Complaints Handling Policy Template (AFSL | Wholesale Clients)

A complaints handling policy for Australian financial services licensees, drafted on the basis that the licensee provides financial services to wholesale clients and is therefore not required to maintain a formal dispute resolution system under section 912A(1)(g). It documents how complaints are received, acknowledged, investigated, resolved and recorded, and assigns each stage to a named policy owner with board oversight.

Use this policy if you:

• Hold an AFSL and provide financial services to wholesale clients
• Need a documented complaints process that your board has formally approved
• Want complaints captured in one register rather than across inboxes and file notes
• Review complaints at a regular compliance meeting and need a standing framework for it
• Are preparing for an audit or licence review and need your complaints handling evidenced

It is suited to:

• Australian financial services licensees with a wholesale client base
• Licensees whose complaints handling sits with a compliance officer
• Businesses that report complaint data to a board or compliance committee
• Licensees that outsource part of their dispute resolution process and remain responsible for it

What this policy covers:

• Who the policy binds, including directors, employees, contractors, consultants and committee members
• The definition of a complaint and the non-technical approach to identifying one
• The wholesale client position under sections 912A(1)(g) and 912A(2) of the Corporations Act 2001 (Cth)
• A two-step process: acknowledgement and early resolution within five business days, then the IDR Response
• When a written IDR Response is required and the limited circumstances in which it is not
• The three IDR Response outcomes: rejection with reasons, redress without acceptance and acceptance with a remedy
• Remedies including fee refunds, referral, financial assistance and compensation, and who may approve them
• Complaints Register requirements, quarterly compliance meeting review and systemic issue escalation

You receive an editable Word document with placeholders for your entity name, ABN, ACN, AFSL number and the date the policy is approved, plus a version control and approval history table, a key obligations table, a definitions table and two schedules — a Complaints Register and a complaints process flowchart. The regulatory position assumes a wholesale client base, so review it against your own licence authorisations and client mix and obtain advice tailored to your circumstances before adopting it.