Complaints Handling Policy

Complaints Handling Policy

This Policy provides a transparent overview of how YWO (PTY) Ltd handles and resolves client complaints, in compliance with the Financial Advisory and Intermediary Services Act, 2002 (FAIS) and Conduct Standard 1 of 2022 (FAIS General Code of Conduct). At YWO (PTY) Ltd (hereinafter, the “Company”), we are committed to providing high-quality services to our clients. We strive for excellence in all our interactions, but we recognize that, at times, clients may have concerns or grievances regarding our services.

To ensure transparency, fairness, and efficiency, we have implemented this Client Complaints Procedure to provide a structured process for resolving complaints in a professional and timely manner. The Company treats every complaint as an opportunity to identify potential improvements in its services, processes, and communications.

This document outlines how you can submit a complaint, how we handle complaints, expected response times, and what steps you can take if you are not satisfied with our response. This Policy is intended for clients and public disclosure. Internal responsibilities and escalation steps are governed by the Company’s internal Complaints Management Procedure.

1. Purpose and Scope

The purpose of this Policy is to outline the complaint resolution procedures the Company maintains to ensure fair, efficient, and consistent handling of all client complaints. This Process applies to any of the Company’s Clients who have reasons to believe that the Company has treated them in any way unfairly and/or has failed to comply with any of the provisions of the Law. Clients should follow the procedure outlined herein in order to make a formal complaint to the Company.

2. Regulatory Framework

The Company acting in its capacity as a Financial Service Provider with License No. 54357 and in accordance with the Financial Advisory and Intermediary Services Act, 2002 (Act No. 37 of 2002) (the “Law”) is required to have in place and disclose to its Clients the Complaints Resolution Process, which is described in this document.

This Policy has been designed in accordance with the requirements of:

• The Financial Advisory and Intermediary Services Act, 2002 (FAIS Act);
• The General Code of Conduct for Authorised FSPs and Representatives, BN 80 of 2003 (as amended);
• FSCA Conduct Standard 1 of 2022 (Complaints Management and Resolution).”

YWO (PTY) Ltd is authorised as a Financial Services Provider (FSP No. 54357) by the Financial Sector Conduct Authority (FSCA).

Complaints Handling Policy

3. Definition of a Complaint

In simple terms, a complaint is any expression of dissatisfaction from a client regarding a financial service offered by the Company.

As per General Code of Conduct for Authorised Financial Services Providers and Representatives BN 80 of 8 August 2003 as amended, the term “complaint” means a specific complaint relating to a financial service rendered by a Financial Services Provider (the “Provider”) and/or its representative to the knowledge of the provider, to the provider's service supplier relating to a financial product or financial service provided or offered by that provider which indicates or alleges, regardless of whether such an expression of dissatisfaction is submitted together with or in relation to a client query, that:

a) the provider or its service supplier has contravened or failed to comply with an agreement, a law, rule, or a code of conduct which is binding on the provider or to which it subscribes; b) the provider or its service supplier's maladministration or willful or negligent action or failure to act, has caused the person harm, prejudice, distress or substantial inconvenience; or c) the provider or its service suppliers has treated the person unfairly;

3.1. Application of these definitions to YWO

While the statutory definitions above apply in full, the Company’s role as an intermediary determines which complaints fall within the Company’s mandate. Accordingly: a) If the complaint relates to the Company’s own conduct as an FSP, such complaint falls fully within the scope of this Policy. b) If the complaint relates to the product supplier’s trading platform, execution, spreads, deposits/withdrawals, trading disputes, account verification, or any other product-supplier activity, the complaint will be forwarded to the product supplier, and the complainant will be notified accordingly.

4. Complaints Categorization

As a licensed Financial Services Provider (FSP), we are committed to maintaining a transparent, fair, and effective complaints management process.

In accordance with regulatory requirements, all reportable complaints received will be categorised using the following minimum categories:

a) Information or Communication Provided by the Company Complaints relating to the accuracy, clarity, completeness, or fairness of information, Complaints Handling Policy marketing material, or disclosures provided by the Company.

b) Intermediary Services Rendered by the Company Complaints relating to the Company’s conduct as an FSP, including administrative errors, delays in responding to enquiries, or failure to meet regulatory obligations.

c) Client Service by the Company Complaints relating to the Company’s responsiveness, professionalism, or quality of service during interactions with prospective or existing clients.

d) Privacy and Data Handling Complaints relating to the handling of Personal Information, POPIA compliance, or concerns about data accuracy, security, or consent.

e) Complaints Handling Process Complaints about the way a previous complaint was handled or resolved, including dissatisfaction with the response, timelines, communication, or process.

f) Product Supplier–Related Complaints Complaints that relate to the product supplier’s responsibilities, including trading platform functionality, spreads, execution, deposits or withdrawals, account verification, trading disputes, or the performance or characteristics of the financial product. These complaints are acknowledged, recorded, and forwarded to the product supplier, and the complainant is informed accordingly.

g) Other Complaints that do not clearly fall into the above categories.

Each complaint is reviewed for underlying conduct risk and root cause analysis. The Company tracks and analyses recurring issues to improve client experience and prevent reoccurrence.

Additional Categories

The Company may apply additional internal sub-categories to support enhanced conduct risk management, where relevant to its intermediary-only business model.

5. Submitting your Complaint

If you wish to submit a complaint regarding any aspect of our services, you may contact our Complaints Handling Team via email at: support@ywo.com

To help us address your concern as quickly and efficiently as possible, please ensure your complaint is written in English language and includes the following information:

Complaints Handling Policy a) Your full name and contact details (email and phone number) b) Your account number or reference number (if applicable) c) A clear and detailed description of your complaint, including relevant dates and any previous communication with our team d) Any supporting documentation or evidence, such as:

• Screenshots of errors or discrepancies
• Copies of emails or chat transcripts
• Transaction records or account statements
• Any other relevant materials that support your claim

6. Acknowledging your Complaint

We will acknowledge receipt of your complaint within five (5) business days from the receipt of your complaint.

This acknowledgment will be sent to your registered email and will include:

a) Confirmation that we have received your complaint b) A unique Complaint Reference Number for tracking purposes c) The name and contact details of the officer handling your case d) An estimated timeframe for resolution

You may use the Complaint Reference Number in all future correspondence regarding your complaint to ensure seamless communication. If we require more information to assess your complaint, we will contact you within the same five (5) business-day window.

7. Investigation and Handling of Your Complaint

Once we acknowledge your complaint, our specialized Complaints Handling Team will begin a thorough review and investigation of the issue.

Investigation Process

a) Initial Review

• We will assess the details of your complaint and ensure we have all the necessary information.
• If further details are required, we may contact you for clarification.

b) Internal Investigation

• Our team will review your case based on available data, records, and interactions with our services.
• We may consult other departments, such as Compliance, Risk Management, or Customer Support, to gather relevant information.

Complaints Handling Policy c) Resolution Attempt

• Once the investigation is complete, we will determine whether your complaint is valid and, if so, identify the appropriate resolution.
• If corrective action is necessary, we will outline the steps we will take to address the issue.

We handle all complaints objectively and in accordance with the principles of Treating Customers Fairly (TCF). The staff member who originally handled your transaction will not be responsible for investigating your complaint.

d) Timeframe for Resolution and Final Outcome

We will make every effort to resolve your complaint and provide a final response within twenty (20) business days from the date of receipt.

If we are unable to resolve the matter within this twenty (20) business days period, we will provide you with a written update on the status of your complaint, including the reasons for the delay and an updated estimated timeframe for resolution.

Once our investigation is complete, we will issue a Final Response Letter that includes:

• A summary of your complaint and the key issues investigated
• Our findings and the rationale behind our decision
• Any corrective actions we will take, if applicable
• Information about your right to refer the complaint to the FAIS Ombud if you are not satisfied with the outcome

Possible Outcomes of Your Complaint:

• Upheld – Your complaint is found valid. We may issue a refund, offer compensation, make adjustments to your records, or implement internal process improvements without undue delay and within agreed timeframes.
• Partially Upheld – If part of your complaint is valid, we may offer a partial resolution of compromise. We will provide a clear explanation of our decision.
• Rejected – Your complaint is not upheld. We will provide a clear explanation for our decision. You still retain the right to escalate the matter to the FAIS Ombud.

All resolutions will be implemented promptly. Any agreed compensation or corrective action will be completed without unnecessary delay and confirmed to the complainant in writing.

e) Your Right to Escalate the Outcome Complaints Handling Policy If you are not satisfied with our final response, or if your complaint remains unresolved by us after six (6) weeks, from the date on which you submitted it, you have the right to refer it to the Office of the FAIS Ombud free of charge.

The Ombud acts independently and objectively and has jurisdiction in respect of complaints relating to advice or intermediary services which have arisen after 15 November 2002.

If you wish to refer the matter to the Ombud, you must do so within six (6) months of receiving our written notice informing you that we are unable to resolve your complaint to your satisfaction.

FAIS Ombud Contact Details: Ombud for Financial Services Providers Contact Details

Physical address: Sussex Office Park, Ground Floor, Block B, 473 Lynnwood Road & Sussex Ave. Lynnwood, 0081, South Africa

Toll Free No: 0860324766

Telephone: +27 1 470 9080

Facsimile: + 27 12 348 3447

E-mail address: info@faisombud.co.za

Website: http://www.faisombud.co.za/

7. Record Keeping

The Company shall establish, maintain and/or update the Complaints Register with details of all the complaints received per month; date of the complaint, identification of the complainant, complaint cause, the financial instrument, the disputed amount and settlement date if applicable and any comments thereof for a period of five (5) years. The Complaints Register is reviewed periodically by the Compliance Department to ensure all complaints are resolved within the required timelines and that systemic issues are identified.