Internal Dispute Resolution Policy

In compliance with its obligations under ASIC Corporations (Non-Cash Payment Facilities) instrument 2016/211, part two, paragraph 4, Conditions, Issuers of low value, non-cash payment facilities, Mobility has prepared this policy.

This policy describes the systems that Mobility has in place for managing and resolving complaints and disputes in relation to the financial services provided under its Australian financial services (AFS) licence.

Mobility’s internal dispute resolution procedures (“IDR Procedures”) are in accordance with Australian Standard AS ISO 10002-2006.

The CEO has been appointed Mobility’s Complaints Officer.

 1. INTERNAL DISPUTE RESOLTUION

 1.1       Receiving and dealing with complaints

  • Complaints may be made in writing to, or by phoning, the Complaints Officer at:

Email: complaints@mobility.com.au

Phone: 1300 GET CARE (1300 438 227)

Or alternately, Complaints can be lodged through the FAQs section of the Platform.

  • The process for making complaints is outlined in this Internal Dispute Resolution Policy.

 

1.2       Timeframes for dealing with complaints

  • Mobility will endeavour to respond to all complaints within 10 business days by informing the complainant that their complaint has been received.
  • Mobility will endeavour to resolve a complaint within a maximum of 45 days from the date it confirmed that it had received the complaint to the complainant, but a shorter period if possible.
  • If Mobility cannot resolve a complaint within 45 days, Mobility will inform the complainant that they have been unable to resolve the dispute, and the complainant may wish to start mediation with an external mediator appointed by Mobility.

1.3      Resolving complaints

  • Mobility will endeavour to address all aspects of the complaint that can be resolved via remedies and will provide follow-up assistance where appropriate.
  • Mobility will, where appropriate, offer remedies to complainants that are both non-financial as well as, or instead of, financial remedies. Such remedies may include but are not limited to:
  • financial assistance (e.g. arranging for the Account holder to access additional services to the value of the agreed loss or damage);
  • other assistance (e.g. where there has been unauthorised or mistaken transactions relating to the facility or loss or theft of the device (if any) through which the facility is used);
  • compensation; or
  • Where a financial remedy is considered appropriate in the circumstances, Mobility will seek to offer compensation that is fair.
  • In determining the most appropriate remedy, Mobility will take into consideration any direct loss or damage suffered by the complainant as well as any relevant legal principles, relevant codes of conduct, fairness and relevant industry best practice.
  • In dealing with a complaint, Mobility may, in appropriate circumstances, offer remedies to other parties who have suffered in the same way as the complainant, but did not make a formal complaint.
  • Any material given to the complainant explaining IDR Procedures will be provided free of charge.
  • Any complaint about a service will be handled by Mobility free of charge (subject to statutory requirements).

1.4       Recording and monitoring complaints

  • When a complaint is first received, the Complaints Officer will enter all information concerning the complaint into the complaints register attached as Annexure A. Any additional correspondence from the complainant must also be recorded in the complaints register;
  • The information contained in the complaints register will comply with the National Privacy Principles. Mobility will inform individuals of what sort of personal information is held and for what purposes, including the method of collection, storage, use, accuracy and disclosure of information;
  • The Complaints Officer will be responsible for any trend analysis with respect to complaints. This may assist in identifying any systemic issues that may require remedial action;
  • The Compliance Officer reviews annually the operation of the IDR Procedures, including the complaints register, the number of complaints received, the type of activity complained of and the length and outcome of dealing with complaints;

1.5       Unresolved complaints

If  cannot resolve a complaint within 45 days, Mobility will inform the complainant that they have been unable to resolve the dispute, and that the complainant may wish to start the mediation with an external mediator appointed by Mobility.

1.6       Compliance with Australian Standard AS ISO 10002-2006

In accordance with Australian Standard AS ISO 10002-2006, Mobility subscribes to the following essential elements of effective complaints handling:

  • Fairnesss – Mobility’s IDR Procedures recognises the need to be fair to both the complainant and to SIAL or the person against whom the complaint is made. Mobility’s has therefore implemented a system whereby the complaint can be properly identified and investigated by staff not involved in the subject matter of the complaint, i.e. a Complaints Officer.
  • Resources – Mobility has adequate resources for complaints handling given the size of the business.
  • Feasibility – Mobility’s IDR Procedures will be well publicised to representatives and clients. The disclosure document, which all clients will receive, will contain information about the process for making a complaint.
  • Access – Mobility’s IDR Procedures are accessible to all representatives. Mobility’s IDR Procedures are easy to understand and use and are drafted in plain language.
  • Assistance – Mobility will provide assistance to clients in relation to the formulation and lodgement of complaints.
  • Responsiveness – Mobility ensures that complaints will be dealt with quickly and the complainant shall be treated courteously.
  • Charges – Mobility does not charge any handling fee in relation to complaints made against it on an internal basis.
  • Remedies – Mobility IDR Procedures have the capacity to determine and implement remedies.
  • Data Collection – Mobility has an appropriate systematic recording of complaints and outcomes as it maintains a complaints register.
  • Systematic and Recurring Problems – The Complaints Officer is responsible for any trend analysis with respect to complaints. In addition, the Compliance Manager reviews the complaints register annually.
  • Accountability – The Complaints Register is available for inspection by ASIC if required.
  • Reviews – Mobility’s IDR Procedures are reviewed annually by the Compliance Manager to ensure that it is efficiently delivering effective outcomes.