1.    Purpose

The purpose of this policy is to set out Navinci’s approach to Complaints management.

2.    Scope

This policy applies to Navinci entities and Employees in Australia.

3.    Definitions

Employee(s) includes an employee, director, contactor (including individual contractor) or representative of Navinci.

Navinci or we, us, our means Navinci Global Markets Pty Limited and its related bodies corporate. This includes any affiliate entities and authorised representatives.

4.    Policy Principles

At Navinci, we are committed to providing high-quality financial services to our clients. We value feedback and aim to resolve complaints efficiently and effectively. This policy outlines the procedures for handling complaints to ensure a fair and prompt resolution.

5.    Scope

This policy applies to all complaints made by wholesale clients regarding the services provided by Navinci.[1]

5.1    Definition of a Complaint

A complaint is any expression of dissatisfaction made to Navinci about our products, services, or staff, where a response or resolution is explicitly or implicitly expected.

5.2    How to Lodge a Complaint

Complaints can be lodged through the following channels:

·         Email: compliance@navincigm.com

·         Phone: 1300 103 408

·         Mail: Attention: Head of Legal and Compliance, Navinci Global Markets Pty Ltd, Level 10, 75 Pitt Street, Sydney, NSW, Australia

We request that customers please be respectful in their engagement with Navinci employees when making a complaint or providing feedback. Navinci does not tolerate unreasonable, abusive, aggressive or disrespectful behaviour. 

Please note that this policy does not apply to recruitment or employment-related complaints. These will be referred to the relevant contact internally for consideration.

5.3    Information to Provide

To help us resolve the complaint promptly, we ask that you please provide us with the following information:

·         Name and contact details

·         Detailed description of complaint

·         Any relevant documents or correspondence

·         The desired outcome or resolution

5.4    Acknowledgement of Complaints

We will acknowledge receipt of your complaint within 5 business days. This acknowledgment will include the name and contact details of the person handling your complaint.

5.5    Investigation and Resolution

·         Initial Review: Your complaint will be reviewed by a Navinci Compliance representative.

·         Investigation: We will investigate the complaint. This may involve contacting you for further information or clarification.

·         Resolution: We aim to resolve all complaints within 30 business days. If the complaint is complex and requires more time, we will keep you informed of the progress and the expected resolution timeframe.

5.6    Response

Once the investigation is complete, we will provide you with a written response outlining:

·         The outcome of the investigation

·         The reasons for Navinci’s decision

·         Any actions we have taken or will take to resolve the complaint

5.7    Escalation

If you are not satisfied with our response, you may request a review of your complaint by a senior executive or escalate the complaint to an external dispute resolution scheme.

10. External Dispute Resolution

As Navinci does not provide financial products or services to retail clients, it is not a member of Australian Financial Complaints Authority (AFCA). At the date of this policy, wholesale financial services clients do not form part of the core legislative external dispute resolution obligation, and as such AFCA’s Rules give AFCA a discretion to exclude a complaint by a wholesale client (as defined in the Corporations Act 2001 (Cth)), even if that complaint would otherwise fall within AFCA’s jurisdiction.

5.8    Continuous Improvement

We are committed to improving our customer experience. We appreciate that feedback can give us important insights into how we might improve.

5.9    How we monitor complaints

Complaints are reported to Navinci’s Senior Management / Board periodically.

Navinci’s Head of Legal and Compliance is responsible for managing this policy. This policy is subject to review in accordance with our Compliance Plan.

5.10  Confidentiality

All complaints will be handled in strict confidence. Your personal information disclosed to us as part of your complaint will be handled in accordance with our Privacy Policy, available from time to time on our website. You can request that your complaint and identity be kept confidential. We will endeavour to uphold such requests where practicable unless we are required or authorised to disclose information under applicable law or regulation, or to any regulator or government body. However, this may restrict our ability to investigate the complaint if we cannot contact you to clarify or seek further information.

5.11  Contact Information

For further information about our complaints policy or to lodge a complaint, please contact Navinci at the details set out in section 5.2 above.

5.12 Other

Please also note that we are subject to legislative and other confidentiality provisions that may limit our ability to provide information to you about third parties. If you are lodging a complaint on behalf of a third party, we reserve the right to seek evidence of your authority to do so and to receive communications on behalf of the third party.

6.    Compliance with this policy

Compliance by Navinci Employees with this policy is mandatory and a breach is considered to be a serious matter that may result in disciplinary action. Disciplinary action will be based on the severity of the matter and may include dismissal.

7.    Review

This policy will be reviewed every two (2) years, or earlier if required including due to any regulatory or legislative change. Compliance is responsible for managing and reviewing this policy.

8.    Further Information

Compliance manage this Policy. If you have any questions about this policy, please contact the Compliance team using the contact details set out above.

[1] Navinci does not have retail client authorisation on its Australian Financial Services Licence (AFSL).