SCHINDLERSX COMPLAINTS POLICY

Schindlers Digital Assets (Pty) Ltd ("SDA") is the owner of SchindlersX.

1. Introduction

   This framework establishes SDA"s structured approach to managing all complaints, whether from customers or employees, aiming to address and resolve issues promptly, equitably, and efficiently.

2. Objective

   To create a harmonized process for identifying, reporting, investigating, and resolving both external and internal complaints, ensuring adherence to regulatory standards and promoting a culture of openness and improvement.

3. Principles

   The core principles guiding this framework include fairness, accessibility, confidentiality, responsiveness, and a commitment to continuous improvement.

4. Scope

   This framework applies to complaints received from customers and employees regarding SDA"s products, services, workplace environment, or conduct.

5. Roles and Responsibilities

   5.1 Complaints Officer: Appointed to manage the complaints process, acting as a central point of coordination for both customer and employee complaints.

   5.2 Human Resources (HR): Handles all internal employee complaints, working closely with the Complaints Officer to ensure consistency.

   5.3 Senior Management: Reviews escalated complaints and oversees the implementation of systemic improvements based on feedback.

6. Receipt of Complaints

   6.1 Multiple Channels for Submission: Both customers and employees can submit complaints through various channels, including email or in-person meetings.

   6.2 Acknowledgment: Every complaint is acknowledged within one working day, with complainants receiving a reference number for tracking purposes.

7. Recording and Categorization

   7.1 Centralized Register: All complaints are logged into a centralized system that categorizes them based on nature, urgency, and severity.

   7.2 Triage System: Complaints are triaged to determine the appropriate pathway and urgency for resolution.

8. Investigation

   8.1 Impartial Investigation: An impartial investigation is conducted for each complaint to ascertain facts, gather evidence, and identify the root cause.

   8.2 Employee Complaints: For internal complaints, HR ensures investigations are conducted with respect to privacy and in accordance with employment law.

9. Resolution and Redress

   9.1 Resolution Strategy: A clear resolution strategy is developed, tailored to the specifics of the complaint, with an aim for timely and satisfactory resolution.

   9.2 Remedial Actions: Appropriate remedial actions are identified and implemented, which may include an apology, changes to processes or policies, retraining, or other corrective measures.

10. Communication

    10.1 Ongoing Updates: Complainants are kept informed throughout the process, with transparency about investigation progress and expected timeframes.

    10.2 Outcome Communication: A clear explanation of the outcome is communicated to the complainant, including any steps taken to resolve the issue.

11. Monitoring, Reporting, and Learning

    11.1 Performance Monitoring: The effectiveness of the complaints management process is regularly monitored against KPIs, such as resolution times and satisfaction rates.

    11.2 Reporting: Regular reports summarizing complaint trends, outcomes, and lessons learned are presented to management and relevant stakeholders.

    11.3 Continuous Improvement Cycle: Data from complaints are analyzed to identify systemic issues and opportunities for improvement, feeding into a continuous improvement cycle.

12. Training and Development

    12.1 Comprehensive Training: The complaints officer receives training on the complaints management process, including how to handle, escalate, and resolve complaints appropriately.

    12.2 Skill Enhancement: Specific training is provided to those involved in managing and investigating complaints to enhance their skills in problem-solving, communication, and empathy.

13. Regulatory Compliance and Review

    13.1 Regulatory Alignment: The framework is designed to comply with all relevant consumer protection laws, employment laws, and industry regulations.

    13.2 Regular Framework Review: The complaints management framework is reviewed annually, or more frequently if regulatory changes occur or in response to an internal review.

14. Internal and External Communication

    14.1 Transparency with Employees: Employees are informed about how to report concerns and are assured that complaints will be treated with respect and without retaliation.

    14.2 Public Commitment: SDA publicly commits to high standards of customer service and a respectful workplace, underlining the importance of feedback and the value of complaints in driving improvements.

15. How the Complaint will be handled at SDA

    Once we have received your complaint containing all of the necessary detail, you can expect the complaint to be handled as follows:

    15.1 A SDA Complaints Officer will be assigned to your complaint and will acknowledge receipt of your complaint within 3 business days, by email to the email address provided in your complaint.

    15.2 If SDA Complaints Officer is able to resolve your complaint immediately, you will receive a Resolution Notice with feedback at the same time as the acknowledgement.

    15.3 If the complaint is of a more complex nature and cannot be resolved immediately, the Complaints Officer will investigate the matter further. As part of the investigation, the Complaints Officer is entitled to request further information from you or require you to make written representations. The Complaints Officer will do his/her best to resolve the complaint and provide you with a Resolution Notice within 15 business days. If the complaint involves multiple issues and reasonably cannot be resolved within 15 business days, we will resolve it as soon as reasonably possible and will keep you updated on a regular basis.

    15.4 A Resolution Notice will set out, when applicable:

    15.4.1 Where your complaint was accepted and how your complaint was resolved

    15.4.2 Where your complaint was rejected and the reasons for this decision

    15.4.3 Where you have requested specific action or redress, whether the action or redress is possible and/or available

    15.4.4 Possible further steps which may be available to you.

    15.5 Complaints Officers are committed to demonstrating objectivity and decisions will be made on fact. Should you feel that the decision made was unfair or incorrect, you may request that the matter be reviewed. This process will involve the following:

    15.5.1 You may request that the matter be reviewed by sending a written request to this effect within 7 days of receiving the Resolution Notice. You must include written reasons for taking the matter on review.

    15.5.2 The review will be referred to the Complaints Manager for consideration. The Complaints Manager will acknowledge your request to review the matter within 3 business days, by email to the email address provided in your complaint.

    15.5.3 Subject to point 15.5.4 directly below, the Complaints Manager will investigate and decide on the matter within 15 business days. During this time, the Complaints Manager is entitled to request further information from you or require you to make written representations.

    15.5.4 Depending on the complexity of your complaint, the Complaints Manager may, in his/her discretion convene a Complaints Committee comprised of senior management at SDA to investigate and examine your complaint, in which event you will be notified. The Complaints Committee will be required to reach a decision within no more than 20 business days. The Complaints Committee is entitled to request further information from you or require you to make written representations.

    15.5.5 The Complaints Manager will provide you with a written decision of the outcome of your review and any further steps which are available to you.

    15.6 If your complaint has not been resolved by the Complaints Manager to your satisfaction, you may be entitled to take external adjudicative action depending on the nature of your complaint.

16. External adjudication

    Depending on the nature of the complaint, the country of origin, SDA entity involved or a number of other factors, you may be able to approach an external adjudicator to review a decision made by SDA regarding the outcome of your complaint. Before approaching a potential adjudicator, please allow SDA to investigate and reply to your complaint first by following process outlined in this Complaints Policy.

    If there are external adjudicative options available to you, the Complaints Officer will do his/her best to bring these to your attention but this does not exclude you from taking any steps yourself. Please be advised that there might be deadlines applicable to filing any action or specific conditions which apply to your complaint.

17. Legal action

    We draw your attention to the fact that, if you wish to institute legal action against SDA regarding the outcome of your complaint, you must do so within 1 year after the date on which the final decision is communicated to you by the Complaints Manager.

SDA"s complaints management framework is integral to its commitment to operational excellence, customer satisfaction, and employee engagement. By addressing complaints through this comprehensive and responsive system, SDA demonstrates its dedication to upholding high standards of service and fostering a positive and productive work environment.