy and its key terms at any time.

The Bank’s Privacy Notice is available here.

Definition of Terms

Delivery Partners/Business Support Partners

These are a network of organisations that work with the Bank to provide essential support for businesses and deliver or support those seeking to access finance.

Finance Provider

This is The Enterprise Fund Limited t/a GC Business Finance, who are the Lender under the Start Up Loans Scheme. The Finance Provider is authorised and regulated by the FCA. They will be a Start Up Loans borrower’s primary point of contact for matters relating to a Start Up Loans loan administration, loan status and repayment arrangements.