Customer Compliant Policy

Content

Policy Statement

Applicability

Definitions

Compliant Management

Roles and Responsibility

Disciplinary Action

Policy Statement

1.1 Overview
Anchoria Investment and Securities Limited (starting now referred to as “Anchoria”) are committed to conducting business professionally, with integrity and following all existing rules and regulations under which its business operates. Anchoria values its numerous Customers and ensures that they are always treated fairly and satisfactorily.
This document sets out the principles and procedures for handling customer complaints and ensures that they are promptly and effectively resolved. This Policy aligns with the Securities and Exchange Commission (SEC) and Anchoria minimum requirements for treating Customers fairly.
1.2 Scope
The Policy:
▪ Recognises the right of the Customers to complain whenever they are dissatisfied with the service(s) of Anchoria.
▪ Applies to all complaints, regardless of who reports them. Any person may make a complaint to whom Anchoria delivers services or who is affected by the services of Anchoria, an organisation with which Anchoria works, or a member of the public.
▪ Provides a complaint procedure that is clear and easy to use for anyone wishing to make a complaint.
▪ Acts as a guide for all Anchoria staff for resolving any complaint received.
▪ Ensures commitment to resolving complaints in a responsive, effective, fair, timely and economical way to learn from all feedback provided, whether positive or negative.

Applicability

This Policy shall apply to all employees of Anchoria.

Definitions

Complaints – For this Policy, Anchoria regards a complaint as any expression of dissatisfaction or grievance from a counterparty regarding the quality of product or service offered by Anchoria; or regarding any unsatisfactory conduct of an employee or any individual acting on behalf of Anchoria; in which the customers alleged that they have suffered or are likely to suffer, financial loss, whether such grievance or dissatisfaction is valid or not.
Complaints may include allegations that Anchoria has:
I. Mistreated a customer.
II. Breached any instruction given by a customer or any agreement or mandate entered with a customer.
III. Violated any regulatory law under which Anchoria operates.
IV. Has acted dishonestly, negligently, or unprofessionally.
V. Have caused a customer to suffer some loss because of Anchoria’s misconduct.
Complaints Management System – This is a set of procedures used by Anchoria to address complaints and resolve disputes.
Customer – Any person (Individual or corporate) to whom Anchoria provides financial products and services. These include present or prospective customers, as well as their agents.
Employee(s) – Employees of Anchoria include the following, regardless of specific job responsibilities, department:
 Full-time employees, and
 Non-full-time employees.
Competent Authority – This refers to a body or organisation that regulates the
activities of Anchoria. This may include:
 SEC: Securities and Exchange Commission
 NGX: The Nigerian Exchange

Complaints Management

4.1. Definition of a complaint
Anchoria regards a complaint as any expression of dissatisfaction or grievance from a counterparty regarding the quality of product or service offered by Anchoria; or regarding any unsatisfactory conduct of an employee or any individual acting on behalf of Anchoria; in which the Customers alleged that they have suffered or are likely to suffer financial loss, whether such grievance or dissatisfaction is valid or not.
More specifically, complaints may include allegations that Anchoria has:
 Contravened or failed to comply with any instruction given by a customer or any agreement or mandate entered with a customer.
 Acted dishonestly, fraudulently, negligently, recklessly, or unprofessionally.
 Treated a customer unreasonably or unfairly, or
 Not delivered services of a reasonable standard.
4.2. Channels for complaints
All complaints can be reported via any of the following channels:
I. Verbally: Complaints can be reported verbally through the Customer Contact Centres or any member of staff or individual acting on behalf of Anchoria or through the Anchoria office.
II. Via Email: Complaints can be reported via email through the customer support emails of Anchoria or any member of staff acting on behalf of Anchoria.
III. Letters: Complaints may also be addressed as letters to Anchoria via post to the customer complaints desk.
IV. Social Media: Complaints can be reported through any Anchoria social media platforms, e.g., Twitter, Facebook, web chat etc.
4.3. Categories of complaints
Anchoria categorises complaints into the following:
I. Low risk: Complaints that can quickly be resolved at Anchoria’s location or via any channel through which it is received at the time such complaint is received or shortly after that. This has minimal financial or legal implications and can be handled by any staff without specialised expertise.
II. Medium risk: Complaints that cannot be resolved on the spot but require support staff’s assistance at the Anchoria location or back-office units. This also has minimal financial and legal implications.
III. High risk: these are complaints that have financial or legal implications and require the expertise of the centralised complaints management desk for resolution. Examples of such risks include account fraud, letters of complaints from legal firms etc.
General complaint handling principles
 All complaints received must be handled; no complaint shall be ignored, suppressed, or rejected by any staff or unit.
 Customers will not be charged any fee for making a complaint.
 A complaints management portal or database must be maintained and updated immediately any employee of Anchoria receives complaints.
 Adequate and accessible complaints channels should be in place to accommodate customer feedback.
 A complaint will be regarded as resolved and closed upon receipt of confirmation from the client of his satisfaction with the resolution of the complaint. However, where no feedback is received from the Customer within 30 days from the date of communication to the Customer of the resolution of a complaint, such complaint may also be deemed to be closed.
 A centralised complaints desk should be maintained for managing, reporting, and analysing all complaints received.
 All employees of Anchoria must be equipped to receive and resolve complaints from Customers.
 Adequate controls must be in place to ensure adherence to resolution timelines and minimum standards for handling complaints.
 Complaints must be dealt with on an individual basis and without bias taking into consideration all facts received from Customers and the responses provided by employees involved in the incident giving rise to the complaint.
 Follow-up procedures should be in place to determine and analyse the root cause of any complaint to accurately assess the corrective action required.
 All communication regarding the complaints process must be transparent, easily understandable, and readily available to Customers through appropriate materials and alternatively on the website.
 Resolution timelines must be well defined.
4.4. Acknowledgement of complaints
 All complaints received via email shall be acknowledged via the same channel within two (2) working days. All acknowledgements of complaints by post shall be deemed sent on the date the response letters are registered with the post office or registered courier.
 All complaints received via social media shall be acknowledged via the same channel within 24 hours.
 All complaints received in writing shall be acknowledged in writing within five (5) working days.
4.5. Compliant’s handling/resolution procedures
The complaints management procedure seeks to resolve complaints and lead to customer satisfaction.
Consequently, it must ensure the following:
 Low and Medium Risk complaints should be reviewed and resolved immediately or as soon as possible after it is received. At the same time, the Customer is notified of the resolution, and the complaint is logged on the complaint’s portal/ database for tracking.
 The centralised complaints management team should resolve high-Risk complaints within the stipulated SLA (Service Level Agreement). Customers should be notified of the resolution through the same medium of complaint, and the same is logged on the complaint’s portal/ database for tracking. All solutions must be communicated to the Customer within 24 hours to confirm satisfaction. Where the Customer is not satisfied with the resolution, the dissatisfaction process must be initiated, and a complaint case re-opened to ensure the Customer is happy.
 Root Cause Analysis (RCA) must be carried out on all complaints received and where appropriate corrective measures are set up to forestall similar complaints’ recurrence, thereby improving the process, products, and services.
 All complaints must be resolved no later than ten (10) business days from the date of receiving the complaint where the complaint relates to a SEC matter, or such timeline as stipulated by the relevant Competent Authority that oversees the issue that the complaint relates to. Where this is not achievable, a holding response should be sent to the Customer via email within two (2) business days and within five (5) business days if received by post.
 Where the complaint relates to a regulatory matter, if after ten (10) business days of receipt of the complaint (“resolution period”) the complaint has not been resolved to the satisfaction of the Complainant, the Complainant shall refer the complaint to the Competent Authority within two (2) business days in a letter accompanied by a summary of proceedings of events leading to the referral and copies of relevant supporting documents.
 Where complaints are not resolved in favour of the Complainant, the Complainant must be advised of the option to approach the Competent Authority. Documentation and timelines required to lodge complaints with the Competent Authority must be explained to customers.
4.6. Registering of complaints
All complaints received from customers must be logged on the electronic complaints portal/database/CRM within one working day. The complaints database must contain all essential details relating to the Customer and the complaint, such as:
 Name of Complainant
 Date of complaint
 Contact details of Complainant
 Nature of complaint
 Summary of complaints with necessary details
 Supporting documents
 Remarks/comments
The complaints database shall be updated regularly to enable reporting to relevant regulatory bodies within the specified regulatory timeline.
4.7. Communications
 Complaints management process must be made known to customers during the onboarding process. 
 The complaints management policy may be available on the Anchoria website.
4.8. Reporting
 Anchoria shall provide information on complaints received to the SEC quarterly and other Competent Authorities in line with their specified timelines. This data shall cover the number and nature of complaints received and differentiated according to their various criteria.
 Anchoria will comply with requests for information from regulatory bodies or Competent Authorities that have the jurisdiction to hear any customer complaint.
4.9. Retention of complaints records
 All records and supporting documents must be maintained for a minimum period of not less than six (6) years from the date of lodging the complaint, whether the complaint has been resolved.
 Information regarding complaints should be recorded in a format accessible to Customers, SEC, and adjudicators on request.

Roles and Responsibilities

For this Policy, the following shall be held responsible for:
5.1. Executive Committee (EXCO)
 Adopt and approve the Policy
 Ensure full implementation of this Policy
 Ensure the proper and adequate process is in place to operationalise this Policy.
 Supports this Policy and any policy changes that may be presented for consideration.
5.2. Customer Experience Team
 Ensure strict compliance with the Policy
 Manage the complaints management framework.
 Provide resolution to customers on complaints received.
 Give customers regular feedback on their complaints and ascertain customer satisfaction.
 Recommend changes to this Policy to EXCO for approval.
 Provide relevant input, guidance, and awareness training on this Policy to aid implementation.
5.3. Compliance
 Advise employees, line managers and Business Unit Heads, where necessary.
 Monitor compliance with this policy and report instances of non-compliance to EXCO.
 Provide to regulators adequate information regarding any complaints as may be requested.
5.4. Business Unit Heads/Line Managers
 Ensure employees are aware of their obligations under the Policy.
 Responsible for implementing this Policy.
 Ensure documented processes are in place to operationalise the Policy.
 Attend to breaches in respect of this Policy and report same to compliance.
 Create necessary awareness in respect of this Policy to all members of staff that work in their team.
5.5. Employees
 Employees must familiarise themselves with this Policy and comply with the requirements.
 Act independently, objectively, and professionally towards clients.
 Facilitate any regulatory, internal/external audit or internal investigation regarding this Policy.
5.6. Internal Control/ Audit
 Assure that there is adherence to the Policy.

Disciplinary Action

Employees who do not comply with this Policy will face disciplinary action.