1. Introduction
Customer satisfaction is an integral part of the Eunifin (Pty) Ltd t/a Republik (”Republik”) client-centred philosophy, governance framework and Treating Customers Fairly (TCF) culture. Republik regards complaints as critical feedback mechanisms that provide valuable insights into customer experience, operational risk exposure, system weaknesses, regulatory compliance gaps, and opportunities for service enhancement.
This policy is designed to ensure:
● Fair and timely resolution of customer complaints
● Compliance with FAIS regulatory requirements
● Alignment with the General Code of Conduct
● Protection of customers’ rights
● Continuous improvement of Republik’s fintech banking, wallet and lending services Protection of Republik’s reputation and regulatory standing Republik is a licensed credit provider regulated under the National Credit Act.
Republik operates under Sava Technologies Pty Ltd (2022/301994/07) - an authorised Financial Services Provider (FSP 53169) and a distribution partner of Access Bank South Africa Limited (Reg. No. : 1947/025414/06), an authorised Financial Services Provider (FSP 5865). Sava is not a bank. Thus Republik operates under an authorised licensed partner arrangement and is not itself an authorised Financial Services Provider. We embrace the spirit of the principle-based outcomes as published by the FSCA and commit to continuous compliance.
Republik is committed to treating customers fairly and resolving complaints promptly and transparently. Complaints are considered a key component of Republik’s enterprise risk management and compliance governance framework.
2. Key Definitions
Complaint: An expression of dissatisfaction regarding Republik’s products, wallet functionality, lending services, digital platforms, staff conduct or regulatory compliance, which alleges:
● Non-compliance with agreements, laws or codes of conduct
● Financial prejudice, inconvenience or unfair treatment
● Maladministration, negligence or system failure
● Incorrect lending decisions or wallet transaction issues
● Compensation Payment: Payment to a complainant where Republik accepts liability for financial loss.
● Goodwill Payment: Payment made to resolve a complaint where Republik does not admit liability but seeks an amicable resolution.
● Reportable Complaint: Any complaint not resolved within 5 business days through normal service channels.
3. Complaints Process
3.1 Submission Channels
Clients may submit complaints through:
● Email: complaints@republik.africa
Acknowledging receipt of the complaint to the customer and outlining the expected process and next steps, including indicative timelines for investigation and resolution. Republik ensures that information about the complaints process is made available via client communications, onboarding materials and digital platforms.
Complaints may relate to:
● Wallet transactions
● Lending approvals or declines
● Repayment calculations
● Fees or charges
● System outages
● Staff conduct
● Regulatory compliance concerns
3.2 Handling Process
Step 1: Receipt & Acknowledgement (2 business days)
● All complaints must be logged in the Complaints Register with a unique reference number. The complainant shall receive written acknowledgement via email including: Reference number
● Contact details of handler
● Overview of next steps
● Expected resolution timeline
Step 2: Assessment & Assignment (2 business days)
● Severity
● Complexity
● Regulatory impact
● Financial risk exposure
● Potential systemic implications
● The complaint shall be assigned to an appropriate handler. Immediate action must be taken where urgent risk exists (e.g., wallet freeze error, incorrect debit).
● The handler must determine whether the complaint qualifies as a reportable complaint for regulatory purposes.
Step 3: Investigation (7–14 business days)
● The complaint handler shall:
○ Gather all relevant documentation
○ Review wallet transaction logs
○ Assess lending and affordability records
○ Interview relevant staff
○ Evaluate contractual compliance
○ Conduct root cause analysis
○ Investigations must be objective, impartial and documented thoroughly.
Step 4: Resolution & Response (within 15 business days total)
● Following investigation, the handler shall determine appropriate resolution and obtain required approvals.
● The written response must include:
○ Clear explanation of findings
○ Basis for decision
○ Corrective actions taken
○ Details of compensation (if applicable)
○ Escalation rights
○ All resolution details must be recorded in the complaints register.
Step 5: Follow-up & Closure
● The handler must:
○ Confirm complainant acceptance
○ Implement agreed actions
○ Update register
○ Document systemic implications
Step 6: Analysis & Learning
● The Compliance Officer shall:
○ Conduct regular complaint analysis
○ Identify systemic risks
○ Recommend fintech system improvements
○ Share learnings across departments
○ Ensure integration into risk management framework
3.3 Timelines
Acknowledgement: Within 2 business days
Simple complaints: Resolution within 5 business days
Complex complaints: Resolution within 15 business days
Extension: Complainant updated weekly if additional time required
3.4 Escalation Path
If unresolved or complainant dissatisfied:
● Internal
○ Escalation to Compliance Officer
○ Final review by Chief Executive Officer
● External
○ FAIS Ombud – complaints@faisombud.co.za / 012 762 5000
○ Financial Sector Conduct Authority (FSCA)
○ Financial Services Tribunal
3.4 Types of Complaints
Complaints are generally categorized by their complexity and the time required for resolution.
Simple Complaints:
Simple complaints are typically straightforward issues that can be resolved quickly (often within a few days or weeks) through direct communication, correction of administrative errors, or straightforward explanation of policy terms.
Examples of Simple Complaints:
● Administrative Errors: Failure to update contact details, incorrect debit order dates, or failure to issue policy documentation.
● Minor Miscommunication: Misunderstanding a straightforward, non-material aspect of a policy.
● Simple Service Failure: Delayed responses to inquiries or poor service conduct .
●Simple Misrepresentation (Obvious Errors): A complaint that a debit was made without consent when the agent clearly misread a, "No" as a, "Yes" (where evidence is easy to verify).
Complex Complaints:
Complex complaints involve intricate facts, high financial value, multiple parties, or significant legal/compliance disputes. These often require formal adjudication, expert input, and longer resolution times, sometimes involving the FAIS Ombud.
Examples of Complex Complaints:
● Inappropriate Advice (Mis-selling): Recommending high-risk investment products (e.g., Sharemax, Fidentia) to conservative investors (like pensioners) unsuitable for their risk appetite.
● Non-Disclosure of Material Information: Failure to disclose significant investment risks, fees, or early withdrawal penalties (e.g., 7% penalty) that directly result in loss.
● Breach of Fiduciary Duty/Negligence: Claims where the FSP failed to act timeously on instructions, leading to significant financial loss (e.g., failed to invest funds immediately).
● Complex Misrepresentation: Cases involving mass-sold products where agents are accused of fabricating signatures or misrepresenting the nature of a product to numerous clients.
● Large Financial Loss Disputes: Complaints involving high-value investments (up to the FAIS Ombud jurisdictional limit, often up to R3.5 million) requiring in-depth investigation into whether the advice was appropriate.
● Failure to Act on Risk Factors: Not advising a client to install a tracking device as required by the policy, leading to a rejected claim.
Key Distinctions:
● Simple complaints are usually solved by correcting an error (remediation).
● Complex complaints usually involve a dispute over whether the advice was appropriate at the time it was given.
4. Roles & Responsibilities
4.1 All Staff
All staff must:
● Identify complaints
● Escalate immediately
● Cooperate fully
● Implement improvements
4.2 Complaints Officer (Compliance Officer – Chesznokov Zungu) Responsible for:
● Daily management
● Logging and tracking
● Regulatory reporting
● Trend analysis
● FAIS compliance oversight
● Supervising complaint handling
● Providing regulatory guidance
● Conducting quality assurance reviews
● Ensuring policy adherence
● Ensuring adequate complaints systems exist
● Reviewing quarterly reports
● Overseeing implementation of systemic improvements
4.3 Senior Management Responsible for:
● Reviewing monthly reports
● Addressing systemic issues
● Allocating adequate resources
● Promoting positive complaints culture
4.4 Chief Executive Officer – Takura Malaba Holds ultimate accountability for:
● Governance oversight
● Approval of high-risk decisions
● Regulatory submissions
● Integration of complaint risks into enterprise risk management
5. Performance Monitoring
5.1 Key Performance Indicators
● % acknowledged within 2 days
● % resolved within timeline standards
● % escalated externally
● % upheld/partially upheld
● Complaint volumes by category
● Average resolution time
5.2 Reporting
● Weekly: Operational report
● Monthly: Management review
● Quarterly: Compliance review
● Annual: TCF governance review
6. Core Principles
6.1 Transparency
● Clear communication of processes, timelines and outcomes.
6.2 Impartiality
● Objective assessment based on evidence.
6.3 Confidentiality
● Handled in accordance with POPIA.
6.4 Customer-Centric Approach
● Empathy, diligence, analytical thinking, fairness.
6.5 Awareness
● Clients informed of right to complain and escalation rights.
7. Systemic Issues & Preventative Actions
7.1 Root Cause Analysis
● Mandatory for each complaint.
7.2 Trend Analysis
● Monthly review of recurring issues and system weaknesses.
7.3 Improvement Implementation
● Clear accountability and monitoring of corrective actions.
8. Training
8.1 Staff Training Requirements
● All sales and customer-facing staff must receive complaint identification and escalation training. Complaint handlers require comprehensive training on FAIS obligations and communication techniques.
● Refresher training conducted annually.
8.2 Training Records
● Maintained in the HR training register for audit purposes.
9. Record Keeping
The following must be recorded:
● Complainant details
● Complaint description
● Date received
● Responsible staff member
● Supporting documentation
● Investigation notes
● Resolution details
● Compensation/goodwill payment
● Root cause analysis
● Systemic issue identification
● Records retained minimum 5 years.
