AIICO CAPITAL LIMITED

COMPLAINT MANAGEMENT

FRAMEWORK

2018

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Table of Content

1. INTRODUCTION………………………………………………………………………………………………………03

2. OBJECTIVES…………………………………………………………………………………………………………...03

3. KEY FEATURES…………………………………………………………………………………………….…………04

4. POLICY STATEMENT………………………………………………………………………………………….……05

5. TYPES OF CLIENT COMPLAINTS………………………………………………………………………………05

6. RISK RATING OF COMPLAINTS………………………………………………….……………………………06

7. CLIENT COMPLAINT MANAGEMENT PROCEDURE…………………………………………………..06

8. REGISTER OF COMPLAINTS………………………………………………………………………………….…08

9. DISPUTE RESOLUTION……………………………………………………………………………………………10

10. RECORD RETENTION…………………………………………………………………………………………….11

11. COMMITMENT AND RESOURCES……………………………………………………………………….…11

12. REPORTING………………………………………………………………………………………………….………12

13. PERIODIC REVIEW OF THE FRAMEWORK………………………………………………………...……12

14. APPROVAL…………………………………………………………………………………………………………...12

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1. INTRODUCTION

AIICO Capital Limited is a client and service oriented company that sees client’s satisfaction as

wealth creation and views complaint management process as an avenue to continuously deliver

satisfactory services to our Clients. In order to articulately manage the process, we have

developed an approach in line with the SEC Complaint Management Framework for managing

complaints which are regarded as Client Compliant Management (“CCM”).

As a Capital Market Operator (CMO), we recognize the need to establish a Complaint

Management Framework which will address complaints professionally, competently, timely, and

in a manner complaint with the principles of natural justice, equity and good conscience as well

as upholding utmost confidentiality.

2. OBJECTIVES

The objectives of the Complaints Management Framework are to:

2.1 Provide guidance to the individuals who are responsible for handling and resolving

complaints within AIICO Capital Limited

2.2 Ensure clients receive the excellent level of service they are entitled to receive

2.3 Provide an effective method of early detection of failures in service delivery and serve as a

valuable source of feedback on quality of service

2.4 Provide an opportunity for the Company to improve its services and sustain its good reputation

2.5 Ensure adherence to SEC rules relating to the Complaints Management Framework of the

Capital Market Operators.

It is necessary to note that Client complaints can be verbal or written. All complaints must be

recorded and resolved timely in accordance with laid down rules set by the SEC.

3. KEY FEATURES OF AIICO CAPITAL CLIENT COMPLAINT MANAGEMENT FRAMEWORK

The following highlights the key features of the AIICO Capital’s CCMF:

1. Quarterly reporting of client complaints to the regulatory authorities

2. Documented complaint management process that ensures consistency in application

3. Formulation of a Complaint Management Committee.

4. Periodic client complaint management training; and

5. Weekly updates on complaints and resolution to be reported to the Head of Sales and Client

Service / Compliance Officer.

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4. POLICY STATEMENT

The aim of having an efficient Client Complaint Management procedure is to ensure proper

management of complaints brought to the attention of the company for fair resolution. It is

designed to improve the services offered, by helping to detect weakness, remedy unfair

situations and improve operating methods within the system.

The Board and Management are highly committed to promoting an effective and efficient

complaint handling process within the Company and adequate resources shall be deployed

towards ensuring the achievement of this objective. All Complaints received shall be

acknowledged and analyzed towards aiding and ensuring informed and continuous quality

improvement initiatives.

The major aims of this Framework are to:

1. provide accessibility and a platform for clients to communicate any dissatisfaction to AIICO

Capital

2. improve communication links between AIICO Capital and its clients

3. establish and maintain a clear, effective and transparent procedure for reasonable and

prompt management of all client complaints

4. continuous management of clients’ experience enhanced client satisfaction and brand

protection

5. identify developmental and improvement areas in order to provide better services

6. establish a consistent approach and guideline to be observed when attending to complaints;

and

7. comply with regulations on Complaint Management, particularly with the SEC Client

Complaint Framework.

5. TYPES OF CLIENT COMPLAINTS

We recognise that Complaints may fall into one or more of the following categories:

a. Complaints alleging financial losses;

b. Complaints with potential legal/regulatory implications;

c. Complaints alleging failure of service delivery; and

d. Complaints that increases the risk of reputational damage.

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5.1.1. Causes of complaints

The following issues have been identified as causes of clients ‘complaint though the list is

inexhaustive:

• Delay in execution

• Poor Client service

• Failure to carry out instructions

• Negligence, which includes

- Failure to follow through on promises; and

- Failure to carry out instructions.

• Mistakes in the computation of charges/fees

• System errors; and

• Communication and or technological failures

5.2. Channel of Complaint

AIICO Capital’s clients may lodge their complaints through any one or more of the following

channels:

a) Verbal Complaints - Complaints may be reported verbally through our Client Service Help

Desk or Relationship Managers or through members of staff. Complaints may also be verbally

reported via the line 01-2792974.

b) Written Letters - Complaints may be reported through letters addressed to AIICO Capital

Limited at Plot 12, AIICO Plaza, Church Street, Victoria Island, Lagos and marked for the

attention of;

(i) Client Service Unit

(ii) Relationship Manager (where the name is known)

(iii) the Managing Director

c) By Email - Complaints can be reported through emails to the client service email address,

through members of Staff of the Company. This complaint should be sent to

accs@aiicocapital.com.

The recipient of the complaint in respect of clauses a, b and c above shall escalate the

complaint to Senior Management for the purpose of implementing and monitoring compliance

of the Complaint Management Policy. Provided that Senior Management shall assign the duty

of resolution of such complaints to the Complaint Management Committee for resolution in

accordance with Clause 7 below

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6. RISK RATING OF COMPLAINTS

We have categorized Client’s complaints under three board heading of low, medium and high

based on internationally accepted risk rating method and for ease of treatment of complaints.

a) Low risk

Complaints that can easily be resolved via any channel which such complaint is received or shortly

thereafter. This has minimal financial or legal implications and can be handled by any staff

without any specific expertise;

b) Medium risk

Complaints that can be resolved on the spot but require assistance of a support staff at the back

office. This also has minimal financial and legal implications; and

c) High risk

These are Complaints that have financial, legal and or reputational implications and require the

expertise of the centralized complaint management desk within Client Service and the operations

team for resolution.

7. CLIENT COMPLAINT MANAGEMENT PROCEDURE

The procedure for managing client complaints is progressive in nature. Upon the completion of

the first stage, the next stage shall commence and shall continue in that order until final

resolution of the complaint. Note that as soon as a resolution is reached, subsequent stages of

the CCM would be discontinued. The stages are outlined below;

7.1. Acknowledgement upon the receipt of a Client’s complaint, the immediate recipient of the

complaint should take any of the following actions depending on the mode of complaint as listed

under clause 7.

7.1.1. In the case of verbal complaints:

a. An attempt should be made to calm the offended client while an employee with better

knowledge of the situation (preferably the client’s Relationship Manager) is notified;

b. Neither the employee of first contact nor the Relationship Manager is to admit liability on

behalf of the Company or to apportion blame in the presence of the client. The aim here is to

contain the situation until it is escalated to the next stage if required; and

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The complainant’s email address shall be obtained and an email acknowledging receipt of the

verbal complaint shall be sent same day of receiving such complaint. Such email shall detail the

nature of the complaint

c. The client should be informed of the nearest date within which the business will revert to him

on the issues in dispute.

7.1.2. In the case of written complaints

a. The recipient of the letter must send it to Client Service Desk as soon as it is received;

b. Client Service Desk shall immediately send out an acknowledgement to the client within 24

hours (in case of complaint received via email) and within three (3) working days (in case of

complaint received via post) assuring the Client of the receipt of the complaint and the proposed

date of communication of the findings on the issues raised by the complainant in the

correspondence.

Within five (5) hours of receipt of client’s complaint, Client Service Desk shall notify Compliance

Unit of the complaint via email and verbally. The Client Service Desk shall keep a Register of

Complaints.

The Compliance Unit will also send copies of the Complaint and the acknowledgment to the

relevant Competent Authority as part of routine regulatory reporting obligation.

7.2. Timeline for Resolution of Complaints

AIICO Capital’s Policy is to resolve all complaints within ten (6) working days from the date the

complaint is received. After resolution of the complaint, the Company shall notify the relevant

Competent Authority of the resolution of the Complaint within 2 (two) working days.

7.3. Complaints Escalation to the Competent Authority

7.3.1. Complaints not resolved within the time-frame of ten (10) working days shall be referred

to the relevant Competent Authority within two (2) working days either by Client Service or the

Complainant.

A letter and a summary of the proceedings of events leading to the referral and copies of relevant

supporting documents shall be sent to the Competent Authority. Clients are hereby notified that

sanctions may be imposed by the SEC for failure to forward a summary of the proceedings within

the above stated timeline.

7.3.2. If the client is not satisfied with the decision of the Competent Authority, the Complainant

shall have the right to refer the Complaint to the SEC within 2 (two) working days where he/she

is not satisfied with the decision of the Competent.

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7.4 Competent Authority

7.4.1. Complaints referred by Compliance Unit to the relevant Competent Authority shall be

resolved within 20 (twenty) working days of receipt of the Complaint.

The complainant shall refer the complaint to the SEC within two working days, if the decision of

the Competent Authority is unsatisfactory.

• Where there is no relevant Competent Authority or client is not satisfied by the decision

reached, the Complaint shall be referred to the SEC within 3 (three) working days either by the

Company or the Complainant. The summary of the proceedings of events leading to the referral

and copies of relevant supporting documents shall be attached to the letter to the SEC.

8. REGISTER OF COMPLAINTS

8.1. All complaints must immediately be reported to the Head Sales & Client Services;

8.1.1. All complaints must be recorded in the Electronic Complaint Log. The Electronic Complaint

Log must, at least, include the following information:

a. Date of complaint;

b. Complainant’s name;

c. Nature of the complaint and the circumstances;

d. Name of the person who is the subject of the complaint;

e. The product or the services which are subject of the complaint; and

f. The date and summary of the decision reached on the complaint.

g. Remarks and comments

h. Dates of referral to the Competent Authority and/or the SEC, as the case may be

8.2. Scope of Complaints to the Competent Authority and SEC at first instance

8.2.1 Clients shall not lodge at first instance with the relevant Competent Authority or the SEC.

8.2.2. Only complaints between Capital Market Operators and complaints against the Relevant

Authority may be lodged at first instance, with the SEC.

8.2.3. Only complaints

a. against a Competent Authority

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b. against Capital Market Operators by Regulators and or Self-Regulatory Organisations and;

c. trade manipulation, accounting frauds, Ponzi schemes and such other complaints may be

lodged with the SEC in the first instance.

8.3. Escalated Complaints

In cases where the Client had already escalated the complaint to the SEC and the Company is

aware, the Company will write the Regulator within two (2) working days stating that the CCM

process has commenced. The Client will be notified of this and the Company will continue with

the CCM process except instructed otherwise by the Regulator.

8.3.1. Investigation

Where complaints cannot be resolved immediately at the point the Complaint is made, such

complaints will be thoroughly investigated. The head of the relevant Unit or business against

whom the Complaint is levied shall be notified of the Complaint (via email) by the Client Service

Officer. This shall be done on the same day on which the Complaint is received.

In all cases, the occurrence of the complaint shall be recorded in the Complaint Register by the

responsible Client Service Officer within 24 hours of receipt. The issues complained about must

be clearly defined and recorded. Steps taken to ensure the resolution of the complaint as well as

the resolution must also be stated as soon as it occurs.

Investigations of complaints received after 5:00pm shall be initiated latest 8:00am on the next

business day. The head of the Unit against whom the complaint is lodged shall investigate the

true state of affairs leading to the complaint. Investigation must be concluded within 24 hours of

receipt of the email notifying the Unit head of the existence of the Complaint. If a suitable

resolution is reached at this stage, it must be communicated to the following officers before the

client is informed of the decision:

a. Unit Head of the affected department

b. Head, Internal Control

c. Compliance Officer

Communication of the decision reached to the abovementioned officers is to ensure that AIICO

Capital collectively owns the decision communicated to the client.

8.3.2. Escalation

Any unresolved complaints as well as all complaints brought to the Company’s notice by any

Regulator must be escalated to the Complaint Management Committee. The Panel is expected

to take one of the following actions:

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a. Approve the decision communicated as the appropriate resolution to the

complaint. Approval can be done by Circular; or

b. Further investigate all unresolved cases and decide on the best solution to the

complaint.

If a resolution cannot be reached immediately, the head of the affected Unit shall verbally and in

writing communicate with the offended client until a resolution is reached within the timeline

stated in this Framework. All verbal communications must be transcribed and circulated amongst

members of the Complaint Management Committee.

8.3.3 Communication of Decision

All resolutions reached must be promptly communicated to the complainant in writing. In cases

where any Regulator had been informed about the situation, such Regulator must be copied on

all written correspondences to the complainant.

9. DISPUTE RESOLUTION

AIICO Capital will always seek harmonious ways to resolve clients’ complaints. The company will

encourage and pursue the use of alternative dispute resolution techniques in resolving issues to

avert public court cases that may create acrimony between the company and its clients. This

approach will be deployed where all available measures to resolve an issue is unsuccessful. It is

the responsibility of Senior Management to choose an appropriate and independent negotiator,

mediator or arbitrator to mediate. Such person must be independent and shall not;

a) Be a former employee of the Company;

b) Perform other functions that could affect independence; and

c) Be subjected to receive instructions or be influenced by the Company

10. RECORD RETENTION

10.1. CLIENT COMPLAINT REGISTER

Upon resolution of client complaint, the complaint record (which includes details of how the

complaint was resolved) and associated correspondence shall be retained in the records for at

least 7 (seven) years from the date the complaint was received whether or not the Complaint has

been resolved. The date on which the complaint was resolved must be recorded. This record will

also include information on measures taken for resolution of issues logged by Clients.

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11. COMMITMENT AND RESOURCES The Senior Management shall be committed to the laid down procedures. The Senior Management shall act through the Complaint Management Committee to ensure that these procedures are integrated into the culture of the organization and monitored for compliance purposes. The Complaint Management Committee, saddled with the responsibility of executing the terms of this policy, shall sit on ad-hoc basis, with membership comprising of representatives of the following offices:

a. Head of Investment Operations

b. Company Secretary/Legal Officer

c. Head of Client Services

d. Head of Internal Control/Internal Audit e. Compliance Officer f. Heads of Investment Units

The management shall also ensure that: a. All members of staff are educated about and familiar with the internal procedures b. Adequate financial resources are allocated to complaints management and sufficient

levels of authority are delegated to handle the process

c. Adequate systems are put in place and reporting procedures implemented to ensure timely, effective and consistent complaints handling and monitoring

d. Reasonable steps are taken to ensure that clients know about the existence of the complaints handling mechanism and how to lodge complaints

12. REPORTING

At the end of every quarter, a status update of complaint filed with AIICO Capital shall be

forwarded to the SEC.

Such report shall be sent to the SEC not later than the 20th day of a new quarter.

13. PERIODIC REVIEW OF THE FRAMEWORK

This Framework shall be subject to review annually or as recommended by the regulatory

authority (SEC). The compliance and internal control unit shall be responsible for the periodic

review.

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14. APPROVAL

This Policy is approved by:

_________________________

Head, Investment Operations

_________________________

Head, Client Services

_________________________

Head, Internal Audit

_________________________

Managing Director/CEO