1. GENERAL

1.1 Purpose

a. PAYMENTSAVE LTD (the “Company”, “Us”, “We” or “Our”), company registration number 09872986, is committed to promoting customer satisfaction by encouraging feedback, including complaints. We recognise that, on occasion, things may not go as expected and aim to resolve any issues raised by you (the “Complainant”, “You”, “Customer” or “Client”) as quickly as possible, in a fair, transparent and straightforward manner.

b. This Complaint Handling Procedure (the “Policy”) sets out how PAYMENTSAVE LTD deals with complaints in an efficient, fair and transparent manner. It provides a systematic approach to receiving, investigating, assessing and resolving complaints, as well as identifying issues and implementing improvements to help prevent them from recurring.

c. This Policy provides all the information you need about making a complaint, including how to contact us, how your complaint will be handled and what you can expect from us throughout the complaint-handling process.

1.2 Objectives

This Policy provides a clear framework for handling complaints through effective and efficient procedures. PAYMENTSAVE LTD will analyse and assess customer complaints while taking into consideration the needs, circumstances and concerns of the complainant.

We aim to ensure that complaints are handled consistently, fairly and efficiently, and that lessons learned from complaints are used to improve the quality and consistency of our services.

1.3 Principles of Effective Complaint Handling

1.3.1 Visibility and Transparency

This Complaint Handling Procedure is made available to customers through the PAYMENTSAVE LTD website at www.gentility.co.uk.

1.3.2 Making a Complaint

a. We aim to resolve most issues at the initial point of contact wherever reasonably possible, including through our Customer Services team, sales representatives or authorised sub-brokers.

b. If you are unhappy with the service provided by an employee, supplier, sales representative or sub-broker acting on behalf of PAYMENTSAVE LTD, you should let us know so that we can investigate the matter and work towards an appropriate resolution.

c. Complaints may be directed to PAYMENTSAVE LTD for the attention of a Director or the designated Complaints Handling Officer.

d. You can make a complaint using any of the following methods:
i. Email: info@gentility.co.uk
ii. Telephone: +44 7405 597709, Monday to Friday, 10:00am–6:00pm, excluding UK bank holidays
iii. Post: Unit 4 Stanton Gate, 49 Mawney Road, Essex, England, RM7 7HL

1.3.3 No Charges

There is no charge for submitting a complaint or for the internal handling and investigation of a complaint.

1.3.4 No Detriment

Customers who make a complaint will not be adversely affected or disadvantaged as a result of raising a genuine complaint.

1.3.5 Objectivity and Fairness

Complaints will be handled fairly, objectively and without unreasonable bias. Where reasonably possible, complaints will be reviewed independently of the business unit, employee or activity that is the subject of the complaint.

1.3.6 Confidentiality and Disclosure

Complaints will be treated confidentially and handled in accordance with applicable UK data protection legislation. Information will only be disclosed where necessary for the investigation and resolution of the complaint, where required by law or where otherwise permitted.

1.3.7 Responsiveness

a. Complaints will be handled promptly and efficiently. We will endeavour to resolve complaints within one month of receiving all information reasonably required to investigate the matter.

b. Where a complaint is likely to take longer to resolve, we will explain the reason for the delay and, where reasonably possible, provide an expected timeframe for completion.

1.3.8 Review

This Policy will be reviewed periodically and updated where necessary to ensure that it remains effective and consistent with applicable legal, regulatory and industry requirements.

1.4 How Long Before Your Complaint Is Resolved?

a. Where a complaint is made verbally, we may record the details of the complaint and, where appropriate, ask you to confirm the complaint in writing.

b. Where a complaint is received by email or post, we aim to acknowledge or contact you regarding the complaint within 3–4 working days.

c. We will keep you appropriately informed of the progress of your complaint and, where reasonably possible, provide an update where there is a material development or further information is required.

d. We aim to resolve complaints within two to four weeks, depending on the complexity of the matter and the information required to complete the investigation.

e. If you remain dissatisfied with our final response, or it has been 8 weeks since your first complaint and you remain dissatisfied, you may be entitled to refer your complaint to the Dispute Resolution Ombudsman (DRO), who will investigate your complaint independently.

f. PAYMENTSAVE LTD is bound to follow any decision made by the Dispute Resolution Ombudsman in accordance with the applicable scheme rules.

g. To find out more about the Dispute Resolution Ombudsman and how you may be able to use its dispute resolution service, please visit www.disputeresolutionombudsman.org or telephone 0333 241 3209.

h. Where a complaint is upheld, PAYMENTSAVE LTD will consider appropriate corrective or remedial action, including compensation where appropriate, for any acts or omissions for which the Company is responsible.

i. If a complaint relates primarily to an energy supplier rather than PAYMENTSAVE LTD, we will, where appropriate, direct you to the relevant supplier’s complaints procedure and assist you in identifying the appropriate party to contact.

2. DEFINITIONS AND RESPONSIBILITIES

2.1 Definitions

2.1.1 Complaint

A complaint is an expression of dissatisfaction concerning a specified business matter, product, service, employee, supplier, sales representative or sub-broker, where the complainant expects the matter to be addressed or resolved. Complaints may be made verbally or in writing, although written complaints are preferred where reasonably possible.

2.1.2 Complainant

A complainant is a client, customer, partner or other relevant party raising a complaint concerning PAYMENTSAVE LTD, its services, employees, suppliers, sales representatives or sub-brokers.

2.2 Responsibilities

The Risk and Compliance Manager (RCM) acts as the designated Complaints Handling Officer and is responsible for overseeing the Company’s complaints process.

The Complaints Handling Officer is responsible for managing and handling complaints, ensuring that complaints are appropriately recorded, investigated and resolved, monitoring the effectiveness of this Policy, identifying recurring issues and trends, and implementing appropriate improvements where required.

All employees and representatives of PAYMENTSAVE LTD must refer complaints to the Complaints Handling Officer as soon as reasonably practicable and provide the relevant details in writing where appropriate.

3. PROCESSES

3.1 Complaint Handling Procedure

3.1.1 Receipt and Acknowledgement

Upon receiving a complaint, PAYMENTSAVE LTD will confirm receipt by email or another appropriate method. We aim to acknowledge complaints within two working days, unless exceptional circumstances apply.

Complaints will be centrally managed and recorded by the Complaints Handling Officer.

3.1.2 Investigation

a. Complaints will be investigated fairly and, where reasonably possible, independently of the business unit, employee or activity concerned.

b. Information and evidence provided by the complainant will be taken into consideration as part of the investigation.

c. Where applicable, we may require the following information to investigate a complaint:
i. Name and contact details;
ii. Confirmation of authority where the complaint is being made on behalf of another person or business;
iii. Details of the complaint and the reason for dissatisfaction;
iv. Relevant dates, account details or transaction information; and
v. Any supporting documentation or evidence.

d. We may request further information or documentation where this is reasonably required to investigate and resolve the complaint.

e. Complaints will be assessed fairly and consistently, taking into consideration the circumstances of the complaint, available evidence, any remedial action required, the responsibility of other parties where applicable, and any improvements that may be required to our processes or services.

3.1.3 Third-Party Involvement

Where another party is wholly or partly responsible for the matter raised, we may refer the relevant part of the complaint to that party where appropriate.

Where reasonably necessary, we will inform the complainant of this and keep them appropriately updated throughout the process.

Where a complaint relates to an energy supplier, PAYMENTSAVE LTD will, where required and as soon as reasonably practicable, notify or direct the customer to the relevant supplier and explain the appropriate complaints route.

3.1.4 Closing a Complaint

a. We will endeavour to resolve complaints within one month of receiving all information reasonably required to complete the investigation.

b. Where the complaint cannot be resolved within this timeframe, we will explain the reason for the delay and, where reasonably possible, provide an expected timeframe for resolution.

c. We will provide a written response setting out the outcome of the investigation and, where appropriate, any remedial or corrective action being taken.

d. Where applicable, our final response will explain the reasons for the outcome and provide information about the Dispute Resolution Ombudsman and any applicable escalation route.

e. A complaint will be formally closed once the investigation has been completed and any agreed or appropriate actions have been taken.

3.1.5 Dispute Resolution Ombudsman (DRO)

If you remain dissatisfied with our final response, or it has been 8 weeks since your first complaint and you remain dissatisfied, you may be entitled to refer your complaint to the Dispute Resolution Ombudsman (DRO), subject to the applicable eligibility requirements and scheme rules.

The Dispute Resolution Ombudsman will investigate eligible complaints independently.

PAYMENTSAVE LTD is bound to follow any decision made by the Dispute Resolution Ombudsman in accordance with the applicable scheme rules.

To find out more about the Dispute Resolution Ombudsman and how you may be able to use its dispute resolution service,
please visit www.disputeresolutionombudsman.org or telephone 0333 241 3209

3.2 Documentation and Records

PAYMENTSAVE LTD will maintain appropriate records of complaints, including, where applicable:

a. Date the complaint was received;
b. Complainant’s name and contact details;
c. Details and nature of the complaint;
d. Current status of the complaint;
e. Investigation and assessment undertaken;
f. Correspondence and supporting evidence;
g. Corrective or remedial measures taken;
h. Final outcome and closure date; and
i. Any improvements or actions identified as a result of the complaint.

Complaint records will normally be retained for seven years, or for a longer period where required by applicable law, regulation or contractual obligations.