Buckingham Leasing Limited

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1 Purpose

This policy and procedures detail how Buckingham Leasing Limited (the Firm) will deal with complaints.
Buckingham Leasing Limited is authorised by the Financial Conduct Authority (FCA) and, as such, will act in
accordance with the Complaints rules as defined in the FCA Handbook, which will take precedence over the
requirements of this policy and procedures.

2 Review of Policy and Procedures

This policy and procedures will be reviewed regularly, at least once a year, and amended as considered
necessary by our firm’s Management Body in the event of changing circumstances or regulations.

3 Responsibilities

3.1 Management Body Responsibilities

Our firm’s Management Body comprises of 3 Directors and Senior Managers and are responsible for the
implementation of the Complaints Policy and for monitoring compliance with it.

The Management Body have appointed a Complaints Manager, Lesley Bridges. If the Complaints
Manager is unavailable, this may be carried out by a Nominated Officer.

3.2 Complaints Manager Responsibilities

The Complaints Manager is responsible for the investigation of complaints.

3.3 Employee Responsibilities

All employees are expected to refer any verbal or written complaints to the Complaints Manager at the earliest
opportunity and to cooperate fully with the Complaints Manager in its investigations. Employees undertake
initial training and training on an annual basis to ensure their knowledge is up to date.

4 Definitions

4.1 Definition of a complaint

The FCA defines a complaint as any oral or written expression of dissatisfaction from or on behalf of a client,
whether justified or not, which includes an actual or potential financial loss, material distress or material
inconvenience.

The Financial Conduct Authority complaints rules apply to complaints:

• Made by, or on behalf of an eligible complainant
• Relating to regulated activity
• Involving an allegation that the complainant has suffered, or may suffer, financial loss, material distress or
  material inconvenience

4.2 Definition of eligible complainant

An eligible complainant is a complainant that is:

• A consumer (a person acting outside their trade, business or profession)
• A micro enterprise (enterprise which employs fewer than 10 people and has a turnover or balance sheets that
  does not exceed EUR 2,000,000)
• A charity with an annual income of less than £6,500,000
• A trustee of a trust which has a net asset value of less than £5,000,000
• A buy to let consumer
• A small business (enterprise which has an annual turnover of less than £6.5 million and employs fewer than
  50 people or has a balance sheet total of less than £5 million)
• A guarantor

Complainants that are professional clients or eligible counterparties that are acting outside of their trade or
professions in relation to the activity to which the complaint relates are consumers and, as such, eligible
complainants.

If in doubt whether a complainant is an eligible complainant or not, we will treat them as an eligible
complainant. Only eligible complainants can refer their complaints on to the Financial Ombudsman Service.

5 Policy

It is our policy to treat all complainants the same, however, eligible complainants are legally defined and have
additional rights in law that we must acknowledge and adhere to. We have elected to treat all complaints in the
same way for simplicity. Occasionally we may not know if a complainant is ‘eligible’ in which case it will treat
them as such and if it becomes necessary, the Financial Ombudsman Service will establish the status of the
complainant, not Buckingham Leasing Limited.

Buckingham Leasing Limited’s clients and potential clients can submit complaints free of charge.

Complaints will be handled promptly, effectively and in an independent manner, obtaining additional
information as necessary.

We will always communicate with clients and potential clients clearly in plain language that is easy to
understand and will reply to the complaint without undue delay.

We will assess fairly, consistently and promptly:

• The subject matter of the complaint
• Whether the complaint should be upheld
• What remedial action or redress may be appropriate
• Whether another party may be solely or jointly responsible for the matter alleged in the complaint

We will promptly comply with any offer or remedial activity or redress accepted by the complainant.

We will consider a complaint closed when it has issued a final response.

Buckingham Leasing Limited will provide information about the Financial Ombudsman Service to eligible
complainants on our website and if applicable, in the general conditions of our contracts with eligible
complainants in a clear, comprehensible and easily accessible way.

5.1 Consumer Awareness

Buckingham Leasing Limited has published Complaints Procedures on our website
www.buckinghamleasing.co.uk
that includes contact details of our Complaints Manager. The procedures are made available to clients and
potential clients on request and when we are acknowledging a complaint. The procedures contain information
about the Financial Ombudsman Service.

5.2 Timings

Buckingham Leasing Limited has a maximum of 8 weeks to issue a final response to the complainant and we
require that this practice is followed (as a maximum timescale) for all complaints.

5.2.1 Complaints resolved by close of the third business day

If we satisfactorily resolve the complaint by close of business on the third business day following the
receipt of the complaint then we will issue a written “Summary Resolution Communication” to the
complainant, advising that we consider the complaint as resolved and inform the complainant, for eligible
complainants, about their options for referring the complaint back to us or for onward referral to the
Financial Ombudsman Service if they are dissatisfied.

In addition to sending a complainant a “Summary Resolution Communication”, we may also use other methods to communicate the information where:

• We consider that doing so may better meet the complainant’s needs; or
• The complainant and Buckingham Leasing Limited have already been using another method to communicate about the complaint.

5.2.2 Complaints not settled within 3 business days

On receipt of a complaint, we will send the complainant a written acknowledgement providing
confirmation that we have received the complaint and are dealing with it.

We will ensure that the complainant is kept informed of the progress of the measures being taken for
resolution of the complaint and will write to complainants after four weeks if we have not reached a
decision.

We will issue a final response to the complainant within 8 weeks and inform the complainant, for eligible
complainants, about their options for onward referral to the Financial Ombudsman Service.

The final response will clearly set out:

• Whether Buckingham Leasing Limited accepts or rejects the complaint
• The reasons for rejection, where applicable
• The intention to offer redress or remedial action, where applicable
• Details of the redress to be offered and any compensation offered with a clear method of calculation.

Additionally, where the client is an eligible complainant, we will:

• Explain that where the complainant disagrees with our decision, they must refer the matter to the
  Financial Ombudsman Service within six months of the date of this letter or the right to use this
  service is lost, and
• Enclose contact details for the Financial Ombudsman Service, including website details.

We will consider a complaint closed when we have issued our final response.

5.3 Complaints forwarding

Buckingham Leasing Limited will promptly forward the complaint in writing to another party if we have
reasonable grounds to believe that the other party may be solely or jointly responsible for the matter alleged
in the complaint.

If a complaint is forwarded, Buckingham Leasing Limited will inform the complainant promptly in a final
response of why the complaint has been forwarded to another party and provide the complainant with the other
party’s contact details.

If Buckingham Leasing Limited receives a forwarded complaint, the complaint will be treated as if we have
received the complaint directly and the same time limits will apply from the date on which we received the
forwarded complaint.

5.4 Complaints time barring

If Buckingham Leasing Limited receives a complaint which is outside the time limits for referral to the
Financial Ombudsman Service, we may reject the complaint without considering the merits but will explain
this to the complainant in our final response.

Unless Buckingham Leasing Limited consents, the Financial Ombudsman Service will not consider a complaint
if the complainant refers it to the Financial Ombudsman Service:

• More than six months after the respondent sent the complainant its final response
• More than six years after the event complained of
• More than three years from the date on which the complainant became aware that they had cause for complaint

5.5 Financial Ombudsman Service

Buckingham Leasing Limited will co-operate fully with the Financial Ombudsman Service in resolving any
complaints made against us and agrees to be bound by any awards made by the Ombudsman. Buckingham Leasing
Limited undertakes to pay promptly the fees levied by the Financial Ombudsman Service.

5.6 Analysis

Buckingham Leasing Limited will conduct root cause analysis of any complaint received and record any
appropriate actions taken. Complaints will be analysed on a Monthly basis for any reoccurring patterns and
all lessons learnt will be incorporated into future training and development. The causes of complaints will be
recorded in our Management Information and will be used with the prioritisation of dealing with the root
causes.

6 The procedure

Refer any complaint verbal or written to the Complaints Manager at the earliest opportunity.

The Complaints Manager will then,

1. Make an initial assessment of the complaint, contacting the complainant for further information if required.
   This can be done via telephone, email or any other appropriate means of communication.
2. If there is sufficient information and the complaint can be resolved within 3 business days, then proceed to step 9.
3. If the complaint cannot be resolved within 3 business days, send out an initial response letter to the
   complainant using the Initial Response Letter Template, adding the details known about the
   complaint by the next working day, stating that the complaint has been received and is being dealt with.
4. Investigate the complaint impartially obtaining additional information from our records/staff and/or the complainant as necessary.
5. Enter the complaint onto the Complaints Log and create a Complaint Record.
6. Assess fairly, consistently and promptly:
   
   1. The subject matter of the complaint
   2. Whether the complaint should be upheld
   3. What remedial action or redress (or both) may be appropriate
   4. If appropriate, whether it has reasonable grounds to be satisfied that another party/respondent may be solely or jointly responsible for the matter alleged in the complaint.
7. If appropriate, forward the complaint to the relevant party/respondent and advise the complainant in writing why the complaint has been forwarded to the other party and provide the other party’s contact details.
8. If the complaint is unresolved after four weeks, send out a holding letter using the Holding letter template, advising an expected resolution date.
9. If the complaint is resolved, communicate our firm’s position on the complaint to the complainant and
   inform them about their options, including that they may be able to refer the complaint to an alternative
   dispute resolution entity (Financial Ombudsman Service for eligible complainants) or that the complainant
   may be able to take civil action, using the Final Response Letter template. If the complaint was resolved
   within 3 days, use the Summary Resolution Communication instead.
10. In the final response letter, clearly set out whether Buckingham Leasing Limited accepts or rejects the
    complaint, the reasons for rejecting any complaint or where we accept the complaint, and intend to offer
    redress or remedial action, details of the redress to be offered, any compensation offered and a clear
    method of calculation.
11. In the final response letter to eligible complainants, enclose a copy of the Financial Ombudsman
    Service’s contact details, which includes the website address of the Financial Ombudsman Service and inform
    the complainant that if they are still dissatisfied with our response, the complaint may now be referred to
    the Financial Ombudsman Service.
12. Comply promptly with any offer of remedial action or redress accepted by the complainant.
13. Conduct a root cause analysis in the case of any complaint and record with the appropriate action having been taken. Record any actions within the individual complaint record.
14. Liaise with senior management if any changes need to be made to our firm’s procedures based on the analysis.
15. Update the Complaints Log and Complaints Record with the final decision including details of the amount of any redress offered.

7 Record keeping

Buckingham Leasing Limited will keep a record of each complaint received and the measures taken for its
resolution, including any redress offered, and retain that record for three years from the date the complaint
was received.

8 Complaints reporting

Through our firm’s REGDATA reports, we will provide the FCA with a complete report concerning complaints
from eligible complainants. Complaints that have been forwarded in their entirety to another party will not be
included in the report.

9 Breaches of the Complaints Policy and Procedure

Any breaches of the Complaints Policy and Procedures will be recorded on our breach log in conjunction with
our Regulatory Breach policy.

10 Annex

Financial Ombudsman Service

Address: The Financial Ombudsman Service, Exchange Tower, London E14 9SR
Tel: 0800 023 4567 (free for most people ringing from a fixed line) or 0300 123 9123 (cheaper for those calling using a mobile) or 44 20 7964 0500 (if calling from abroad)
Email: co************@*********************rg.uk
Website: www.financial-ombudsman.org.uk