1. Purpose, Scope & Definition
This policy details how Paayed Ltd (the firm) trading as Paayed Ltd handles client or potential client complaints.
Complaints must be handled fairly, promptly, in a transparent manner and provide consistent outcomes for all customers. This is in accordance with the FCA’s Principles of Treating Customers Fairly and Consumer Duty.
1.1 Scope
This policy applies to all employees of the firm and will govern all complaints made by clients or potential clients. All complaints should be immediately addressed to the Complaints Management Function.
1.2 Definitions
1.2.1 Complaint
A complaint includes any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of a person about the provision of, or failure to provide a financial service or a redress determination which:
Alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience; and
Relates to an activity which the firm has provided in relation to the provision of payment services and electronic money.
1.2.2 Eligible Complainant
An eligible complainant is a complainant that is
A consumer (a person acting outside their trade, business or profession)
A micro enterprise (which employs fewer than 10 people and has a turnover or balance sheet that does not exceed €2 million)
A charity with an annual income of less than £6.5 million (at the time of the complaint)
A trustee of a trust which has a net asset value of less than £5 million (at the time of the complaint)
A small business (enterprise which has an annual turnover of less than £6.5 million and employs fewer than 50 people or has a balance sheet total of less than £5 million)
A guarantor 1
In addition to meeting the criteria above, the eligible complainant must have a complaint which arises from the relationship with Paayed Ltd. The types of relationships include the following:
The complainant is or was a customer, payment service user or electronic money holder of the firm.
The complainant is (or was) a payer in a payment transaction in relation to which the firm is (or was) the payee’s payment service provider
The complainant is a person that has transferred funds as a result of an alleged authorised push payment fraud.2
In the case of eligible complainants, the firm will, in its final written response to the complaint, refer the complainant to the Financial Ombudsman Service (“FOS”).
1.2.3 Non-Eligible Complainant
A non-eligible complainant can be defined as a person who does not fall within the meaning of an eligible complaint3 but has a complaint which arises from either:
being, (or was) a customer, payment service user or electronic money holder of the firm or;
being (or was) a potential customer payment service user, or electronic money holder of the firm.
When a complaint has been received, the Complaints Management Function will determine whether it has been provided by an eligible complainant.
For the avoidance of doubt, the firm will deal with non-eligible complainants in the same manner as eligible complainants. However, non-eligible complainants as defined by the FCA will not have access to the Financial Ombudsman Service.
2. Complaints Collection Process
Customers and Non Customers can make complaints via:
Web form: paayed.com
Letter: One Canada Square, London, E14 5AB
Telephone: 0330.030.0045
3. Complaints Management Function
The Compliance Officer will operate Paayed’s Complaints Management Function, responsible for investigating all complaints received by a client.
The Compliance Management Function will also be responsible for reporting to the Board, the FCA and any relevant third parties about complaints received relating to payment services and electronic money. Reporting to the Board will be quarterly, reporting to the FCA will be annual in accordance with the electronic money and payment services complaints return form. Reporting to third parties will reflect contractual terms.
4. Complaints Procedure
4.1 Keeping the client informed
On receipt of a complaint, the firm will:
Send the client a prompt written acknowledgement providing reassurance that the complaint has been received and being is being dealt with and
Ensure the client is kept informed thereafter of the progress of the measures being taken for the client’s resolution.
Complaints will be handled promptly, effectively and in an independent manner, obtaining additional information as necessary. Communication with clients by the firm will be done clearly and in plain language that is easy to understand.
The Firm will assess all information relating to the complaint such as:
The subject matter of the complaint
Whether the complaint should be upheld
What remedial action or redress may be appropriate
Whether another party may be solely or jointly responsible for the matter alleged in the complaint.
4.2 Complaints handling time limits
The firm will apply the following time limits to client complaints, regardless of whether they derive from eligible complainants or non-eligible complainants.
Send a final response to the client by the end of 15 business days after the day on which it received the complaint; or
In exceptional circumstances, if a final response cannot be given in accordance with paragraph (1) for reasons beyond the control of the firm:
send a holding response to the complainant by the end of 15 business days after the day on which it received the complaint, clearly indicating the reasons for the delay in answering the complaint and specifying the deadline by which it will send the final response; and
send a final response to the complainant by the end of 35 business days after the day on which it received the complaint.
A final response sent under (1) or (2) above must be made in writing. The Firm will consider a complaint closed when it has issued its final response.
A final response to the client will:
accept the complaint and, where appropriate, offers redress or remedial action; or
offer redress or remedial action without accepting the complaint; or
reject the complaint and give reasons for doing so;
inform the complainant the option to forward their complaint to PayrNet Limited to re-evaluate our decision and provide a second opinion.
The final response will also:
enclose contact details of PayrNet Limited,
enclose a copy of the Financial Ombudsman Service’s standard explanatory leaflet;
provide the website address of the Financial Ombudsman Service;
inform the client that if they remain dissatisfied with our response, they can forward the complaint to PayrNet Limited or they can now refer the complaint to the Financial Ombudsman Service; (eligible complainants only).
When a complaint has been resolved within 3 working days, the firm will send the client a ‘summary resolution letter.’ If the complaint cannot be resolved within 3 working days, then a final response will be issued within the timelines above.
4.3. Complaints Handling
All client facing staff (including call centre and sales teams) will be trained to recognise and appropriately respond to expressions of dissatisfaction whether received verbally or in writing. Upon identifying a complaint, staff must:
Acknowledge the complaint promptly and ensure the client is treated with courtesy and respect throughout the process
Record all relevant details accurately (using the complains webform [link]) and forward all details to the Complaints Management Function via email – complaints@paayed.com
Refrain from attempting to resolve complaints
Inform the client that their complaint will be handled in accordance with our internal complaints procedure
4.4 Complaints Log
All complaints received are recorded in the firm’s Complaints Log which is managed by the Complaints Management Function. The log is maintained to ensure accurate tracking, monitoring and reporting of complaints in accordance with the FCA’s requirements.
The Complaints Log is also used to identify recurring issues, support root cause analysis and inform continuous improvement in line with the firm’s Consumer Duty obligations.
The Complaints Log includes key information such as (but not restricted to):
Complaint details
Date of receipt
Nature & substance of the complaint
Actions taken and responses given
Outcome and resolution date
Whether the complaint is reportable to the FCA
Any further action taken post complaint resolution
5. Client Awareness
The firm has published a summary of its complaints procedure on our website. The procedures will also be made available to clients and potential clients on request and when the Firm is acknowledging a complaint. The procedures contain information about the Financial Ombudsman Service.
6. Complaints Forwarding
The Firm may promptly forward the complaint in writing to another party if they have reasonable grounds to believe that the other party may be solely or jointly responsible for the matter alleged in the complaint. If a complaint is forwarded, the Firm will inform the complainant promptly in a final response of why the complaint has been forwarded to another party and provide the complainant with the other party’s contact details.
If the Firm receives a forwarded complaint, the complaint will be treated as if the Firm has received the complaint directly and the same time limits will apply from the date on which the Firm has received the forwarded complaint.
6.1 Financial Ombudsman Service
The Firm will co-operate fully with the Financial Ombudsman Service in resolving any complaints made against it and agrees to be bound by any awards made by the Ombudsman. The Firm undertakes to pay promptly the fees levied by the Financial Ombudsman Service.
6.2 Time Barring
If the Firm receives a complaint which is outside the time limits for referral to the Financial Ombudsman Service, it may reject the complaint without considering the merits but will explain this to the complainant in its final response.
6.3 PayrNet Limited
The Firm is committed to maintaining open and constructive communication with PayrNet Limited and will fully engage with the company. The firm will ensure that all information requests are acknowledged and responded to in a timely manner. Information requests will be provided to PayrNet Limited no later than five business days from receipt.
Paayed will fully engage proactively with PayrNet Limited and ensure that the business a timely response to information requests. The firm will respond to information requests relating to complaints no later then 5 business days.
7. Complaints Reporting & Analysis
Once a year, the Firm will provide the FCA with a complete report concerning complaints from complainants. Complaints that have been forwarded in their entirety to another party will not be included in the report.
The Firm will conduct root cause analysis of any complaint received and record any appropriate actions taken. Complaints will be analysed for any reoccurring patterns and all lessons learnt will be incorporated into future training and development. The causes of complaints will be recorded in the Management Information and be presented to the Board at least quarterly.
8. Training and Awareness
All staff will be training on the complaints policy and client facing staff will be trained on their specific responsibilities in terms of recording complaints or expressions of dissatisfaction, recording them and participating fully in any required investigations. e are committed to acting ethically and with integrity in all our business relationships and to implementing effective systems and controls to safeguard against modern slavery.
9. Record Keeping
The Firm will keep a record of each complaint received and the measures taken for its resolution, including any redress offered and retain that record for three years from the date the complaint was received.
