Complaints & Disputes


This policy explains how you can make a complaint, our measures for handling your complaint, and the steps you can take if you are not satisfied with our response to your complaint or the time that it takes for us to respond.

The Concept Trading acknowledges the importance of having an effective and efficient complaints handling and Internal Dispute Resolution (“IDR”) framework, and we adopt a customer-focused approach. While we acknowledge your right to make a complaint, we expect that you will treat our staff with respect when they are dealing with your complaint.

The purpose of this Complaints Policy is to set out the information required to be in a Complaints policy by ASIC Corporations, Credit and Superannuation (Internal Dispute Resolution) Instrument 2020/98 (“the Instrument”).

The Instrument is a legislative instrument made by ASIC. Further information is contained in ASIC RG 271.

The Concept Trading adopted this current policy on 2nd November 2021.

What is a Complaint?

For the purposes of this policy, a Complaint is defined as:

An expression of dissatisfaction made to or about an organisation—related to its products, services, staff or the handling of a complaint—where a response or resolution is explicitly or implicitly expected or legally required.

This is the definition given in Australian Standard AS/NZS 10002:2014 Guidelines for complaint management in organizations.

How to make a complaint

If you want to make a complaint to us, you may do so in any of the following ways:
Telephone: +61 7 4599 3855

It is important to note that your complaint may be made either in writing or verbally, however, we encourage all communication to be in writing.

When making your complaint, you will need to advise:

If you need help to make or manage your complaint, you can appoint someone (for example, a relative or friend) to represent you. Please note that we will need your authority to speak to any representative that you appoint.

How we will deal with your complaint


We will acknowledge receipt of your complaint and try to resolve it as quickly as possible.

Generally, where your complaint is made:

When acknowledging your complaint, we will also have regard to any preferences you have communicated to us in relation to the way in which you wish for us to communicate with you.

Investigation of your complaint

If we cannot resolve your complaint immediately, we will need some time to investigate your concerns.
We may also request that you provide us with further information to assist us with the investigation.

IDR Response

We will provide you with our written reasons for the outcome of your complaint (“IDR Response”) within 30 calendar days after receiving your complaint where:

Our IDR Response will also inform you of your right to escalate your complaint to the Australian Financial Complaints Authority (“AFCA”). AFCA offers a free and independent dispute resolution for financial complaints to individuals and small businesses.

If we reject your complaint (whether in full or in part), our IDR Response will:


We are not required to provide you with an IDR Response if:

Delay in providing an IDR Response

If we are not able to provide our IDR Response to you on time because your complaint is complex or because of circumstances beyond our control, we will write to you to explain the reasons for the delay and inform you of your right to complain to AFCA and provide you with AFCA’s contact details.

Escalating your complaint

If you are not satisfied with our response to your complaint, you can escalate your complaint to AFCA.


The Concept Trading is required to be a member of an external dispute resolution scheme. Accordingly, we are a member of AFCA and our membership number is 12606 as an Authorised Corporate Representative {CAR NUMBER} of JB Markets Pty Ltd ABN 81 123 876 291, AFSL 323182.

You can contact AFCA by way of the following:
Telephone: 1800 931 678
Mail: GPO Box 3 Melbourne Victoria 3001

The AFCA website also permits you to register or lodge a dispute online.


1.1 Complaints Handling Procedure & Process

Procedure Overview

The IDR procedure comprises the following steps:
The following sections describe each of these steps in detail.

Lodging a Complaint

The following table provides information on how a Complainant can lodge a
Complaint with TCT.

Appendix G has to be completed by the TCT representative in case of a verbal
Complaint and given to the Compliance Officer.

Process and Procedure for Receiving Complaints

All sources of Complaints received must be communicated to the Compliance Officer immediately, but no later than within one business day of receipt, regardless of the method they were received, their nature, severity, complexity (also refer to Recording Complaints in the Complaints Register).

For Complaints received via email, the TCT Compliance Officer will be responsible for managing Complaints received through

It is a requirement that all Complaints are logged in the Complaints Register within five business days of receipt.

Recording Complaints in the Complaints Register (see Appendix A)

The Complaints Register serves as a Complaint tracking system to capture vital information about Complaints. Its purpose is to:

Managing Complaints

TCT manages Complaints to ensure Complaints are dealt with appropriately, in a timely manner, and as far as possible, to the Complainant’s satisfaction. This process involves investigating, handling, resolving or escalating the Complaint.

Investigating Complaints

When investigating a Complaint, the Compliance Officer must:

Handling Complaints

All Complaints must be assessed and resolved in a timely manner. The following
minimum standards apply to the resolution of all Complaints:

Sample Content of written TCT Process explanatory to Complainant:

Internal Complaints Resolution Procedure

Complaints may be made verbally or in writing. TCT will attempt to deal with your Complaint in a prompt and efficient manner. TCT will follow the procedure outlined below to ensure that our Complaint is resolved within a period of 30 days (where possible). Some Complaints can be resolved more quickly depending on the facts and the nature of the Complaint. If the Complaint is more complex and takes longer than 30 days, we will communicate the reasons for the delay. If the reasons for the delay are not acceptable to you, you have the right to refer the matter to the External Complaints Resolution Scheme – see section 2.

Our Compliance Officer will assist you if you require assistance in making your Complaint so that all relevant facts are provided.
The following procedure will be followed to review and investigate your Complaint under our Internal Complaints Handling Procedures:

a) Once a Complaint is communicated to TCT, the Compliance Officer will listen to your Complaint or review your written Complaint and ascertain the key issues of your Complaint.

b) The Compliance Officer will ask you to provide specific or additional information so that they can ascertain all relevant facts. You are invited to provide as much information as you think is relevant to the Complaint

c) The Compliance Officer will confirm the key issues of our Complaint either verbally or in writing and keep in regular contact with you while the Complaint is being investigated.

d) The Compliance Officer will conduct an independent internal investigation based on the facts provided in your Complaint.

e) The Compliance Officer will contact you should any additional information be required.

f) The Compliance Officer will discuss the outcome of the review with TCT’s senior management and a decision will be made relating to the resolution of your Complaint. TCT may either:

g) Accept the Complaint and offer a remedy;

h) Offer a remedy without accepting the Complaint; or

i) Reject the Complaint and provide reasons for such a rejection.

j) Remedial action may range from an apology to financial compensation. Where a financial remedy is considered appropriate, the aim is to provide fair compensation for any loss suffered.”

Written Resolution

Written correspondence must be sent to the Complainant for all resolved Complaints. The letter should include:

Sample Complaints Letter 1


<Title> <First name> <Surname> <Street no> <Address> <Suburb>
<State> <Postcode>

Dear <.Title> ,
Account number:
We write with reference to the above and your correspondence/call/fax/e-mail dated 00/00/00 and our subsequent telephone conversation of 00/00/00.We are writing to confirm that we are currently in the process of reviewing your concerns regarding …provide a brief summary of customer Complaint. [insert relevant detail]
Presently we are in the process of requesting further information from [insert relevant detail].

We will attempt to complete our review within 30 days of (insert date above). However, it is possible that additional time may be required. If the review is not completed within this period, we will advise you of its progress.

If you wish to discuss this matter further, please do not hesitate to contact me directly on . Alternatively, you can contact our office on our toll-free line [insert hotline number].
Yours sincerely,

{Compliance Officer Full Name}
Compliance Officer

Sample Complaints Letter 2


<Title> <First name> <Surname> <Street no> <Address> <Suburb>
<State> <Postcode>

Dear <.Title><Surname> ,
Account number:

We write with reference to the above and your correspondence/call/fax/e-mail dated 00/00/00 and our subsequent telephone conversations.

We understand that your concerns were …provide a brief summary of customer Complaint.
[insert relevant detail]

We can confirm that we have now received all the relevant information and have therefore been able to proceed with the full assessment of your concerns.[insert relevant detail]

We trust this meets your approval, however should you still be dissatisfied If you wish to discuss this matter further please do not hesitate to contact me directly on [insert number], or you can contact the office on our toll-free line [insert hotline number].

Alternatively, you have the option to utilise our External Dispute Resolution (EDR) Procedure via the Australian Financial Complaints Authority (AFCA). AFCA can be contacted for the cost of a local call.
Free form text paragraph, this paragraph should outline the action that has been
taken to resolve the Complaint and the decision made.

AFCA contact details

Australian Financial Complaints Authority
GPO Box 3, Melbourne Vic 3001 1800 931 678


Yours sincerely,
{Compliance Officer Full Name}
Compliance Officer

Sample Complaints Letter 3


<Title> <First name> <Surname> <Street no> <Address> <Suburb>
<State> <Postcode>

Dear <.Title> ,
Account number:

We write with reference to the above and our correspondence/call to you dated the 00/00/00.

Presently we are in the process of awaiting further information from [insert relevant detail]. To date we have not yet received a reply despite contacting them on the following date(s) 00/00/00.

Unfortunately, we cannot proceed with reviewing your concerns without this information.
We will continue to pursue this matter with [insert relevant detail] but as your Complaint has been outstanding 45 days, we remind you of your option to utilise the External Dispute Resolution (EDR) Procedure via the Australian Financial Complaints Authority (AFCA).

AFCA can be contacted for the cost of a local call. AFCA contact details:

Australian Financial Complaints Authority

GPO Box 3, Melbourne Vic 3001
1800 931 678
Toll Free Telephone: Website:

If you wish to discuss this matter further please do not hesitate to contact me directly on [insert number]. Alternatively, you can contact our office on our toll free line [insert hotline number].

Yours sincerely,

{Compliance Officer Full Name}

If a matter remains unresolved for 45 days or more, TCT is required to advise the Complainant of their
EDR options (refer to Managing Complaints).

Escalation Process for EDR

In case there is no resolution of the Complaint within 30 days, or if an extension for the time frame to review and respond to the Complaint has not been sent to the Complainant under section 0 above, if the Complainant wishes to do so, the Complaint can be referred to AFCA.

TCT is required to advise the Complainant of the services of FOS. (TCT is a member of AFCA – AFCA membership no 12606)

EDR Contact Details

Contact details for AFCA:
Australian Financial Complaints Authority (AFCA)

GPO Box 3, Melbourne Vic 3001 Toll Free Telephone: 1800 931 678

Toll Free Telephone:




The purpose of the The Concept Trading AU/NZ Pty Ltd (‘TCT’) Dispute Resolution Policy (‘Policy’) is to ensure client complaints in respect of financial services are dealt with promptly, fairly and consistently in accordance with the Corporations Act 2001.

This Policy represents TCT’s commitment to fair and transparent dealings in the financial marketplace.

This Policy is drafted to comply with ASIC Regulatory Guide RG 271: Internal dispute resolution replacing RG 165: Licensing: Internal and External Dispute Resolution on October 5 2021 and TCT’s obligations under sections 912A(1)(g) and 912A(2) of the Corporations Act 2001 (Cth).

This Policy has been developed in accordance with the principles outlined in Australian Standard AS ISO 10002-2014.


The benefits of effectively resolving client complaints through an Internal Dispute Resolution (‘IDR’) procedure with broad coverage include:

a) taking a proactive approach to identifying complaints;

b) the opportunity to resolve complaints quickly and effectively;

c) the ability to identify and address recurring or systemic problems, which can lead to product and service improvements;

d) the capacity to provide fast solutions to problems rather than have remedies imposed by an external body; and

e) improved levels of client confidence and satisfaction.

Wherever possible, complaints should be resolved directly with clients through the IDR procedures.

It is better for all parties that a complaint is dealt with at the earliest possible stage because it:

a) prevents complaints from becoming entrenched;

b) preserves client relations; and

c) is often the most efficient and cost-effective way for an organisation to deal with complaints.


TCT aim to resolve the majority of complaints at the first point of contact within short timeframe.

For minor complaints, TCT aims to resolve during the client’s initial contact with TCT.

For other complaints, TCT aims to resolve the complaints within five (5) business daysafter receipt of the complaints.

TCT aims to outperform the maximum IDR timeframes, which is thirty (30) calendar days after receiving the complaint.


AFCA means the Australian Financial Complaints Authority, an ASIC approved external dispute resolution (‘EDR’) scheme.

Complaint means an expression of dissatisfaction made to or about an organisation, related to its products, services, staff or the handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required.

Complainants are not required to expressly state the word complaint or dispute or put their complaint in writing to trigger TCT’s IDR obligations. Social media posts or comments made on the firm’s account and where the commentator is both identifiable and contactable will be considered complaints and subject to IDR obligations. In addition, dissatisfaction about a matter that is already subject to IDR procedures or the IDR procedures themselves will be considered complaints.

EDRS means External Dispute Resolution Scheme.

Dispute has the same meaning as complaint.

Final Response means a written response to the complainant informing them of the final outcome of their complaint or dispute.

IDR means Internal Dispute Resolution.

Maximum timeframes for an IDR response: 30 Calendar days upon receipt of initial complaint
Policy means this Internal Dispute Resolution Policy.

TCT means The Concept Trading AU/NZ Pty Ltd and its related bodies corporate.



TCT’s Employees must immediately inform the Risk and Compliance Officer regarding to the complaint. This ensures that wherever possible, the complaint will be investigated by a staff member not involved in the subject matter of the complaint.

On receiving a complaint, the following information must be recorded:

(a) Date of complaint;

(b) Name of complainant;

(c) TCT’s business team concerned;

(d) Contact details of complainant;

(e) Format of complaint (phone / email / letter / fax/ social media);

(f) Preferred contact method of complainant (phone / email / letter / fax);

(g) Details of the complaint; and

(h) Classification of the complaint (Refer to Section of Classification of complaints)

TCT aims to acknowledge the receipt of the complaint promptly using the preferred contact. The acknowledgment is normally immediate or within 24 hours (one business day). In other cases, TCT will acknowledge the complaint as soon as practicable.


Expressions of dissatisfactions in posts that meet the definition of complaint on a social media channel or account owned or controlled by TCT, where the author is both identifiable and contactable, are complaints.
Complaints about a matter that is the subject of an existing remediation program or about the remediation program itself (e.g. delays, lack of communications) are complaints.
When responding to a complaint made on social media, TCT will ensure consumer privacy is protected.
TCT Representatives must refer complains made on social media to the Company as they are required to do for complaints they receive through other channels.


The following procedure must be followed when a complaint is received orally:

(a) Identify yourself, listen, record details and determine what the complainant wants;

(b) Confirm the details received;

(c) Empathise with the complainant in a courteous manner;

(d) Explain the courses of action available;

(e) Do not attempt to lay blame or be defensive;

(f) Resolve the complaint if possible or commit to doing something immediately, irrespective of who will ultimately handle the complaint;

(g) Don’t create false expectations;

(h) Inform the complainant of the name and contact details of the person who will be formally dealing with the complaint (i.e. the Complaints Officer);

(i) Refer the matter immediately to the Risk and Compliance Officer (even if you resolved the matter);

(j) Record the details in the complaints register.


All complaints must be classified by TCT and then analysed to identify systemic, recurring and single incident problems and trends.

Level 1 – the least serious complaints. The complaints are more incidental in nature and it could be resolved generally during the initial contact with TCT.

Level 2 – more serious complaints, considering the nature, scale and complexity of the complaints. It could be an indicator for systemic issues. The Risk and Compliance Officer will be in charge of the case analysis and investigation. Directors will be involved and oversee the progress.

Level 3 – the most serious complaints. Directors will take over and lead the case.


Client facing representatives, normally the sales team members, are the frontline staff and initial point of contact considering the complaint.

The Risk and Compliance Officer is informed of all levels of complaints and is responsible for dealing with more serious and complex complaints.

The Board of Directors hold overall responsibility for TCT’s IDR process.

For Level 1 complaints, frontline staff are empowered to resolve the complaints at the first point of contract within a short timeframe, generally within 1 business day. The Risk and Compliance Officer will be informed of the progress and outcome and will be engaged where deemed necessary.

For Level 2 complaints, the Risk and Compliance Officer will conduct in depth review and investigation of the case, which will be briefed to the Board of Directors. The Board of Directors will oversee the progress and will engage where deemed necessary. Level 2 complaints are generally expected to be resolved within 5 business days upon receipt.

For Level 3 complaints, Directors will take over the case and lead the case investigation. The Directors will consider the situation, all available information and the investigation reasoning and outcome conducted by the Risk and Compliance Officer and then provide
the complainant with a written response within thirty (30) calendar days upon receipt of the initial complaint.

There are many variables that can affect complaint response times. TCT is not required to provide a complainant with an IDR response within the maximum IDR timeframes if certain circumstances exist:

(a) resolution of the individual complaint is particularly complex; and/or

(b) circumstances beyond the financial firm’s control are causing complaint management delays

An example of ‘complexity’ is an individual complaint that is about a transaction or event that occurred more than six years ago and requires reconstruction of account information; and

Examples of circumstances that may be beyond a financial firm’s control include when:

(a) the complainant is waiting on a medical appointment that the firm reasonably requires the complainant to attend;

(b) the complainant is unable to respond to the financial firm due to illness or absence;

(c) information must be obtained from third parties to a complaint (excluding an authorised representative who is a party to the complaint); and

(d) a death benefit decision-maker is waiting on information requested from potential beneficiaries to a death benefit to substantiate their claim.

Before the relevant maximum IDR timeframe expires, an “IDR delay notification’ must be given to the complainant that advises the complainant about:

(a) the reasons for the delay;

(b) the complainant’s rights to complain to AFCA if they are dissatisfied; and 

(c) the contact details for AFCA.

Where a complaint relates to a potential or alleged breach of the financial services laws, an appropriate assessment is carried out at the same time as the complaint is managed as to the nature of any alleged breach to determine whether it is (or may become) a reportable situation as per TCT’s Breaches and Incidents Reporting Policy and under ASIC’s new breach reporting regime (RG 78).


Complaints referred to the Risk and Compliance Officer must be responded to in the same manner they are received unless otherwise requested by the client. For example, a telephone complaint must be initially responded to with a telephone call.

The time and date of all telephone calls to the client made in connection with a complaint must be recorded with other details about the complaint outlined in section Receiving Complaints of this Policy.

TCT will provide an IDR response to Complainants no longer than 30 calendar days after receiving the complaint. Level 3 complaints will require an IDR response.

An IDR response will not be required, if the complaint is closed by the end of the 5th business day and because TCT has:

(a) resolved the complaint to the complainant’s satisfaction, or

(b) given the complainant an explanation and/or apology when the firm can take no further action to reasonably address the complaint.

Generally Level 1 and 2 complaints do not require an IDR response.

However, TCT must provide a written IDR response, even where the complaint is closed by the end of the fifth business day, if:

(a) the complainant requests a written response; or

(b) the complaint is about hardship.


An ‘IDR response’ is a written communication from TCT to the complainant, informing them of:

(a) the conclusion of TCT’s internal dispute resolution process in relation to the client’s complaint/dispute.

(b) the final outcome of their complaint at IDR (either confirmation of actions taken by TCT to fully resolve the complaint or reasons for rejection or partial rejection of the complaint. The word final should be given prominence);

(c) their right to take the complaint to AFCA if they are not satisfied with the IDR response; and the contact details for AFCA.

If TCT rejects or partially rejects the complaint, the IDR response must clearly set out the reasons for the decision by:

(a) identifying and addressing the issues raised in the complaint;

(b) setting out TCT’s findings on material questions of fact and referring to the information that supports those findings;

(c) providing enough detail for the complainant to understand the basis of the decision and to be fully informed when deciding whether to escalate the matter to AFCA or another forum; and

(d) detailing the time limit to lodge a dispute with the relevant EDRS; (e.g.: in relation to AFCA, the client must lodge a dispute within two (2) years of the date of the final written response).

The level of detail in an IDR response should reflect the complexity of the complaint and the nature and extent of any investigation conducted by the firm.


When an outcome is reached for a complaint, TCT will be communicating with complainants through telephone first. If complainants are satisfied with the resolution of the complaint, a verbal or written confirmation will be required from complainants. The IDR response will be emailed to the complainants where applicable.


A Complaints Register is managed by the Risk and Compliance Officer.
All complaints received will be recorded in the Complaints Register.


The Risk and Compliance Officer should aim to identify any systemic issues or recurring complaints as a result of compiling the Complaints Register.

Where any systemic issues or recurring complaints are identified, these should be addressed to the Directors by preparing a report to accompany the Complaints’ Register. The report must include metrics and analysis of complaints including about systemic issues identified thorough those complaints. This will encourage the identification of compliance issues or risks, which can be investigated to determine their causes and can
then be rectified.

If an investigation confirms that a systemic issue exists, TCT will take prompt action to identify affect clients and provide fair remediation.

Where any systemic issue results in a breach of TCT’s obligations under their AFSL, the Corporations or any other financial services laws, the breach will be reported by the Risk and Compliance Officer in accordance with TCT’s Breaches and Incidents Reporting Policy.



A broad range of possible remedies are considered when attempting to resolve complaints. Remedies may include:

(a) an explanation of the circumstances giving rise to the complaint;

(b) an apology;

(c) provision of assistance and support;

(d) a refund or waiver of a fee or charge;

(e) a goodwill payment;

(f) a payment of compensation;

(g) waiver of a debt

(h) replacing damaged or lost property;

(i) correcting incorrect or out-of-date records;

(j) repairing physical damage to property;

(k) changing the terms of a contract;

(l) ceasing legal or other action that may cause detriment; and

(m) undertaking to set in place improvements to systems, procedures or products.

If the Risk and Compliance Officer or the Directors are of the opinion that a complaint requires a remedy (e.g. compensation), the matter must be referred to the Directors to make a determination.


The IDR procedure should not involve the release of information on TCT generally, or clients or staff individually, that contravenes TCT’s Privacy Policy in relation to confidential information or contravenes any other policies in relation to the contractual obligations of TCT.

All staff need to be aware of their obligations in dealing with personal information. Reponses to IDR matters that contain personal information on clients or staff must be provided to the Directors for final approval, prior to publication or release. Staff are recommended to refer to the Privacy Policy for additional information about their obligations in dealing with personal information.

Further information and advice on this matter can be obtained from the Directors.



TCT is required to be a member of an EDR. TCT is a member of AFCA. TCT’s AFCA
membership number is 31643. If membership with this scheme is changed or cancelled,
TCT will notify ASIC within three (3) business days of becoming aware of the change.

TCT will diarise when their AFCA membership is due for renewal.

TCT will liaise with AFCA and ensure full cooperation with it.



Employees of TCT who deal with clients, not just complaints handling staff, need to have an understanding of the IDR procedures. Consequently, all employees of TCT will receive regular training and information about the IDR procedures including awareness of their obligations under RG 271 and financial services laws. This training will be scheduled and conducted at the discretion of the Risk and Compliance Officer. All training will be recorded in the Training register, along with an attestation form the employees.

The Risk and Compliance Officer will provide training to client facing representatives in regard to how to handle unreasonable complainants conduct.


The complaint policy is made publicly available and readily accessible via TCT’s website. The hard copy is free to clients on request.


Directors, Officers and Employees of TCT are required to retain copies of all Complaints Handling documents in accordance with the TCT’s Document Retention Policy. These files are to be maintained at the premises of TCT. A copy must also be provided to the Risk and Compliance Officer for storage and inspection by ASIC as required.

The Complaints Register is provided to the Risk and Compliance Officer on a monthly basis and a hard copy is kept on file.


This Policy will be reviewed regularly by the Directors having regard to the changing circumstances of TCT. Any amendments to this Policy will be advised by email and any updated Policy will be advised to TCT staff.

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