Complaints Management Framework

POLICY BACKGROUND

NEWERA CAPITAL MARKETS (Pty) Ltd ("the Company") Registration number : 2024/447619/07, FSP 54447 is committed to providing financial services honestly, fairly, with due skill, care and diligence, and in the best interests of its clients. The Company recognizes that an effective complaints management framework is essential to maintaining client confidence, improving service quality and meeting its regulatory obligations as an authorized Financial Services Provider.

The Company views complaints as an opportunity to identify service shortcomings, strengthen internal controls and improve customer outcomes. Complaints are managed fairly, consistently, transparently and without unreasonable delay, ensuring that complainants are treated with respect throughout the complaints process.

This Complaints Management Framework forms part of the Company's Governance Framework and should be read together with the Business Plan, Code of Ethics and Conduct, Risk Management Policy, Compliance Management Framework, Conflict of Interest Management Policy and other governance documents.

1. PURPOSE

The purpose of this Complaints Management Framework is to establish a fair, transparent and effective process for the receipt, investigation, resolution, monitoring and reporting of complaints received by the Company.

The Framework aims to ensure that complaints are managed consistently, objectively and within reasonable timeframes while protecting the rights and interests of clients and supporting compliance with applicable legislative and regulatory requirements.

2. OBJECTIVES

The objectives of this Framework are to:

• establish an accessible and effective complaints management process;
• ensure that complaints are handled fairly, objectively and consistently;
• promote the fair treatment of clients throughout the complaints process;
• identify and address the root causes of complaints;
• support continuous improvement in the Company's products, services and business processes;
• comply with applicable legislative and regulatory requirements;
• maintain appropriate complaints records; and
• provide meaningful complaints reporting to management and the Board.

3. SCOPE

This Framework applies to:

• all directors;
• the Key Individual;
• Representatives;
• employees;
• outsourced service providers involved in complaint handling; and
• all complaints relating to financial services rendered by the Company.

This Framework applies to complaints received through any communication channel, including written correspondence, email, telephone, electronic platforms and verbal complaints that are subsequently recorded by the Company.

4. LEGISLATIVE AND REGULATORY FRAMEWORK

This Framework has been developed with due consideration to the legislative and regulatory requirements applicable to Financial Services Providers.

The primary legislative and regulatory framework includes:

The Company shall review this Framework whenever legislative or regulatory developments require amendments.

5. DEFINITIONS

6. COMPLAINTS MANAGEMENT FRAMEWORK

6.1 General

The Company shall maintain an effective, transparent and accessible complaints management framework that enables complaints to be received, investigated, resolved and monitored in a fair, objective and timely manner.

The Framework shall support the Company's commitment to treating customers fairly, improving service delivery and complying with applicable legislative and regulatory requirements.

Complaints shall be managed in a manner that is proportionate to the nature, size and complexity of the Company's business.

6.2 Complaints Management Principles

The Company shall ensure that complaints are managed in accordance with the following principles:

• fairness and impartiality;
• accessibility and transparency;
• timely acknowledgement and resolution;
• consistency in complaint handling;
• confidentiality of complainant information;
• objective investigation of complaints;
• appropriate record keeping; and
• continuous improvement through complaint analysis.

6.3 Accessibility

Clients may submit complaints through any of the communication channels approved by the Company, including:

• Email – compliance.sa@newera365.com
• Telephone – 084 281 4524
• the Company's website – https://newera365.com/legal/
• any other communication channel designated by the Company.

The Company shall make information regarding its complaints process readily available to clients.

6.4 Complaints Register

All complaints received by the Company shall be recorded in the official Complaints Register.

The Register shall include, where applicable:

• the complaint reference number;
• complainant details;
• date received;
• summary of the complaint;
• responsible person;
• investigation status;
• outcome of the complaint;
• date resolved; and
• any corrective actions implemented.

7. COMPLAINT HANDLING PROCESS

7.1 Receipt of Complaints

The Company shall acknowledge receipt of a complaint as soon as reasonably practicable after it has been received.

Each complaint shall be assigned a unique reference number to facilitate monitoring and communication with the complainant.

7.2 Initial Assessment

Upon receipt, the Company shall conduct an initial assessment to determine:

• whether the matter constitutes a complaint;
• the nature and complexity of the complaint;
• whether additional information is required;
• the person responsible for handling the complaint; and
• the expected timeframe for resolution.

7.3 Investigation

Each complaint shall be investigated objectively, fairly and without unreasonable delay.

The investigation may include:

• reviewing relevant documentation;
• obtaining information from employees or Representatives;
• communicating with the complainant where clarification is required;
• considering applicable legislation, regulatory requirements and Company policies; and
• determining the appropriate outcome.

7.4 Resolution

Following completion of the investigation, the Company shall communicate its decision to the complainant in clear and understandable language.

Where a complaint is upheld, the Company shall implement appropriate remedial action without unreasonable delay.

Where a complaint is not upheld, the Company shall provide the complainant with the reasons for the decision and advise the complainant of any available escalation or external dispute resolution options.

7.5 Timeframes

The Company shall endeavor to resolve complaints as soon as reasonably practicable.

Where additional time is required due to the complexity of the complaint, the complainant shall be informed of:

• the reason for the delay;
• the expected timeframe for completion; and
• any further information required to finalize the investigation.

8. COMPLAINTS CLASSIFICATION AND INVESTIGATION

8.1 Complaints Classification

For monitoring and reporting purposes, complaints may be classified according to:

• advice-related complaints;
• service-related complaints;
• administrative complaints;
• disclosure-related complaints;
• complaints relating to Representatives;
• complaints relating to conflicts of interest;
• complaints relating to fees or charges; and
• any other category determined by the Company.

8.2 Root Cause Analysis

Where appropriate, the Company shall conduct a root cause analysis to determine whether a complaint indicates:

• deficiencies in internal controls;
• weaknesses in business processes;
• inadequate training;
• compliance failures;
• conduct risk;
• operational risk; or
• opportunities for service improvement.

Lessons identified through complaint investigations shall be considered during risk management, compliance monitoring and business improvement activities.

9. ROLES AND RESPONSIBILITIES

9.1 Board of Directors

The Board of Directors shall retain ultimate responsibility for the oversight of the Company's complaints management framework.

The Board shall:

• approve this Complaints Management Framework and any material amendments;
• ensure that adequate resources are available to support effective complaints management;
• oversee complaints trends and significant complaints;
• monitor the effectiveness of the Company's complaints handling arrangements;
• ensure that complaints are considered as part of the Company's governance and risk management processes; and
• promote a culture that supports the fair treatment of clients.

9.2 Key Individual

Mr Mongiwethu Kumalo shall be responsible for the implementation and administration of this Framework and shall:

• oversee the Company's complaints management process;
• ensure that complaints are investigated objectively and fairly;
• monitor compliance with this Framework;
• review complaints trends and root causes;
• recommend corrective actions where appropriate; and
• report significant complaints and complaints trends to the Board.

9.3 Representatives and Employees

All Representatives and employees shall:

• promptly report complaints received from clients;
• cooperate with complaint investigations;
• provide accurate and complete information during investigations;
• maintain confidentiality throughout the complaints process; and
• implement corrective actions where required.

9.4 Outsourced Service Providers

Where complaint handling activities involve outsourced service providers, such providers shall cooperate with the Company and comply with applicable contractual obligations and regulatory requirements.

10. RECORD KEEPING AND REPORTING

10.1 Complaints Record

The Company shall maintain complete, accurate and up-to-date records of all complaints received.

Complaint records shall include:

• complaint reference number;
• complainant details;
• date received;
• nature of the complaint;
• investigation undertaken;
• outcome of the complaint;
• corrective action implemented;
• date finalized; and
• any escalation or external referral.

Complaint records shall be retained in accordance with applicable legislative requirements and the Company's Record Management Policy.

10.2 Complaints Reporting

The Company shall prepare periodic complaints reports for management and the Board.

Reports may include:

• the number of complaints received;
• complaint categories;
• average resolution times;
• upheld and rejected complaints;
• recurring complaint themes;
• root cause analysis findings;
• corrective actions implemented; and
• recommendations for process improvements.

Complaint reporting shall support the Company's Risk Management Framework, Compliance Management Framework and Treating Customers Fairly (TCF) objectives.

11. MONITORING AND REVIEW

11.1 Monitoring

The Company shall continuously monitor the effectiveness of this Framework to ensure that complaints are managed fairly, consistently and in accordance with applicable legislative and regulatory requirements.

Monitoring activities may include:

• review of complaint files;
• trend analysis;
• root cause analysis;
• monitoring complaint resolution timeframes;
• review of corrective actions; and
• assessment of customer outcomes.

11.2 Continuous Improvement

Information obtained through complaints shall be used to strengthen:

• internal controls;
• business processes;
• employee training;
• compliance monitoring;
• risk management; and
• customer service.

11.3 Policy Review

This Framework shall be reviewed at least annually and whenever:

• legislative or regulatory requirements change;
• significant complaint trends emerge;
• material deficiencies are identified;
• changes occur in the Company's operations; or
• the Board determines that amendments are necessary.

Recommendations arising from reviews shall be documented and approved before implementation.