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Public Complaints Management Policy
Disclaimer
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This document has been prepared for the exclusive use and benefit of Stable Connect Limited (AFSL 336964), our clients and our Authorised Representatives. It must not be used or relied on by any other person, without our prior written consent. Information is sourced from third parties and Stable Connect believes it to be reliable at the date of publication, although we cannot guarantee accuracy and reliability, nor do we accept responsibility for errors and omissions. The information, including opinions, estimates and forecasts contained herein are as of the date of publication and are subject to change without notice. Stable Connect is under no obligation to correct any inaccuracy or update the information. Before acting on anything contained in this document, you should speak to your Stable Connect representative and consider the appropriateness of the information or general advice having regard to your objectives, financial situation, or needs. If you act on anything contained in this document without seeking personal advice you do so at your own risk. To the maximum extent permitted by law, neither we, nor any of our representatives, will be liable for any loss, damage, liability, or claim whatsoever suffered or incurred by you or any other person arising directly or indirectly out of the use or reliance on this information, or any changes made to this document without our prior written consent.
1. Stable Connect Limited
Stable Connect Limited (AFSL 336964) is involved in providing financial services and products in the Thoroughbred Racing and Breeding industry.
Managed Investment Schemes
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a) Promotes and manages horse breeding syndicated (both Stallion and Broodmare)
b) Promotes and manages horse racing syndicates, together with Authorised Representatives (AR’s), under ASIC Corporations (Horse Schemes) Instrument 2016/790 (formerly Class Order 02/319).
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Financial Advice
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Stable Connect Limited provides General Advice only in relation to the financial products being financial interests in Thoroughbred horses.
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2. Purpose
The purpose of this policy is to provide information on how consumers can lodge a complaint with Stable Connect Limited, the options available to assist consumers who might need additional assistance to lodge a complaint and Stable Connect Limited’s steps for dealing with complaints including response timeframes.
3. How to lodge a complaint
Complaints can be lodged (either in writing, online, via email, by phone call or in person) directly with the Company’s Complaints Officer. The Complaints Officer is the Compliance Officer, however, in certain circumstances the Compliance Officer may appoint a delegate to manage or assist with a complaint.
Ashleigh Carpenter
Compliance Officer
P: +61 9629 3023
​E: acarpenter@stablefinancial.com.au
Mail or in person:
Level 10, IBM Building, 60 City Rd, Southbank VIC 3006
We request that you direct your complaint directly to the Complaints Officer via one of the above methods. Complaints raised via other means, such as social media, may not be seen by the Complaints Officer or recognised as a complaint.
What if I need assistance to lodge a complaint?
We recognise that not all people want to make a complaint and therefore it is important to us that you feel encouraged and supported to lodge a complaint.
A complaint may be lodged by yourself or by a representative on your behalf. Such representatives might include, but may not be limited to, financial counsellors, legal representatives, family and friends. Where a complaint is received via a representative , Stable Connect will not contact you directly unless you specifically request direct communication with us. Exceptions to this might include where we don’t believe the representative is acting in your best interests, or they are acting in a deceptive or misleading manner, or we believe they are not authorised to represent you.
Alternatively, contact the Complaints Officer and request assistance. We will endeavour to assist you to make the process as easy as possible.
4. Our complaints handling process
4.1 Complaint is received
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A complaint may be received by anyone within Stable Connect Limited or our AR’s and therefore AR’s and staff have received training to assist them in recognising a complaint and immediately directing it to the Complaints Officer. Complaints may be received verbally or in writing.
Verbal complaint - When a verbal complaint is received, either by phone, video link or in person, the person receiving the complaint is expected to make a comprehensive record of the complaint, including who is making the complaint and their contact details, the background information that has led to the complaint and any desired resolution from the complainant – including timeframes. This information is required to be passed through to the Complaints Officer for consideration and actioning.
Written complaint - Written complaints are also to be directed to the Complaints Officer immediately after receipt.
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The Complaints Officer or the person who received the complaint (e.g. the AR) may contact you if further clarification is required on any of the matters raised.
Complaints received are recorded by the Complaints Officer in a Complaints Register for record maintenance and further investigation purposes.
4.2 Acknowledgement of the complaint
Stable Connect will provide you with an acknowledgement within 24 business hours of receiving the complaint. The acknowledgement may be verbal or in writing and will inform you that a formal response will be provided within 10 business days.
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4.3 Assessment and investigation of the complaint
The Complaints Officer, or a delegate, will attempt to collect and analyse all information and background material relevant to the complaint and may make further enquiries of the complainant or the Stable Connect (AR) or staff to gain a better understanding of the complaint.
The Complaints Officer
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will analyse the information from the various sources and will generally form a view as to whether the complaint is reasonable and valid, and if so, what resolution may be appropriate.
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May also consider whether any breach of the AFS License, Codes of Ethics or law has occurred and recommend appropriate action to address this. This may include a formal breach notification, identifying whether other parties may be affected and determining if broader remediation steps are required.
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Where the complaint relates to concerns about independence or actual or perceived conflicts of interest the complaint the Complaints Officer may refer the matter to the Company’s Board of Directors along with proposed action.
4.4 Formal response
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Stable Connect will issue a formal response to you within 10 business days of the complaint being made. If we are unable to resolve the issue in the 30 da period we will disclose to you the reason for the delay.
The formal response will include the outcome of the complaint assessment, and any proposed action and resolution where it is determined that the complaint is valid.
Our response will also provide options available to you if you are not satisfied with our response. This will generally include the offer of an independent internal review conducted by a designated Director or consultant of Stable Connect
The details of the designated Director or consultant will be provided at the time of our response. We will also include the contact details for the Australian Financial Complaints Authority (AFCA) which also appear below.
Stable Connect has a maximum timeframe to provide you with a formal complaint response within 30 calendar days unless we have had no reasonable opportunity to provide a response whether due to the complexity of the complaint or due to matters beyond our control.
4.5 Delayed complaint resolution
Some limited exceptions for resolution may apply in certain circumstances. Where a delay is likely to occur and we are unable to resolve the complaint within 30 calendar days, we will issue a delay notification to the complainant (either yourself or your representative). In our communication, we will include the reason for the delay. You have a right to complain to AFCA if you are dissatisfied with the delay.
4.6 Maintaining and filing complaints
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All records in relation to the complaint are retained by the Complaints Officer within the Company’s document management system.
5. Independent External Review – Australian Financial Complaints Authority (AFCA)
Stable Connect is a member of AFCA. If you still do not get a satisfactory outcome within 30 calendar days of the first notification of your complaint to us, you have the right to lodge a complaint with AFCA.
Australian Financial Complaints Authority (AFCA)
GPO Box 3, Melbourne, VIC 3001
w. https://www.afca.org.au/about-afca
Consumers - 1800 931 678
Infoline - 1300 300 630
This service is provided to you free of charge
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We may refer a complaint to AFCA for resolution when a complaint remains unresolved and you have not escalated the matter to AFCA. In such instances, we will obtain your consent prior to escalating any unresolved complaints with AFCA.
The Australian Securities and Investments Commission (ASIC) also has a freecall Infoline 1300 300 630 which you may use to obtain information about your rights.