Sterling Vehicles Ltd Complaints Policy & Procedure Contents

1 Complaints Policy & Procedure 2 Complaint Handling 1 COMPLAINTS POLICY & PROCEDURE This document sets out the firms Complaints Procedure which comply with the FCA Sourcebook, DISP. As a firm we are committed to treating our customers fairly and we will seek to respond to all complaints received promptly and fairly. In order to ensure that complaints are fairly, consistently and promptly dealt with, a Director must be consulted in all cases, and any proposed course of action or correspondence signed off by the Director. The Director will be responsible for ensuring that any complaint is properly investigated and is done so competently, diligently and impartially and that the required timetable set by the FCA rules is adhered to. In the event that a complaint identifies a systemic, recurring or specific problem, the Director will seek to resolve it via discussion and the implementation of any conclusions arrived at. We treat all complaints very seriously. We will use data about complaints and how they are handled as a key measure of how successful we are at achieving our overarching goals of meeting our Consumer Duty obligations and conducting our business with integrity, due skill, care and diligence.

1.1 WHAT IS A COMPLAINT? The FCA defines a complaint to be any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, any person about the provision of, or failure to provide, a financial service, which: ∙ alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience; and ∙ relates to an activity of that financial institution, which comes under the jurisdiction of the Financial Ombudsman Service. The definition of "complaint" in DISP is a broad one and there is little in the way of case law to give certainty as to what is or is not a complaint. The Court of Appeal has though confirmed that it is possible for a complaint to be contained in more than one communication. We therefore need to interpret the definition widely and prudently.

1.2 INVESTIGATING, ASSESSING AND RESOLVING COMPLAINTS Our obligations under DISP are that, upon receipt of a complaint, we must: ∙ investigate the complaint competently, diligently and impartially, obtaining additional information as necessary; ∙ assess fairly, consistently and promptly taking into account all relevant factors: o the subject matter of the complaint; o whether the complaint should be upheld; o what remedial action or redress (or both) may be appropriate; o if appropriate, whether we have reasonable grounds to be satisfied that another respondent may be solely or jointly responsible for the matter alleged in the complaint; ∙ offer redress or remedial action when we decide this is appropriate; ∙ explain to the complainant promptly and, in a way that is fair, clear and not misleading, our assessment of the complaint, our decision on it, and any offer of remedial action or redress; and ∙ comply promptly with any offer of remedial action or redress accepted by the complainant.

1.3 TIME BARRED COMPLAINTS If we receive a complaint which is outside the time limits for referral to the Financial Ombudsman Service we may reject the complaint without considering the merits of the complaint. If we chose to so reject a complaint, we must explain this to the complainant in a final response letter 1.4 FORWARDING AND FORWARDED COMPLAINTS If we were to receive a complaint but we are satisfied that the complaint actually relates to another firm, or that the complaint relates to us and another firm jointly, we will refer the matter on to that firm so that they can consider the customers complaint. We will do this promptly and tell the client what we have done. We will also provide the client with the other firm's contact details. If we receive a forwarded complaint, it will be dealt with in accordance with this policy with the time frames applying from the date the forwarded complaint was received by us. For complaints where we have a shared responsibility, we will deal with the portion of the complaint that relates to us in accordance with this policy. 2 COMPLAINT HANDLING 2.1 IDENTIFY THE COMPLAINT A complaint will involve an allegation from a customer or potential customer that they have suffered financial loss, distress or material inconvenience in the company’s provision or failure to provide a financial service. If the recipient of the complaint is unsure regarding the complaint please refer it to a Director. In the event that a customer wishes to make a complaint, this can be made verbally, by telephone or in person, or via a written communication delivered in person, via post, e-mail, sms or fax or any other reasonable means available. In the first instance, the complaint should be handled by the manager responsible for the account, in consultation with the Director, and resolution of the complaint sought. 2.2 COMPLAINTS RESOLVED WITHIN 3 BUSINESS DAYS We will seek to resolve any complaints received as quickly as possible with a view to reaching agreement with the complainant within 3 business days of receipt. In the case of resolved complaints note will be made in the customers file of any agreed course of action together with any copy correspondence. We will then promptly send the complainant a summary resolution communication which includes the following detail: ∙ refers to the fact that the complainant has made a complaint and informs the complainant that we now considers the complaint to have been resolved; ∙ informs the complainant that if he subsequently decides that he is dissatisfied with the resolution of the complaint he may be able to refer the complaint to the Financial Ombudsman Service but must do so within 6 months as otherwise the Ombudsman will not have our permission to consider the complaint and so will only be able to do so in very limited circumstances; ∙ provides the website address of the Financial Ombudsman Service and refers to the availability of further information on the website of the Financial Ombudsman Service. For any complaint received an entry should be made in the Complaints Register and the date of receipt of the complaint recorded in the Complaints Log, an example of the format of which appears in Appendix A. 2.3 PROCESS FOR COMPLAINTS NOT RESOLVED WITHIN 3 BUSINESS DAYS In the event that a complaint is not capable of resolution by the close of business on the third business day following the day on which it was received then a brief written explanation of the substance of the complaint should be provided together with any written correspondence from the customer concerned to the Director. At this point in time, an entry should be made in the Complaints Register and the date of receipt of the complaint recorded in the Complaints Log, an example of the format of which appears in Appendix A. If the complaint has not been resolved by the close of business on the second day, we must ensure that a copy of these internal procedures are sent to the customer and receipt of the complaint acknowledged in writing as soon as practicably possible to assure the customer that the complaint is being handled promptly. The name and job title of the person handling the complaint must be advised to the customer and the customer invited to contact should the need arise. 2.3.1 INVESTIGATION OF THE COMPLAINT Investigation must be done by a Director of the company. We must investigate a complaint and ensure we understand fully the nature of the complaint that has been made. We need to maintain good communication with the complainant and regularly update them with the status of our investigation, updating at least every two weeks during our investigation process. 2.3.2 AFTER 4 WEEKS If a complaint has not been resolved within 4 weeks of being received, unless the customer has already indicated in writing acceptance of a response by the company (provided that the response informed the customer how to pursue his complaint if he remained dissatisfied), and in the event that a final response has not been issued, a holding response must be sent to the customer explaining why the company is not yet in a position to resolve the complaint and indicating when the company will make further contact, which will be within 8 weeks of receipt of the complaint. 2.3.3 UNABLE TO ISSUE FINAL RESPONSE WITHIN 8 WEEKS In this event we will write to the complainant and explain that we are still not in a position to make a final response, outline the reasons for the further delay and indicate when we expect to be able to provide a final response; and also inform the complainant that they may now refer the complaint to the Financial Ombudsman Service if they are dissatisfied with the delay and we will enclose a copy of the Financial Ombudsman Service's explanatory leaflet. 2.3.4 FINAL RESPONSE A Final Response must be made within 8 weeks of receiving the complaint. This response sets out the final view of the company on the complaint, dealing directly with the issues the customer has raised. It will summarise the complaint and summarise the outcome of the investigation. The written final response must either: ∙ Accept the complaint and offer appropriate redress. We must include a clear explanation of how we have arrived at this offer. ∙ Reject the complaint giving the reasons behind this decision. ∙ A combination of a) and b) We must inform the customer that they have 8 weeks to respond to our final response until we consider the complaint closed. A complaint will be deemed to be closed where the company has sent a final response or where the customer has indicated in writing acceptance of the company’s earlier response. 2.3.5 CONTENT OF FINAL RESPONSE LETTER Our Final Response Letter must provide the complainant with full details of our understanding of the reasons for the complaint, our investigation into the circumstances behind the complaint, detailing relevant facts, our findings and whether the complaint is being upheld or not and whether any redress payment is to be offered. Our Final Response to the client must include the following text as applicable: a) Where we do not agree to waive the six-month time limit for the complaint to be referred to FOS “You have the right to refer your complaint to the Financial Ombudsman Service, free of charge – but you must do so within six months of the date of this letter. If you do not refer your complaint in time, the Ombudsman will not have our permission to consider your complaint and so will only be able to do so in very limited circumstances. For example, if the Ombudsman believes that the delay was as a result of exceptional circumstances.” b) The complaint was received outside of the time frames for a complaint to be referred to FOS and we do not consent to waive such “You have the right to refer your complaint to the Financial Ombudsman Service, free of charge. The Ombudsman might not be able to consider your complaint if: • what you’re complaining about happened more than six years ago, and • you’re complaining more than three years after you realised (or should have realised) that there was a problem. We think that your complaint was made outside of these time limits but this is a matter for the Ombudsman to decide. If the Ombudsman agrees with us, they will not have our permission to consider your complaint and so will only be able to do so in very limited circumstances (see below). If you do decide to refer your complaint to the Ombudsman you must do so within six months of the date of this letter. If you do not refer your complaint to the Ombudsman within six months of the date of this letter, the Ombudsman will not have our permission to consider your complaint and so will only be able to do so in very limited circumstances. The very limited circumstances referred to above include, where the Ombudsman believes that the delay was as a result of exceptional circumstances.” c) Where the complaint was received outside the time 6 or 3 year time limits and we do not consent to waive those time limits but do consent to waive the six-month time limit The Ombudsman might not be able to consider your complaint if: • what you’re complaining about happened more than six years ago, and • you’re complaining more than three years after you realised (or should have realised) that there was a problem. We think that your complaint was made outside of these time limits but this is a matter for the Ombudsman to decide. If the Ombudsman agrees with us, they will not have our permission to consider your complaint and so will only be able to do so in very limited circumstances. For example, if the Ombudsman believes that the delay was as a result of exceptional circumstances. The time limit for referring complaints to the Ombudsman is usually six months but we will consent to the Ombudsman considering your complaint even if you refer the complaint later than this.” d) We consent to waive all time limits “You have the right to refer your complaint to the Financial Ombudsman Service, free of charge. Although there are time limits for referring your complaint to the Ombudsman, we will consent to the Ombudsman considering your complaint even if you refer the complaint outside the time limits.” Our Final Response letter must also include The Financial Ombudsman Service Leaflet 2.4 RESOLUTION Where a complaint has been resolved, a final response should be issued to the customer. A final response is a written response from the company which accepts the complaint and, if appropriate, offers redress (appropriate redress may not involve financial redress, it may, for example, simply involve an apology); or offers redress without accepting the complaint or rejects the complaint and gives reasons for doing so, and which informs the customer that, if he remains dissatisfied with the company’s response, he may now refer his complaint to the Financial Ombudsman Service (“FOS”) which, should he wish to do so, must be done within 6 months. 2.4.1 FINANCIAL OMBUDSMAN SERVICE If a complainant is not satisfied after receiving the Final Response from us then they have the right to make a complaint to the Financial Ombudsman Service. They must do this within 6 months of the date of the Final Response letter. The Financial Ombudsman Services details are as follows: The Financial Ombudsman Service Exchange Tower London E14 9SR Tel: 0800 023 4567 (free for most people from a fixed line) or 0300 123 9123 (cheaper for those calling using a mobile) or 020 7964 0500 (if calling from abroad) Email: complaint.info@financial-ombudsman.org.uk Website: www.financial-ombudsman.org.uk We will co-operate fully with the Ombudsman in resolving any complaints made against us and will aim to respond within 2 business days to any information requests from the Ombudsman. We agree to be bound by any awards made by the Ombudsman. We undertake to pay promptly any fees levied by the Ombudsman. 2.5 RECORD KEEPING A record of the complaint must be retained by the company for 3 years from the date of the receipt of the complaint. A report must be made to the FCA via the FCA’s RegData system on an annual basis. This report specifies the total number of complaints received by the firm which were not settled by the close of business on the third business day after the receipt of the complaint in accordance with rule DISP 1.5.4. 2.6 ANALYSING COMPLAINTS DATA There are many sources of data and management information which firms can analyse in order to understand what is negatively impacting their customers, for example, retention data, cancellation rates and customer feedback. 2.6.1 ROOT CAUSE ANALYSIS DISP rules require that firms take steps to identify and remedy any recurring or systemic problems which lead to complaints. This includes examining the root causes of all complaints and changing procedures to reduce the impact on future customers, this analysis will be undertaken in relation to all complaints received, whether upheld, rejected or determined by FOS. It could also mean considering whether any detriment to existing customers, who may also have suffered, should be addressed. Beyond merely complying with the rules, however, the feedback we get from customers who make a complaint is information we might never otherwise find out. This is a view of how we perform in the eyes of the people that matter, the people that pay us for our services. We consider that performance and consider making improvements in response to this feedback. 2.6.2 IDENTIFYING THE ROOT CAUSE A complaint is the natural outcome from a chain of events that led to a customer deciding that they had been poorly treated. It is rare that the complainant can tell us the cause of the complaint, what they know is how it affected them. The root cause can often only be uncovered as part of the subsequent investigation. 2.6.3 USE OF ROOT CAUSE ANALYSIS DATA We will use root cause analysis to achieve the right customer outcomes and consider what the right customer outcome looks like in each individual case. ∙ We will ensure the MI is collected and analysed and is accurate and relevant to their operations. MI will be used to measure whether customers are treated fairly and to identify ways to improve customer outcomes. ∙ We will have robust root cause analysis capabilities to identify and remedy any recurring systemic problems. Effective root cause analysis will allow es to find and tackle the root causes of problems (through a process change or improvement). ∙ We have appropriate governance and processes in place to make sure root cause analysis provides strategic purpose, accurately identifying recurring or systemic problems. ∙ we will record complaints accurately. Weaknesses and failures in recording complaints may result in poor customer experiences and outcomes and affect our ability to put things right. ∙ make sure internal systems and controls allow staff to identify and record complaints correctly. ∙ Have processes in place to make sure the data in our FCA complaints returns are accurate. ∙ Establish and maintain effective and transparent procedures for the reasonable and prompt handling of complaints. ∙ Consider, for each complaint, whether the customer’s outcome and experience shows that we have put the customer’s interests first. Under the Consumer Duty rules (Principle 12) we are required to act to deliver good outcomes for retail clients. Inadequate application of good judgement may lead to poor outcomes and a breach of Principle 12. ∙ Make sure we assess complaints fairly, consistently and promptly. 2.7 STAFF ACKNOWLEDGMENT & RESPONSIBILITY All staff are required to sign a copy of these internal complaints procedures to confirm that they have received, read and agree to be bound by the requirements placed upon by them by these procedures as part of their contract of employment. Failure to comply with this policy may result in disciplinary action. 3 DISPUTE RESOLUTION SERVICE Unresolved disputes may be referred to the BVRLA by either the customer or the member involved. Details should be submitted online at https://bvrla.co.uk/consumer-advice/making-a-complaint adr.html If the customer does not have access to the internet, details can be sent by post to: British Vehicle Rental & Leasing Association River Lodge, Badminton Court Amersham, HP7 0DD The BVRLA will aim to resolve the matter using the information presented by both parties to the dispute. Any information requested from the member should be sent to the BVRLA within five working days. Based on the information available, the BVRLA will provide both parties with its findings and recommendations. The BVRLA aims to resolve complaints through the Dispute Resolution Service within 30 days. Members must comply with the Dispute Resolution Service’s findings. What is covered under the Dispute Resolution Service? The Dispute Resolution Service will investigate potential breaches of this Code of Conduct, which sets out the standards the BVRLA expects from its members. The Dispute Resolution can only look at matters that relate to disputes arising from the activities of BVRLA members. Refunds Where the Dispute Resolution Service finds in favour of the customer we will look to ensure that any unjustified charges incorrectly raised by the member are credited in full. The service cannot adjudicate on the quantum of the amount charged, only on whether the charge was correctly raised. Compensation The Dispute Resolution Service does not have any jurisdiction to award compensation payments. Sterling Vehicles Ltd No restriction of rights BVRLA members must comply with the rulings of the Dispute Resolution Service. Use of the Dispute Resolution Service does not restrict the rights of a complainant to pursue remedies through the courts. Monitoring and compliance The BVRLA’s continual monitoring and internal procedures are aimed at ensuring that members meet their obligation to comply with this Code of Conduct.