Complaints Handling Policy

00Version history

01Purpose

This Complaints Handling Policy sets out how Kintro Ltd ("Kintro") receives, investigates, resolves and learns from complaints in line with the FCA Dispute Resolution: Complaints sourcebook (DISP), the Payment Services Regulations 2017 (PSR 2017) and the FCA Consumer Duty (PRIN 2A). It defines the operating model, the time limits, the routing to the Financial Ombudsman Service (FOS), and the management information that flows to the Board and the Principal.

During the alpha phase Kintro operates as an agent of an FCA-authorised payment institution / electronic money institution ("the Principal"). Complaints about regulated payment and e-money services fall within the Principal's complaints scheme. Kintro is the first line of complaint receipt, investigation and resolution under that scheme, with formal routing to the Principal for matters that the Principal must record, report or settle as the regulated firm.

02Scope

This Policy applies to:

• All Kintro business activities and customer-facing channels, including the Kintro app, the website, in-app chat, email, telephone, social media and any partner-facing surfaces.
• All employees, directors, officers, contractors and any other person handling a complaint on Kintro's behalf.
• All complaints — whether from eligible complainants in the meaning of DISP or from any other person — and irrespective of channel, language or whether the complaint is made in writing or orally.

The Policy applies from the moment an expression of dissatisfaction is received through to closure of the file, plus the record retention period in Section 19.

03Regulatory and Standards Anchors

04Policy Statements

Kintro will:

• Make it easy for customers to complain, in plain English, free of charge, through any of the channels listed in Section 8.
• Acknowledge every complaint promptly and resolve it as quickly as fairness allows, within the statutory and supervisory time limits.
• Investigate every complaint competently, diligently and impartially, with appropriate authority and independence from the operations that gave rise to it.
• Treat all complainants fairly and consistently, with reasonable adjustments for customers who need them.
• Offer redress where appropriate, including refunds, fee waivers, interest, distress and inconvenience awards, and apologies.
• Tell every eligible complainant about their right to refer the matter to the Financial Ombudsman Service (FOS) inside the final response or summary resolution communication.
• Co-operate with the FOS in full and respond within FOS timescales.
• Conduct root-cause analysis on every closed complaint and feed the findings into product, operations, training and policy.
• Report complaints data internally to the Board monthly and externally as required by DISP 1.10 (via the Principal during alpha).
• Train all customer-facing staff on this Policy on induction and at least annually thereafter.
• Review this Policy at least annually and on any material change.

05Definitions

06Roles and Responsibilities

6.1 Board of Directors

• Owns this Policy, approves it at least annually and receives the monthly Complaints MI pack.
• Considers and approves the response to any material complaints theme that crosses a threshold defined in Section 17.

6.2 Chief Executive Officer

• Accountable for complaints handling at firm level; sponsors the framework and ensures resourcing.

6.3 Complaints Lead (interim: CTO)

• Operational owner of this Policy and the complaints case-management tooling.
• Approves final responses where the proposed redress exceeds the discretionary threshold in Appendix C, or where the complaint engages financial-crime, safeguarding, data-protection or systemic-risk considerations.
• Owns the reportable-complaint determination under DISP 1.10 and signs off the half-yearly return submitted via the Principal.
• Owns root-cause analysis and the remediation tracker.
• Single point of contact for the FOS and the Principal's complaints function.

6.4 Customer Operations team

• First-line handling of every incoming complaint — receipt, identification, acknowledgement, investigation and proposed resolution.
• Maintains the complaints register inside the case-management tool.

6.5 Money Laundering Reporting Officer (MLRO)

• Reviews any complaint that surfaces a possible suspicion of money laundering, terrorist financing, sanctions breach or fraud, and decides whether an Internal Suspicion Report is required under KIN-FCC-001.
• Ensures complaints language does not amount to tipping off (POCA s.333A).

6.6 Data Protection Lead

• Handles complaints that allege a breach of UK GDPR or DPA 2018 and signposts the complainant to the Information Commissioner's Office.

6.7 Principal Coordination Lead

• Routes complaints to the Principal where they fall within the Principal's scheme (regulated payment and e-money matters) and coordinates the joint position on customer-facing comms.

6.8 All employees and contractors

• Recognise an expression of dissatisfaction as a complaint and route it to Customer Operations the same business day.
• Never seek to dissuade a customer from making a complaint or referring it to the FOS.

07How Customers Can Complain

Kintro accepts complaints through any reasonable channel. The default routes are:

• In the app, via Help → Make a Complaint.
• By email to complaints@kintro.money.
• By telephone on the number printed in the app.
• In writing to the Kintro postal address listed on kintro.money/legal.
• Through social-media direct message to Kintro's verified accounts.
• Through a regulated third party — e.g. the FOS, a Claims Management Company, or the Principal — acting for the customer.

All routes are free of charge. Customers do not need to label their message a "complaint" for it to be treated as one — any expression of dissatisfaction is enough.

Reasonable adjustments under the Equality Act 2010 and the Consumer Duty include:

• Accessibility features in the app (screen-reader support, larger text).
• Communication in a customer's preferred channel where reasonable, including telephone for customers who cannot use the app.
• Plain-English language; explanations of any technical or legal terms.
• Permission for a friend, family member or other supporter to act on the customer's behalf with their written authority.

08Complaints Handling Process

8.1 Identification and recording

• Customer Operations checks each contact for indicators of dissatisfaction; if any are present, the contact is logged as a complaint in the case-management tool.
• Each complaint receives a unique reference and is categorised against the taxonomy in Appendix E.
• The complainant's eligibility under DISP 2.7 is assessed at logging.

8.2 Acknowledgement

• Kintro acknowledges every complaint promptly — by default, within 1 business day and in any event by the next business day after receipt.
• The acknowledgement tells the complainant the reference number, the assigned case handler, the channel for updates, the expected timescale and how to escalate.

8.3 Investigation

• The case handler gathers facts, timelines, account history and any third-party evidence (e.g. AISP / PISP logs, payment scheme messages, the Principal's records) and develops a view on the merits.
• Where the matter requires specialist input — financial crime, data protection, engineering — it is escalated to the relevant function with a clear ask and SLA.
• Investigators must not contact the customer in ways that risk tipping off if a financial-crime suspicion is present.

8.4 Resolution and redress

• Where Kintro upholds the complaint, redress restores the customer to the position they would have been in but for the issue. Redress can include refunds of fees or charges, refunds of unauthorised payments under PSR 2017 reg. 76, interest, distress and inconvenience awards, and a written apology.
• Where Kintro does not uphold the complaint, the case handler explains why in plain English and addresses each point the complainant raised.
• All redress and rejection decisions follow the discretionary thresholds in Appendix C.

8.5 Final response or summary resolution

• A Summary Resolution Communication is issued for complaints resolved by close of business on the third business day after receipt and where the complainant is satisfied with the resolution. The communication tells the complainant they remain entitled to refer the matter to the FOS within six months if their view changes — DISP 1.5.4R.
• In every other case, a Final Response is issued at the conclusion of the investigation, using the template at Appendix B. It addresses the complaint in full, sets out Kintro's position and any redress offered, and includes the prescribed FOS signposting and timescales.

09Time Limits and SLAs

Two regulatory regimes apply depending on whether the complaint relates to a payment-services matter under PSR 2017 reg. 101, or any other matter under DISP 1.6.

Kintro tracks SLA performance daily. Cases approaching either time limit are escalated to the Complaints Lead 5 business days before the limit, and again 2 business days before, with a recovery plan.

10Categorising and Routing

At logging, every complaint is categorised against the taxonomy in Appendix E and routed as set out below.

11Financial Ombudsman Service Signposting

Every Final Response and every Summary Resolution Communication issued to an eligible complainant tells the complainant about their right to refer the matter to the Financial Ombudsman Service and the 6-month deadline. The signposting includes:

• A copy or a clear link to the FOS consumer leaflet.
• The FOS website (financial-ombudsman.org.uk), telephone (0800 023 4567) and postal address.
• Confirmation that referring to the FOS is free for the complainant.
• A statement that the complainant has six months from the date of the final response to refer the matter to the FOS, and that Kintro will rely on this time limit.

Where the complaint is brought by a person who is not eligible under DISP 2.7 (for example a larger business), the response makes clear that FOS does not apply but Kintro will still consider the complaint fairly.

12Consumer Duty and Vulnerable Customers

The FCA Consumer Duty (PRIN 2A) requires Kintro to deliver good outcomes for retail customers, including those in vulnerable circumstances. Within complaints, this means:

• Spotting potential vulnerability through case handlers — for example bereavement, ill-health, financial difficulty, recent shock or low confidence with financial matters.
• Adapting communication and pace — for example more time to respond, written summaries after telephone conversations, larger text, or speaking to a nominated supporter.
• Looking at the round when assessing redress — including distress and inconvenience awards that reflect the actual impact rather than a blanket figure.
• Recording and reviewing the support given so themes feed the wider Consumer Duty assessment.

13Tipping Off and Financial-Crime Overlay

Where a complaint relates to an account freeze, payment decline or closure that has been driven by financial-crime monitoring, the MLRO joins the case at logging. The response to the complainant must not, directly or indirectly, disclose that a SAR has been filed or is being considered (POCA s.333A), nor prejudice an investigation (POCA s.342). The Complaints Lead and the MLRO agree the language used.

14Redress Framework

Redress is fact-specific. The discretionary thresholds in Appendix C are the maximum amounts that can be settled without escalation. They are not a tariff — case handlers must consider the actual impact on the customer. Indicative principles:

• Restore the customer to the position they would have been in but for the issue.
• Refund fees or charges that were applied incorrectly.
• Pay simple interest at the FOS 8% rate where the customer was deprived of funds for a period.
• Make a distress-and-inconvenience award where the customer suffered material upset, calibrated against the FOS published banding.
• Offer an apology where appropriate; an apology is not an admission of liability beyond the matter complained of.
• Where the complaint touches a payment-services matter under PSR 2017, ensure refunds and interest comply with the statutory regime (regs. 76, 91 and 92).

15Working with the Financial Ombudsman Service

• Kintro acknowledges every FOS notification within 5 business days and provides the file and any other information requested within the FOS timescale, which is typically 14 calendar days.
• Kintro does not seek to settle a FOS case in a way that limits the customer's rights below the FOS award.
• FOS decisions that Kintro accepts are implemented within 28 days of acceptance. Decisions that Kintro intends to contest are escalated to the Complaints Lead and the Board.
• FOS case fees are paid by Kintro (or recharged to the Principal where the complaint falls within the Principal's regulated activity, under the principal-agent agreement).

16Root Cause Analysis and Prevention

Every closed complaint is tagged with a root-cause code. Each month the Complaints Lead reviews:

• Top root causes by volume and by impact.
• Themes by product, channel and customer segment.
• FOS uphold rate (once Kintro has FOS-decided cases).
• Repeat complaints from the same customer or about the same issue.

Material themes drive remediation actions tracked in the Complaints Remediation Tracker — owned by the relevant function (Product, Engineering, Operations, Marketing) with a target date and an owner.

17Management Information and Reporting

Reporting cadence:

• Monthly Complaints MI to the Board covering volumes by category, SLA performance, redress paid, FOS activity, top root causes and remediation status.
• Real-time escalation to the CEO and the Board for any complaint involving alleged regulatory breach, customer detriment above the threshold in Appendix C, mass-customer harm, or material reputational risk.
• Half-yearly DISP 1.10 complaints return — submitted via the Principal during alpha. Kintro's data feeds the Principal's consolidated return; data quality is signed off by the Complaints Lead.
• Annual DISP 1.10A publication if and when Kintro hits the publication threshold (currently 500 reportable complaints, or 500 PSR-services complaints in a relevant period).
• Ad-hoc reporting to the FCA where the complaints picture indicates a risk in scope of SUP 15.3 or PSR 2017 reg. 99 — routed via the Principal.

18Quality Assurance

The Complaints Lead operates a monthly QA programme:

• A risk-stratified sample of closed complaints is reviewed against this Policy and the Consumer Duty outcomes.
• Findings are scored against a published rubric, fed back to case handlers, and used as training cases (anonymised) where appropriate.
• Sample size is at minimum 10% of monthly volume, with a higher rate for high-value or high-risk categories.
• QA outcomes are included in the monthly Board MI.

19Record Keeping

Complaints records are retained for at least 5 years from the date the complaint is closed (DISP 1.9.1R), and longer where another rule applies — for example PSR 2017 transaction records (6 years) or MLR 2017 (5 years from end of relationship). Records include:

• The complaint, the investigation, the redress decision and the final response.
• Any communications with the complainant, the FOS, the Principal or any third party.
• The categorisation, root-cause code and remediation linkages.
• Internal approvals and any reliance on discretionary thresholds.

Records are stored encrypted at rest under Google Cloud KMS, access-controlled and audit-logged in line with KIN-SEC-001.

20Training and Awareness

• All customer-facing staff complete complaints-handling training on induction before being granted access to live customer channels.
• Annual refresher training covers DISP, PSR 2017 reg. 101, the Consumer Duty, vulnerable customers, tipping-off precautions and the FOS signposting language.
• Engineering and Product receive condensed sessions to recognise root-cause patterns and prioritise remediation.
• Training completion is tracked and reported quarterly to the Board; non-completion blocks performance-review sign-off.

21Policy Review and Change Control

This Policy is reviewed at least annually and on any material change to the business, the Principal arrangement, applicable law or supervisory guidance. Changes follow the document control rules in Appendix F.

22Enforcement

Any breach of this Policy by an employee or contractor will be dealt with under the Disciplinary Procedure and may amount to gross misconduct. Breaches by suppliers or partners are dealt with under the relevant contract and may result in suspension or termination.