1. Policy

  • 1.1 Introduction

    Investec Limited (“Investec”) aims to ensure that all complaints received are investigated fairly, fully, promptly and in accordance with the regulatory requirements. Investec’s Complaints Management Policy sets out the overarching approach to the complaints management framework within Investec.

  • 1.2 Purpose of Policy

    Investec values the support of its clients and places strong emphasis on maintaining a long-term relationship that is open, honest and which is based on trust and transparency. Investec balances its entrepreneurial culture with a strong risk management discipline and a client-centric approach.


    In view of this, we encourage Investec’s clients to provide us with feedback to assist in establishing procedures to ensure that clients remain satisfied with the service offered by Investec.  A client wishing to raise an issue, concern or complaint is encouraged to use the formalised complaints procedure to ensure that Investec resolves the issue timeously, effectively and is communicated to the client/s concerned.


    The purpose of this policy is to provide the foundation for implementing a consistent approach throughout Investec and, in turn, facilitate Investec’s compliance with its regulatory obligations. The key principles, objectives and requirements below set out guidelines and the standard to which Investec holds itself to.

  • 1.3 Scope of Application

    The policy applies to all employees, as well as consultants and contractors who work for Investec in South Africa. The principles contained in this policy also applies to international employees, consultants and contractors who provide services to Investec or its clients to the extent that the related products and services are provided from South Africa.

  • 1.4 Key principles and objectives

    Investec considers complainant feedback and complaints resolution to be a crucial focus of its client-centric approach and core to the way it conducts business. This policy creates opportunity for Investec to hear the complainant’s concerns, requirements, expressions of satisfaction or dissatisfaction, and to address these genuinely and effectively.


    This policy is centered around the Treating Customers Fairly (TCF) principles to ensure that Investec consistently delivers fair outcomes to clients and takes responsibility for the business and staff (at all levels) providing an enhanced quality of service to clients, based on a culture of openness and transparency.


    Investec will not impose unreasonable barriers for clients or prospective clients who wish to provide feedback/complaints and may not impose a charge for complainants utilising the process.

  • 1.5 Responsibilities

    It is the responsibility of one or more specific employees to oversee, implement and monitor complaints within each Business Unit (BU).  In order to mitigate any conflict of interest whilst handling complaints, the dedicated employee/s must have the appropriate level of authority, competence and resources to ensure the process is adhered to in a fair, objective and transparent manner. 

    Only an individual who is not directly involved in the matter, is not the subject of the complaint or who is free from any influence in relation to its resolution, is permitted to investigate a complaint.

  • 1.6 Definitions

    The terms and definitions below are applicable to this Policy:

    • Client of Investec means any individual or entity who currently has or previously had a business relationship with Investec or an Investec product, service or capability.
    • Compensation payment means provision of money, or a benefit or service, by or on behalf of Investec to a complainant to compensate him/her for a proven or estimated financial loss incurred as a result of the Investec’s non-compliance, action, failure to act, or unfair treatment forming the basis of the complaint, where Investec accepts liability for having caused the loss concerned, but excludes any -

    a) goodwill payment;

    b) payment contractually due to the complainant in terms of a product or service agreement with Investec; or

    c) refund of an amount paid by or on behalf of the complainant to the bank where such payment was not contractually due; and includes any Interest on late payment of any amount referred to in paragraphs (b) or (c);

    • Complainant - This means an individual or entity who submits a specific complaint to Investec or, to the knowledge of Investec and who:

    a) Is a client or prospective client of Investec and has a direct interest in the agreement, product, service, or capability to which the complaint relates; or

    b) has submitted the complaint on behalf of an individual or entity mentioned in (a).

    A prospective client is only seen as a complainant to the extent that the complaint relates to the prospective client’s dissatisfaction in relation to the application, approach, advertising, or marketing material (see definition of ‘prospective client’).

    • Complaint means an expression of dissatisfaction made to Investec, whether oral or written, to the knowledge of Investec, or to Investec’s service provider relating to a product or service provided or offered by Investec which indicates or alleges, regardless of whether such expression of dissatisfaction is submitted together with or in relation to a customer query, that-
    • Investec or its service provider has contravened or failed to comply with an agreement, a law, a rule, or a code of conduct which is binding on Investec or to which it subscribes;
    • Investec or its service provider's maladministration or willful or negligent action or failure to act, has caused the individual or entity harm, prejudice, distress, or substantial inconvenience; or
    • Investec or its service provider has treated the individual or entity unfairly;
    • Compliment means an expression of praise or admiration;
    • Goodwill payment means the provision of money, a benefit or service by or on behalf of Investec to a complainant as an expression of goodwill aimed at resolving a complaint, where Investec does not accept liability for any financial loss to the complainant as a result of the matter complained about;
    • Prospective client of Investec means an individual or entity who approaches or applies to Investec to become a client, an individual or entity Investec solicits to become a client or an individual or entity who receives marketing or advertising material regarding Investec’s products, services or capabilities directly from Investec or an authorised representation thereof;
    • Rejected means in relation to a complaint means that a complaint has not been upheld and Investec regards the complaint as finalised after advising the complainant that it does not intend to take any further action to resolve the complaint and includes complaints regarded by Investec as unjustified or invalid, or where the complainant does not accept or respond to Investec’s proposals to resolve the complaint;
    • Reportable complaint means any complaint other than a complaint that has been -

    (a) upheld immediately by the person who initially received the complaint;

    (b) upheld within Investec’s ordinary processes for handling customer queries in relation to the type of financial product or financial service complained about, provided that such process does not take more than five business days from the date the complaint is received; or

    (c) submitted to or brought to the attention of Investec in such a manner that Investec does not have a reasonable opportunity to record such details of the complaint as may be prescribed in relation to reportable complaints.

    • Service provider means any other individual or entity who has an arrangement with Investec in relation to the marketing, distribution, administration or provision of products, services or capabilities, regardless of whether or not this individual or entity is the agent of Investec, and to whose products or services the client feedback/complaint relates;
    • Suggestion means an idea put forward for consideration;
    • Upheld means that a complaint has been finalised wholly or partially in favour of the complainant and that -

    (a) the complainant has explicitly accepted that the matter is fully resolved; or

    (b) it is reasonable for Investec to assume that the complainant has so accepted; and all undertakings made by Investec to resolve the complaint have been met or the complainant has explicitly indicated satisfaction with any arrangements to ensure such undertakings will be met by Investec within a time acceptable to the complainant.

  • 1.7 Policy Updates

    This policy will be reviewed and approved on an annual basis.  Changes may be recommended at any time as and in response to changing circumstances. The policy must be approved by the Investec’s Compliance Policy Review Committee whenever there are material changes to the policy.

2. Catergorisation of complaints 


All complaints must be managed and categorised according to relevant regulations, including but not limited to the FAIS General Code of Conduct and the Conduct Standards for Banks which are underpinned by the TCF outcomes. 

The aim of the categorisation is to support the effectiveness of Investec’s complaint management framework in managing conduct risk and effecting improved outcomes and processes for Investec’s complainants. Each Business Unit (“BU”) will utilise the categories and may have additional categories relevant to its business model, financial products and services and its target market and/or client base. 


3. Prompt Attention to Complaints


All complaints received must be identified and handled promptly and in accordance with regulatory requirements. Investec will acknowledge the complaint with the complainant as soon as possible and will regularly inform the complainant of the progress made in finalising the complaint. Investec will additionally inform the complainant of its decision in response to the complaint.  


4. Process and Procedures


Investec will abide by the following general principles on receipt of a complaint, irrespective of the business area the complaint relates to:

  • acknowledge receipt of the complaint and inform the complainant of the applicable complaints handling process and resolution timeline;
  • investigate the complaint competently, diligently and impartially, obtaining additional information as necessary;
  • assess fairly, consistently, and promptly:
  • the subject matter of the complaint;
  • whether the complaint should be upheld or rejected;
  • what remedial action or redress (or both) may be appropriate; and
  • if appropriate, whether Investec has reasonable grounds to be satisfied that another party may be solely or jointly responsible for the matter alleged in the complaint.
  • ensure that plain language is used in all communications with a complainant.

Having performed the above, Investec will:

  • explain to the complainant promptly and, in a way that is fair, clear and not misleading, Investec’s assessment/investigation of the complaint, its decision on it; 
  • provide reasons for the decision and provide possible recourse available for the complainant regarding the decision where the complaint is rejected; 
  • offer redress or remedial action when appropriate (always seeking to put the complainant back in the position they were in before the cause of complaint occurred) and notify the complainant of the options available to them if they are still dissatisfied, notifying complainants of their right to approach the appropriate Ombudsman / Regulator; and
  • comply promptly with any offer of remedial action or redress accepted by the complainant.

Investec will take certain factors into account in the assessment/investigation of a complaint including the following:

  • all the available evidence and the circumstances of the complaint;
  • similarities with other complaints received by Investec; and
  • relevant guidance published by the Financial Sector Conduct Authority (FSCA), other relevant regulators, the Ombudsman.

Each BU will document its complaints management and/or handling procedures and shall stipulate the escalation, decision-making, monitoring, oversight and review processes for its particular BU. The respective BU complaints escalation procedures will provide the applicable internal escalation of complex or unusual complaints, including the allocation of persons of appropriate seniority and expertise within Investec to ensure that the compliant is appropriately managed and resolved.

Each BU will determine the appropriate timeframes applicable to its business having considered the applicable regulatory prescribed timelines, its business model, financial products and services and its target market/ client base. The BUs will further determine the circumstances under which the extension of timeframes may be permitted as part of its complaint’s management processes and procedures.

Complaints information will be recorded, scrutinised and analysed on an ongoing basis and will be utilised to:

  • proactively identify and manage conduct risks;
  • effect improved outcomes and processes for its clients; and
  • prevent reoccurrences of poor outcomes and errors.


5. Complaints Management 



Investec’s Board is responsible for effective complaints management and approves and oversees the effectiveness of the implementation of Investec’s complaints management policy. This oversight responsibility can be delegated to the respective senior management across all the BUs.

BUs are similarly responsible for conducting investigations, analysing complaints, approving proposed remediation or redress and monitoring the complaints handling process. When conducting investigations, the business may draw upon the experience and input of any individual within Investec to assist them with the investigation.


6. Performance standards and remuneration in relation to complaints management


Investec’s remuneration philosophy is underpinned by our value to drive an entrepreneurial spirit in the organisation. We seek to use our various reward levers to attract talent, retain these outstanding individuals and recognise as well as further motivate exceptional performance. The Investec group is committed to offering all employees a reward package that is competitive, performance-driven and fair and the group’s remuneration policy statement is designed to promote the long-term success of Investec.

Investec provides for appropriate performance standards and remuneration and reward strategies for complaints management to ensure objectivity and impartiality.


7. Record Keeping


Investec retains records of all complaints received in accordance with its statutory and regulatory obligations. Each division within Investec has its own processes in place for the accurate recording of all complaints received and the measures taken to investigate and respond to the complainant and/or resolve the complaint. The records will be kept in accordance with Investec’s record retention policies. Investec will treat all information relating to the complaint with confidentially.


8. Reporting


Investec BUs report on all complaints received within their respective governance structures including the identified risks, trends and actions taken in response thereto and the effectiveness and outcomes of the complaints management. All complaints received via the Ombudsman are also reported to Board and/or its respective sub-committees.

All reportable complaints shall be reported to the FSCA in accordance with reporting requirements (including public reporting).


9. Service Provider


Where Investec outsources regulated activities, it ensures that the Service Provider has in place its own Complaints Policy that complies with the regulatory requirements for dealing promptly and fairly with complaints. Investec must review the Service Providers complaints management framework to ensure the following:

  • the Service Provider has adequate complaints management processes in place to ensure fair treatment of complainants; 
  • there are provisions for the monitoring and analysis of aggregated complaints data in relation to complaints received by the Service Provider and related outcomes; 
  • an effective referral process will be enabled between Investec and the Service Provider to cater for the handling and monitoring of complaints that are submitted directly to Investec and to facilitate referral to the other for resolution; and
  • that there are processes in place that ensure that complainants are appropriately informed of the process being followed, the progress and the outcome of the complaint.


10. Training


All employees are trained on general client feedback and complaints handling processes and the importance of keeping a record of the complaints received. Bespoke training shall provide for those directly involved in the client feedback process.


11. Client Awareness


Investec shall publish this policy together with respective complaints procedures on its website (including BU websites) to ensure client awareness of Investec’s complaints management policy and complaints handling processes.  Moreover, client documentation contains (where appropriate) details of Investec’s complaints handling procedures and the rights of clients to ultimately refer their complaints to the appropriate Ombudsman should they so wish to do so.


12. Ombudsman Contact


The SA Client Resolution Team is the point of contact for Investec with the Banking Ombudsman for complaints. The respective FAIS Compliance Officer is the point of entry for Investec with the FAIS Ombudsman/Short-term Insurance and Long-term Insurance, respectively. Complaints relating to Johannesburg Stock Exchange investments will be referred to the JSE Surveillance Department.