Guernsey Community Savings LBG (“GCS”) has introduced certain Policies and Procedures covering all aspects of the company’s business activities, and such Policies and Procedures are contained in the company’s Operational Procedures Manual.

This Complaints Procedure forms part of the Operational Procedures Manual.

It is an expectation under normal business practices for the nature of services provided by GCS and its customers (generally a retail-type service), that a formal Complaints Procedure will be in place, and details made available to customers if and when required.  Rather than adopting arbitrary complaints standards, GCS has chosen to follow the directions of the Guernsey regulator (Guernsey Financial Services Commission (“GFSC”)) under various codes of practice  relevant to financial services providers generally.  Such codes require that every party licensed by the GFSC shall have in operation an effective and robust complaints handling procedure for consideration, together with a central recording system and specific reporting requirements.  Whilst these codes are not directly applicable to GCS, they are felt to be comprehensive and relevant to the type of services being provided to GCS customers.

Complaints

A complaint is defined as any oral or written expression of dissatisfaction, regardless of whether it is justified or not, from, or on behalf of a person about the provision of, or failure to provide a service where the complainant feels or alleges that he has suffered or may have suffered financial loss, material distress or material inconvenience.

Staff should follow the below procedures to ensure that their handling of complaints is appropriate.

1. Any complaint of any nature whether verbal or written shall immediately be referred to the GCS Chairman. In the absence of the Chairman, reference will be made to one of the GCS Directors for review and processing in the meantime.  If the Chairman or any Director are implicated in the complaint, they will be excluded from the review process apart from any involvement or input as may be required from them during the review process.

2. The Chairman shall maintain a record of all complaints received and on receiving notification of a new complaint will enter appropriate details in the record.

3. The circumstances of the complaint will be fully investigated as a matter of priority and within three business days of the receipt of the complaint either a full written reply will be dispatched or the complainant will be advised in writing that the situation is being reviewed and that a full reply will be provided within a further ten business days.

4. Copies of all written communications sent to a complainant in relation to the complaint shall also be provided to the Chairman who will note his record accordingly.  A file will be opened for each client in relation to any complaints.

5. The Chairman shall also be notified of complaints which have been settled and the terms on which settlement has been achieved.  For this purpose a complaint is deemed to be settled when a full reply has been sent to the complainant and no response has been received after a period of four weeks has elapsed from the date on which the reply was dispatched, or if the complainant has confirmed that they are satisfied with the settlement and consider the complaint to be addressed and closed.

6. The record of complaints will be maintained by the Chairman for a period of five years prior to archiving or destruction.

Significant Complaints

1. A significant complaint is defined as a complaint which alleges a breach of  any applicable Law, or one that alleges bad faith, malpractice or impropriety or repetition of a matter previously the subject of a complaint (whether significant or not).  A complaint is not considered significant if it relates to a minor mechanical or clerical error.

2. On receipt of such a complaint the GCS Chairman (or other Director if applicable) will determine the course of action required, and will communicate with the complainant accordingly, including referral to CIFO (see below) if deemed appropriate or where satisfactory resolution cannot be achieved.

Channel Islands Financial Ombudsman (“CIFO”)

As a service targeted to retail customers resident in the Bailiwick of Guernsey, customers will have recourse to the services of CIFO if it is felt that any complaint has not been handled properly or dealt with to a satisfactory conclusion.

On opening an account with GCS, customers will be provided with details of this Complaints Procedure, the contact details for the lodging of formal complaints, and the contact details for CIFO.

If a complaint is filed with CIFO at any time, GCS will cooperate in any investigation in a completely open and honest manner, and provide any records that CIFO may require to support the investigation.

The Board will consider any such complaints, the background to the complaint, and any findings by CIFO, and determine whether any further internal action is required, and whether any additional staff training or new procedures may be required.

Publication of Complaints Procedure

Details of this procedure, the contact details and also links to CIFO will be published on the GCS website in addition to being included in a customer account handout.