Complaints

This policy complies with Sections 16 to 19 of the Notice on the General Code of Conduct for Authorised Financial Services Providers and Representatives, 2003. Recorded and Managed by SA Bullion Management (Pty) Ltd

Internal Complaints Procedure for all Complaints

1. All complaints received from clients ("the Complainants") must be forwarded to the Managing Director on the same day as receipt of such complaint.

2. Complainants with oral complaints must be requested to lodge such Complaints in writing where possible and include all relevant information and documentation and submit it to the Managing Director.

3. Receipt of a Complaint must be promptly acknowledged in writing to the Complainant by the Managing Director, with communication particulars of the Complaints Officer who will be involved in resolution of the complaint.

4. The Managing Director must immediately forward all details of the Complaint to the Complaints Officer.

5. The Complaints Officer must register each complaint in the complaints register and classify each complaint as either a significant or minor complaint. The following definitions are offered as a guideline as to how a complaint is assessed:

Significant Complaint a complaint involving financial loss, reputational risk to SA Bullion Management, a repetition of a minor complaint or where the circumstances warrant it being treated as significant, e.g. investigation is required.

Minor Complaint a complaint falling outside the above category

1. A full record of each Complaint received and all subsequent correspondence must be kept on record for a minimum period of 5 years from date of receipt of the Complaint or the termination date.

2. Access to this Complaints Process document must at all times be available to Clients.

3. Appropriate management controls must be available to ensure effective control and supervision of the Complaints Process.

Procedure for resolution of Minor Complaints

1. The Complaints Officer may revert the Complaint back to the relevant recipient employee for resolution. The staff member must finalise the Complaint in writing. Records of the resolution must be kept for a minimum period of 5 years since date of receipt of the Complaint or the termination date.

2. The staff member must contact the Client within three weeks from date of receipt of the Complaint to follow up as to whether the complaint has been dealt with satisfactorily.

Procedure for resolution of Significant Complaints

1. The Complaints Officer must make a follow-up call to the Complainant within 5 working days from receipt of the Complaint, confirming that a written response will be forthcoming as soon as possible.

2. All actions to be undertaken must be reported in the Complaints Register.

3. The Complaints Officer must inform the Managing Director of the details of the Complaint and the proposed resolution.

4. Complaints must be reviewed every 5 working days and the progress reported to the Managing Director.

5. Upon finalization of all investigations and findings and drafting of a proposed resolution (if applicable) by the Complaints Officer, these must be reported to the Managing Director for review and approval.

6. The Complaints Officer will then, within 6 weeks of receipt of the Complaint, forward a formal response in writing to the Complainant. If the response is not to the satisfaction of the Complainant, full written reasons for the decision must be furnished to the Complainant and the Complainant must be advised that: (a) the Complainant may take the matter up with Ombudsman for Financial Services Providers (with contact details provided, and (b) that the Complainant should take the matter up with the Ombudsman within 6 months of receiving this notification. In the event that a Complaint is resolved in favour of the Complainant the provider must ensure that a full and appropriate level of redress is offered to the Complainant without any delay.

7. Any rectification or compensation agreed upon must be recorded in the Complaints Register.

8. Where the Complainant has received a full reply and has not responded within one month of its despatch, the Complaint can be treated as being resolved. Should the Complainant not respond within one month of receipt of formal response or indicate that it is satisfied with the proposed resolution, the Complaints Register should be "signed off" by the Complaints Officer to confirm the Complaint has been formally resolved.

Definitions

1. Complaint means a complaint relating to a service rendered by SA Bullion Management and/or any of its representatives to the Complainant in which Complaint it is alleged that SA Bullion Management or representative(s) - (a) has contravened or failed to comply with any legislation or Act and as a result thereof the Complainant has suffered or is likely to suffer financial prejudice or damage; (b) has wilfully or negligently rendered a financial service to the Complainant and which has caused prejudice or damage to the Complainant or which is likely to result in such prejudice or damage; or (c) has treated the Complainant unfairly

2. The Pension Funds Adjudicator:
Physical address:
The Pension Funds Adjudicator 2nd Floor, Oakdale House Fedsure Oval Oakdale Road Newlands 7700
Postal address:
P O Box 23005 Claremont 7735
Tel: (021) 674 0209
Fax: (021) 674 0185
E-mail:Enquiries@pfa.org.za

3. Office of the Ombud for Financial Services Providers:
Postal address:
The Financial Services Ombud PO Box 74571 Lynnwoodridge 0040
Tel: (012) 470 9080 or 0860 324 766
Fax: (012) 348 3447
E-mail:info@faisombud.co.za
Internet:www.faisombud.co.za