Dispute Resolution Process
Bricklet has adopted the guidelines as set out in the Australian Investments and Securities Commission Regulatory Guide 165 (ASIC RG165) in relation to the managing of any internal or external complaints or disputes of our customers.
Should you express to us any dissatisfaction in relation to any of Bricklet’s products or services, the below describes the process you/we will undertake in order to resolve or escalate these matters to the point of resolution.
Per the guidelines, a complaint is defined as follows:
An expression of dissatisfaction made to an organisation, related to its products or services, or the complaints handling process itself, where a response or resolution is explicitly or implicitly expected” – RG165
Bricklet always places our customers first and foremost, and our complaints process is designed to ensure this.
Our customer’s confidence in us is maintained through a timely, transparent and effective dispute resolution process.
As a consequence, Bricklet follows the guidelines relating to an effective internal dispute resolution (“IDR”) process defined in the RG165.67:
“IDR procedures can be used to deal effectively with and monitor, all forms of consumer inquiry, complaint or dispute…
- the opportunity to resolve complaints or disputes quickly and directly;
- the ability to identify and address recurring or systemic problems;
- the capacity to provide solutions to problems rather than have remedies imposed by an external body; and
- the chance to improve levels of customer and investor confidence and satisfaction.”
Guiding Principles of the Bricklet Internal Dispute Resolution Process and Reporting Requirements
Bricklet will apply the Guiding Principles of the Regulatory Guide 165, and will base its reporting requirements as follows:
- Accountability – Bricklet complaints will be handled under a formal and structured approach with the Bricklet Operations Support Manager and Chief Compliance Officer to oversight and direct response. It will include visible and clear actions and decisions in respect of the complaints made and agreed with our customers.
- Confidentiality – Bricklet will not disclose personally identifiable information to a third party concerning a complaint unless it is required to address the complaint between Bricklet and our customer. We will always first seek written approval from our customers to do so.
- Customer Focus Approach – Bricklet is committed to being supportive, helpful and transparent in communicating with our customers.
We will use plain English and embrace feedback from our customers to adopt constant improvements to our products and services.
- Continual Improvement – Bricklet is constantly looking for continual improvement and our IDR process will continue to evolve and adapt to learnings, which will be adopted as a continuous improvement process.
- Charges – Bricklet will not charge our customers for any time or materials involved in seeking a resolution to a customer complaint.
- Objective – Bricklet will address complaints in an equitable, objective, and unbiased manner, and in responding to complaints, Bricklet will give reasons for how we reached the decision together with clearly addressing the issues raised in the initial dispute.
Our responses will be in writing, referring to applicable provisions in legislation, codes, standards, and procedures.
Internal Dispute Resolution (“IDR”)
Should you have a dissatisfaction with any of our products or services, please submit your complaint to a Bricklet Consultant via any of the contact methods listed below.
Please include the following information when submitting your complaint:
- Your name;
- Your contact details;
- Your preferred contact method (phone, email, letter), and
- The details of your complaint.
The Bricklet Consultant’s contact details are:
Title: Operations Support Manager
Phone: 1300 733 253
Email: firstname.lastname@example.org (Attention: Complaints)
Address: Level 2, 6 The Corso, Manly NSW 2095
Bricklet Investigation Process
The Bricklet Operations Support Manager will review the complaint carefully and promptly taking such steps and reviewing such documents as a reasonable person would do.
(i) Receiving Complaints
The Bricklet Operations Support Manager will initially be responsible for addressing and handling all the complaints or disputes received.
(ii) Investigating Complaints
You can make a complaint at any time.
Once your complaint has been lodged, Bricklet will acknowledge receipt within five (5) business days of the complaint being received.
(iii) Responding to Complaints – (Time Limits)
The Bricklet Operations Support Manager will aim to resolve the complaint as soon as possible upon receipt. Notwithstanding, the Bricklet Operations Support Manager will investigate the complaint and endeavor to provide you with a written response to resolve the complaint within thirty (30) calendar days of your complaint.
If the Bricklet Operations Support Manager is unable to resolve the complaint directly, they will escalate the matter to the Chief Compliance Officer for deliberation and expected resolution.
If the dispute continues to be unresolved after escalation, the complaint will be further escalated, if not already done so, to the Bricklet Chief Executive Officer for further deliberation.
This escalation will occur within the specified resolution period of thirty (30) calendar days from receipt of your complaint. Bricklet will, however, continue to keep you informed of the progress of the complaint during this thirty (30) day period.
If your complaint remains unresolved after thirty (30) calendar days, you will be advised in writing that additional time is required to complete the investigation and to provide a response.
(iv) Referring Unresolved Complaints – External Dispute Resolution (“EDR”)
When the complaint is resolved, you will receive a final response letter within 45 days, informing you of the final outcome of your complaint or dispute.
If you believe the complaint has been unsatisfactorily resolved, you may undertake the following actions:
- Enforce your right to take the complaint or dispute to EDR, and
- If you are not satisfied with the response/outcome, your right to lodge a complaint with the Australian Financial Complaints Authority (“AFCA”).
Bricklet is a member of AFCA, and if agreement or resolution has not been achieved under the IDR process, you can refer the issue to AFCA.
AFCA will only become involved in a dispute once an organization and its customer have extinguished all avenues of resolution between them under the IDR process.
AFCA is an independent and objective financial complaints authority that manages and seeks to resolve complaints between organisations and their customers where there has been non-resolution or a breakdown in the IDR process.
The AFCA contact details are:
Australian Financial Complaints Authority
Phone: 1800 931 678
Mail: Australian Financial Complaints Authority GPO Box 3 Melbourne VIC 3001
Also, if your complaint remains outstanding within forty-five (45) days, Bricklet must write to you to:
- Inform you of the reasons for the delay and the process undertaken to investigate your complaint;
- Specify a date when a decision can be reasonably expected;
- Informs you of your right to take your complaint or dispute to an EDR, and
- If you are not satisfied with our response, you may lodge a complaint with the Australian Financial Complaints Authority.
(v) Recording Information about Complaints
Bricklet will maintain a Complaints Register. This register will record all details of complaints received with each complaint having a specific and secure file directory to ensure all documentation and correspondence is held under an ordered process to ensure ease of recovery and transparency.
(vi) Identifying and Recording Systemic Issues
The Complaints Register will be the responsibility of Bricklet to maintain. The register will maintain details of all complaints registered and their status.
Senior management will have ready visibility to this register and together with operating staff and the Chief Compliance Officer, will meet regularly as the Complaints Committee to review and undertake learnings and key performance indicators (“KPI’s”) from the Complaints Report, a report produced monthly to provide management with oversight on complaints.
This report will be distributed monthly and will precede the monthly Bricklet Complaints Committee meeting where all parties will meet to discuss new complaints; resolved and unresolved complaints; key performance indicators (volumes of complaints, consistency, and types of complaints), and any other matters relating to the IDR and EDR processes in place at Bricklet.
If not already identified during regular day-to-day operations, systemic issues will be identified and acted upon under this process.
Types of Outcomes
Outcomes of complaints will be derived depending on the nature and scope of the complaint and any ensuing issues surrounding that complaint. As a consequence, the outcome of a complaint will be aimed towards ensuring the customer will not be disadvantaged or in any worse of a position before the complaint or issue arose. Some types of outcomes may be inclusive of either, or a combination of, the below responses:
- Amendment or change of process that resolves the particular issue;
- Reduction or absolution of any fees;
- Compensation for loss;
- As agreed between Bricklet and our customer to the satisfaction of both parties, and/or
- Whatever is required to take our customer back to the position they were in before the issue/complaint occurred.
Bricklet Step by Step to Complaints Resolution
- Complaint received by Bricklet Operations;
- Complaint acknowledged to the customer, Bricklet provides a reference number for customer tracking;
- The complaint added to the Bricklet Complaints Register folder noting relevant details of complaint and customer together with a date stamp, and
- Depending on the nature of the complaint, relevant Bricklet staff will initiate actions to resolve, which may include investigating claims, identifying potential remedies, and any necessary escalations.
All of the preceding actions and responses concerning a customer complaint will be documented and provided to the customer in writing.
Bricklet management will, on at least a monthly basis, review the Bricklet complaints register and also meet with the Bricklet Complaints Committee to determine any consistent themes or types of complaints to remedy any breakdowns in processes or systems.