Consumer Law Complaints Handling Policy

Background

Modular Wholesale Co. Pty Limited ACN 647 208 115 (the ‘Company’) is committed to handling all complaints in a fair, efficient, and effective manner. The Company recognises the right of individuals to comment and complain and is committed to resolving all complaints in a positive and timely manner.

All complaints received by the Company (in writing and by phone) related to conduct that may contravene the competition and /or consumer law provisions of the Competition and Consumer Act 2010 (Cth) (‘Act’) will be dealt with in accordance with this policy.

What is a Competition /Consumer Law complaint?

In this policy, a complaint is an expression of dissatisfaction made to us, related to conduct that may contravene the competition and /or consumer law provisions of the Act, or our complaint handling process itself, where a response or resolution is explicitly or implicitly expected. A complaint is distinguished from feedback and enquiries.

Feedback is an opinion, comment, suggestion, or expression of interest related to our compliance with the competition law provisions in the Act or our complaint handling process.

An enquiry is a request for information, or an explanation related to our compliance with the competition law provisions in the Act.

Where Competition /Consumer Law complaints can be made

We are willing to accept complaints orally, in person, over the phone and by any written means such as by post or email to the Competition/Consumer Law Compliance Manager.

The contact details for the Competition /Consumer Law Compliance Manager are as follows:

Name: Emma Smith
Phone: 1300 770 588
Email: emma@modularw.com.au

We will also accept such complaints made by a person on behalf of another person.

Process for handling Competition / Consumer Law complaints

Any Company representative that receives a complaint must immediately report particulars of the complaint and the complainant to the Competition/Consumer Law Compliance Manager.

The Competition /Consumer Law Compliance Manager must:

(a) acknowledge receipt of the complaint promptly;
(b) clarify the outcome that the complainant is seeking;
(c) make a preliminary assessment as to the significance of the complaint and the urgency of any action required;
(d) respond to the complaint if it is minor or explain the next steps in the complaint process, for example, referral for further consideration or an investigation (as applicable);
(e) estimate a timeframe within which the person can expect to be contacted again;
(f) confirm that the person is satisfied with the proposed next steps or resolution; and
(g) follow up the complaint (where appropriate).

The Competition /Consumer Law Compliance Manager and other Company representatives must not handle a complaint if he or she is in any way implicated in the complaint. In these circumstances, the complaint must be handled by another member of the Senior Management Team.

All complaints will be handled confidentially, impartially and promptly.

Oral complaints

Any Company representative that accepts an oral complaint must:

(a) listen patiently;
(b) endeavour to record all details of the complaint in writing at the time, or as soon as practicable after, the complaint is made including details of the complainant;
(c) confirm that his or her understanding of the details of the complaint are correct; and
(d) not take sides or become defensive.

Classification of complaints

The significance of a complaint must be assessed and classified by reference to the following criteria:

(a) severity;
(b) financial implications;
(c) complexity;
(d) impact on the individual and public; and
(e) potential to escalate.

Investigations

An investigation will be undertaken if a complaint is considered to be significant.

We will take all reasonable efforts to ensure that all relevant circumstances are considered in an investigation.

Any complaint that requires investigation must be referred to the Senior Management Team for them to determine an appropriate resolution.

The Company may seek assistance from external parties to assess and investigate complaints and the likelihood that the substance of the complaint may indicate a contravention of the Act.

Timeframes

We will acknowledge written complaints within 5 days of receiving them.

We will endeavour to resolve complaints as quickly as possible and within 30 days of receiving them unless there are special circumstances.

Disputing a response or resolution to a complaint

If a person is not satisfied with a response received to a complaint or disagrees with a proposed resolution to a complaint, the person handling the complaint may seek additional information and should refer the complaint to the Senior Management Team for further review.

Continuous improvement

The Company acknowledges that the complaints process offers an opportunity for the organisation to improve its operations.

All complaints will be reported for consideration at Senior Management Team meetings and improvements to existing procedures may be suggested. The effectiveness of our complaint handling processes will also be reviewed regularly by the Competition Law Compliance Manager and the Senior Management Team.