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Background

Complaints Handling Policy

1. Purpose

GoReg Ltd ("the Firm") is committed to handling complaints fairly, promptly and transparently, in line with the FCA's Dispute Resolution rules (DISP) and the Consumer Duty (PRIN 2A). This policy sets out how the Firm receives, investigates, resolves and learns from complaints to ensure good customer outcomes.

2. Scope

This policy applies to:

  • All complaints from customers or eligible complainants
  • All Directors and staff of the Firm
  • All activities of the Firm, including:
    • Retail sale and brokerage of vehicle registration numbers
    • Regulated credit broking activities with third-party lenders (e.g. Klarna)

3. Definition of a Complaint

A complaint is any oral or written expression of dissatisfaction, whether justified or not, from or on behalf of a customer, about:

  • The provision of, or failure to provide, a service
  • The firm's conduct, actions or omissions

This includes complaints relating to regulated and unregulated activities.

4. Consumer Duty (PRIN 2A)

In handling complaints, the Firm will act to:

  • Deliver good outcomes for customers
  • Act in good faith
  • Avoid causing foreseeable harm
  • Enable and support customers to pursue their interests

Complaints data will be used to identify and remedy any risks to good customer outcomes.

5. How Customers Can Make a Complaint

Customers may submit a complaint via:

  • Email
  • Written correspondence
  • Telephone
  • Any other reasonable communication channel used by the Firm

Complaints can be made by the customer or an authorised representative.

6. Complaints Handling Process

a) Acknowledgement

  • Complaints will be acknowledged promptly, and in any event within 5 business days, unless resolved sooner.

b) Investigation

  • Complaints will be investigated competently, diligently and impartially.
  • The Firm will consider all relevant evidence and circumstances.
  • Where the complaint relates to a third-party lender, the Firm will cooperate appropriately while retaining responsibility for its own actions.

c) Resolution

  • The Firm aims to resolve complaints as quickly as possible.
  • Where a complaint cannot be resolved promptly, the Firm will provide a final response within 8 weeks, in accordance with DISP.

d) Final Response

The final response will:

  • Clearly explain the outcome
  • State whether the complaint is upheld or rejected
  • Set out any redress or remedial action offered (if applicable)
  • Inform the customer of their right to refer the complaint to the Financial Ombudsman Service (FOS), where eligible

7. Financial Ombudsman Service

If a customer remains dissatisfied, they may refer the complaint to the Financial Ombudsman Service within the applicable time limits.

The Firm will include FOS details in the final response where required under DISP.

8. Vulnerable Customers

Where a complaint involves a vulnerable customer, the Firm will:

  • Handle the complaint with additional care and sensitivity
  • Make reasonable adjustments where appropriate
  • Ensure the customer is not disadvantaged by their circumstances

This policy should be read alongside the Firm's Vulnerable Customer Policy.

9. Record Keeping and Reporting

The Firm will:

  • Maintain records of all complaints in line with DISP requirements
  • Retain complaints records for a minimum of three years
  • Monitor complaints data to identify trends, root causes and areas for improvement
  • Use complaints insights to improve systems, controls and customer outcomes

10. Roles and Responsibilities

  • Overall responsibility for complaints handling rests with the Directors of the Firm
  • Complaints handling may be delegated operationally but accountability remains with senior management
  • Escalation procedures are in place where required

11. Staff Training

Relevant staff receive training on:

  • Identifying and handling complaints
  • DISP requirements
  • Consumer Duty expectations
  • Treating customers fairly and empathetically

Training is reviewed periodically to ensure ongoing effectiveness.

12. Governance and Review

This policy:

  • Is reviewed at least annually
  • Is updated where regulatory requirements or the Firm's business model change
  • Forms part of the Firm's wider governance and Consumer Duty framework