1. Introduction

This document sets out Midland Credit Limited’s policy for handling comments, compliments and complaints made about our services.

Listening to what our users have to say, is essential to improving the quality of our services. We want to know when we do things well and what aspects of our service our users appreciate, but we also want to know when things go wrong or when users feel that our service can be improved. This gives us a chance to make things better and enhance the user experience of Midland Credit Limited

We value our customer’s comments and complaints so that we can:

• Keep doing things that please our customers and give credit to our staff
• Know if things have gone wrong and put them right
• Learn the lessons, and improve our services

2. Who this policy applies to

The policy applies to all those we serve or have dealings with, however regularly, including members of the public, commercial organisations and other bodies.

The term user is employed in its widest sense within this policy to encompass people or organisations who use any of our services, whether visiting, writing, emailing, faxing, telephoning or accessing Midland Credits’ online services.

3. What is a complaint

We define a complaint as an expression of dissatisfaction with our service, no matter how expressed and whether justified or not, that requires a response or further action on the part of Midland Credit Limited.

4. Our principles

We aim to follow the principles of good practise set out in the FCA Handbook, Dispute Resolution: Complaints (DISP)

We try to make our processes:

• Easy to access and understand
• Clear and simple to use
• Responsive to the reasonable needs of complainants
• Prompt, with established time limits for action (see 6 below), and keeping people informed of progress, especially when investigations take longer than expected
• Fair, with an opportunity for a full and impartial investigation
• Proportionate to the matters complained about
• Informative, by using lessons learnt from complaints to improve services and by reviewing the results of such changes.

Our pledge to our customers

When we respond to complaints, Midland Credit can be expected to:

• Take any concerns seriously
• Give the name of the member of staff responsible for dealing with the complaint at each stage of the procedure
• Be factually correct
• Deal with the complaint promptly
• Avoid jargon
• Answer all points of concern
• Be flexible in the way that we communicate
• Give the reasons for the decision reached on a complaint
• Explain the next steps available if the customer is still dissatisfied and provide contact details (address, telephone and email).
• Ensure that users who make a complaint, are not subjected to discrimination or retaliation as a result of complaining

Our complaints process will be:

• Frank and open
• Impartial, avoiding any bias in favour of any party
• Thorough, finding out the relevant facts, taking views from people involved on both sides of the complaint and verifying explanations where possible.
• Equitable, treating people in similar circumstances in similar ways.

5. How to comment or complain

We welcome views on our service and will respond to comments and complaints, however, presented, whether in person, in writing, by telephone, email, fax or other channels.

Complaints, comments or compliments should be sent:

By Post:

Midland Credit Limited
Millhouse Business Centre
Station Road
Castle Donington
Derbyshire
DE74 2NJ

By Email: complaints@midlandcredit.co.uk

By Telephone: 03339 00 00 00

6. How Midland Credit Ltd responds to complaints

Process

We aim to resolve complaints as soon as we are aware of them and by the end of the day if this is possible.  This means that the member of staff who first deals with a complaint is responsible for either:

• Resolving the problem personally, if it is within their area of responsibility, ensuring that complaints handling staff are kept fully informed for monitoring and recording purposes.

Or

• Where this is not possible, for passing the complaint to our complaints handling staff to take forward.

(Initial responsibility for investigating and responding to complaints will usually lie with the part of the organisation which is the subject of the complaint, but our complaints handling team monitors complaints handling across Midland Credit to ensure that they are handled consistently and maintains a central record of complaints. This team is responsible for providing data and information about complaints to the Board of Directors and statutory reporting to the Financial Conduct Authority.

Procedures

The member of staff receiving the complaint will provide acknowledgement of receipt of the complaint within three working days (the day the complaint is received being Day 0). They will usually respond in writing, sometimes to confirm the information given in a telephone call but also to provide confirmation of who is dealing with the complaint. This will usually either be the complaints handling team or the department about which the complaint is made. The complaints handling team will ask the relevant department(s) to assist them to look into matters and responding fully to any concerns. Midland Credit Limited will:

• investigate the complaint competently, diligently and impartially, obtaining additional information as necessary;
• assess fairly, consistently and promptly:
  • the subject matter of the complaint;
  • whether the complaint should be upheld;
  • what remedial action or redress (or both) may be appropriate;
  • if appropriate, whether it has reasonable grounds to be satisfied that another respondent may be solely or jointly responsible for the matter alleged in the complaint;
• taking into account all relevant factors;
  • offer redress or remedial action when it decides this is appropriate;
  • explain to the complainant promptly and, in a way that is fair, clear and not misleading, its assessment of the complaint, its decision on it, and any offer of remedial action or redress; and
  • comply promptly with any offer of remedial action or redress accepted by the complainant.

Prompt written acknowledgement of a complaint will be sent to the customer assuring that the complaint has been received and that it is being dealt with.  Midland Credit will aim to investigate and resolve any complaint within 4 weeks of receipt and in any case within 8 weeks of receipt of the complaint.  The response will include a copy of the Financial Ombudsman Service’s standard explanatory leaflet and set out how to refer the complaint to the Financial Ombudsman Service (FOS) if they are still dissatisfied.

If Midland Credit is unable to resolve the complaint within 8 weeks, it will write to the customer advising why this cannot be met and when the customer can expect to receive a response.

Redress

When our services do not meet our published standards, we aim to make amends in a way that is appropriate to the problems experienced. Redress will always include:

• An apology
• An explanation of what happened and why

and where appropriate:

• We will take action to put things right
• We will give an assurance that the same thing will not happen again and take steps to ensure this

Treating Midland Credit Limited’s staff fairly

When a compliment is received about our service or our staff, we will pass on any comments to the staff and managers concerned.

We will also pass on unfavourable comments so that our staff can learn from them and try to provide a better service.

Midland Credit Limited has a responsibility to ensure that members of staff are treated fairly if a complaint is made against them. They are entitled to:

• Be informed immediately and fully of any complaint made about them and ask for their comments
• Be kept informed of progress in the investigation of the complaint
• Be told the outcome of the complaint investigation and the reasons for it

If a member of staff makes a complaint about a user of our services, or a counter-complaint in response to a complaint, the matter will be looked into by our complaints handling staff or a manager from a different department. In the case of a counter-complaint, a separate investigating officer will be assigned to look into it, to ensure fairness.

Feedback

We welcome any comments on the fairness and efficiency of the complaints procedures and the effectiveness of Midland Credit’s replies to complaints. We will ask people who have made a complaint about whether they are satisfied with the way their complaint was handled and the outcome. Sometimes we will use surveys to do this. We will take account of all feedback in annual reviews of our procedures.

Dissatisfaction with the response

If there is dissatisfaction with our final response, the complaint may be referred to the Financial Ombudsman Service.  This needs to be within six months from the date of the final response letter.

The contact details for the Financial Ombudsman Service are:

By Post:

The Financial Ombudsman Service
Exchange Tower
London

E14 9SR

By Email: complaint.info@financial-ombudsman.org.uk

By Telephone: 0800 023 4567 / 0300 123 9123

Website: www.financial-ombudsman.org.uk

7. Confidentiality

 We respect the need for confidentiality when a complaint is made, both for the complainant and for members of staff who have a complaint made against them. We aim to investigate complaints with sensitivity, preserve confidentiality, and share information only when it is a necessary part of the investigation.

Some information about complaints will be published (see 10 below) but this will not include any personal details of a confidential or sensitive nature. If a complaint is referred to the Financial Ombudsman Service, the FOS may need to have access to confidential information as part of their investigation. However, strict rules of confidentiality are observed by the FOS.

8. Staff training

Receiving and responding to comments and complaints about our service is an integral part of providing the service.

We will train our staff in our complaints procedures and ensure they understand the value of comments and complaints so that they can carry out their roles and responsibilities with confidence.

9. Policy for dealing with unreasonable enquiries

 Our staff will treat people in a courteous, fair and proportionate manner and we expect similar courtesy and reasonable behaviour in return. Very occasionally, we will refuse to respond to a complaint.

This will only happen if the person making the complaint is insulting or abusive towards our staff or if they refuse to accept that their complaint has been dealt with despite a thorough investigation on our part.

We will only do this where it is necessary, and we will write to the person concerned to explain why we believe this to be the case.

10. Recording and publishing statistical information

In accordance with FCA requirements, we will regularly publish anonymised information about the complaints we have received, which will include:

• Numbers and types of complaints
• Speed of response against targets
• Levels of satisfaction with the response
• Action to improve services, taken as a result of complaints.