Complaints Handling Policy
The Policy outlines The Start Up Loans Company’s (SULCo’s) approach to capturing, responding to and resolving complaints. It outlines the objectives underpinning SULCo’s complaints process, explains how to submit a complaint, and who will be responsible for reviewing complaints. SULCo is exempt from Financial Conduct Authority (FCA) regulation, but its approach has been developed in accordance with the principles and requirements outlined by the FCA and should be read in conjunction with SULCo’s other key policies, including the following:
SULCo is a subsidiary of the British Business Bank (BBB). This Policy only applies to SULCo and its customers. A separate BBB Complaints Handling Policy can be found on the BBB website.
2. Purpose and Objectives
SULCo strives to deliver a fair and positive experience for all individuals engaging with the scheme. As part of this endeavour, SULCo is committed to continually reviewing and improving both its offering and the way this offering is delivered. The feedback SULCo receives from its customers and other stakeholders, whether positive or negative, is a primary way that the organisation identifies areas for improvement. The purpose of this Complaints Handling Policy is therefore to provide you with a clear and transparent process for submitting a complaint. This objectives of this Policy are to:
- Provide a clear outline about how any individual who comes into contact with the Start Up Loans scheme can make a complaint.
- Explain who should be contacted when submitting a complaint, including how and when you can escalate a complaint to the Financial Ombudsman Service (FOS).
- Clearly communicate the levels of service you can expect when going through the complaints process.
This Policy applies directly to any individual who has engaged with SULCo and its operations, and wishes to express dissatisfaction or submit a complaint. This Policy does not apply to the scheme’s Delivery Partners or Finance Partners, but you can express dissatisfaction about these Partners to SULCo, who will ensure you are provided with a fair and impartial consideration of your concerns. However, whilst the schemes Partners are monitored by SULCo, they are separate legal entities that operate to their own policies and procedures. You should consult your Delivery Partner or Finance Partner’s own Complaints Policy for guidance on how complaints are managed by this organisation. SULCo has separate policies and procedures for individuals, companies and other organisations who wish to submit a Freedom of Information request or a Data Subject Access Request. This Policy does not apply to employees of SULCo.
4. What is a Complaint?
A complaint is not restricted to a formal submission of dissatisfaction. You may communicate an issue or concern at any stage of your engagement with SULCo, through any method and via any channel.
5. Legal and Regulatory Obligations
SULCo is exempt from FCA regulation, but in order to ensure consistency in how customers are treated, SULCo requires all Delivery and Finance Partners to comply with FCA Regulations in relation to their complaints handling procedures, regardless of their regulated status. SULCo can only investigate complaints that relate to itself or Delivery Partners that are not regulated by the FCA. Please contact our Customer Service team, or visit our Delivery Partners FAQ page for further information. If you would like to express dissatisfaction or make a complaint to SULCo about your Regulated Delivery Partner, SULCo cannot investigate on your behalf. This is because where your Delivery Partner is regulated, you have the right to refer your complaint to The Financial Ombudsman Service (FOS). Their contact information can be found in Section 10. Please note that FOS will only investigate a complaint on your behalf, if your regulated Delivery Partner or Finance Partner has had the opportunity to deal with the matter first through their own complaints process.
In line with market practice, complaint records are kept on file for a three year period and SULCo will co‐operate with any official investigations or requests for information, as required by the relevant authorities.
6. Submitting a complaint
Depending on what stage of the application process you are at, you may find yourself working directly with SULCo, or with one of our official partners, including both our Delivery Partners and Finance Partners. For this reason and to ensure that every complaint is reviewed by the appropriate team as early in the process as possible, SULCo recommends that you use the following guidance about who, when and how to submit a complaint:
Who to submit a complaint to:
When to submit a complaint:
How to submit a complaint:
The Start Up Loans Company
If you have a complaint regarding information or communications provided by SULCo, then this complaint should be submitted directly to SULCo. This will likely, though not exclusively, be the case when you have not yet been assigned to one of SULCo’s Delivery Partners.
This is likely to apply to any complaints regarding:
- Information provided on the SULCo website, or in any official SULCo marketing material and campaigns
- Guidance or support provided by SULCo’s Customer Service team
The Contact page on the SULCo website:
Customer Service team:
*Services available weekdays 9.00am – 6.00pm, excluding bank holidays. **Individuals should expect a reply from a SULCo representative within two working days.
If you have been assigned to one of SULCo’s Delivery Partners then complaints should be submitted directly to that organisation in the first instance.
This is likely to apply to any complaints regarding:
- Service or communications received from the Delivery Partner during the application process for a Start Up Loan
- Outcome of a Start Up Loan application
- Mentoring support provided once a Start Up Loan has been received
Delivery Partner website, phone or email.
Delivery Partner official social media channels (where available).
There are two Finance Partners affiliated with the Start Up Loans scheme – The Growth Company and Street UK.
If unsure, you should consult their Loan Agreement to find out which Finance Partner administers your loan or contact SULCo’s Customer Service team for guidance.
If you have already received a Start Up Loan and your complaint relates to loan administration then complaints should be submitted directly to the Finance Partner organisation that issued your Loan Agreement.
This is likely to apply to any complaints regarding:
- Loan repayments
- Direct Debit set up
- Communications received regarding loan administration
Finance Partner website, phone or email.
Finance Partner official social media channels (where available).
7. The complaints process
The following process relates to complaints that are submitted directly to SULCo and are within the scope of this Policy (see Section 3). Please note that, as referenced in Section 3, if you are submitting a complaint to a Delivery Partner or Finance Partner, you should request a copy of their specific Complaints Policy.
When SULCo receives an individual’s complaint it will endeavour to address the matter immediately, effectively, and in a fair and reasonable manner.
If a resolution cannot be reached within three working days, the Customer Service Team will send you a written acknowledgement. This written acknowledgement will:
- Acknowledge that a complaint has been submitted;
- Advise you that SULCo’s Complaints Manager is reviewing the matter;
- Inform you that the matter will be investigated and that a Final Response will be provided in writing within eight weeks of the complaint being received (although SULCo aims to resolve all matters sooner than this where possible).
From this point forward, SULCo’s Complaints Manager will assume responsibility for ensuring your complaint is resolved within eight weeks. The Complaints Manager will ensure that the complaint is investigated by the appropriate individuals within this above timescale.
Once the matter has been investigated and SULCo has made a decision regarding the complaint, you will receive a written Final Response from the Complaints Manager. This Final Response will be provided to you in PDF format via email and will:
- Acknowledge all of the concerns within the original complaint;
- Outline the findings of the investigation;
- Clarify whether the complaint was ‘upheld’ or ‘not upheld’;
- Outline the proposed resolution (if applicable);
Inform you that if you are not satisfied with the Final Response, you have the right to escalate the matter to the British Business Bank. You must do this within six months of receiving your Final Response.
In exceptional circumstances, the Complaints Manager may not be able to provide you with a Final Response within eight weeks. In these instances, a holding communication will be sent to you in writing. This holding communication will:
- Inform you of the delay;
- Outline the reasons for the delay;
- Provide an expected response time for sending the Final Response.
8. Escalating a complaint: The British Business Bank Group
In the unfortunate event that you are dissatisfied with the final outcome of your response from SULCo, you have the right to escalate your complaint to the Chief Risk Officer at the British Business Bank (BBB).
Whilst BBB has no involvement in the day to day management of SULCo, SULCo is a subsidiary of BBB and as such, it will act as a point of escalation to SULCo customers if they remain dissatisfied with the final outcome of their complaint. BBB contact information can be found in Section 10.
The BBB is not regulated by the FCA.
9. Levels of service
SULCo endeavours to ensure that, where possible, all individuals who interact with the scheme:
- Receive a fair and positive experience;
- Are supported in accordance with their needs, provided this does not conflict with SULCo’s policy requirements or other regulations that the scheme is bound by;
- Are given fair and impartial consideration of their concerns, with due consideration for their confidentiality;
- Have their concerns responded to in a timely manner that reflects the approach outlined within this Policy;
- Can rely on accurate information being provided with which to make an informed decision;
10. Contact information
If you have any questions about this Complaints Policy, the regulatory status of your Delivery Partner, or SULCo’s approach to managing complaints, please use the following details:
SULCo Customer Service team
If you are dissatisfied with the final outcome from your FCA regulated Delivery Partner or Finance Partner, please use the following details:
The Financial Ombudsman Service (FOS)
This is a free service for businesses and consumers.
Phone: 0800 0234 567
Open weekdays, 8.00am – 8.00pm and Saturdays 9.00am – 1.00pm.
Free on mobile phones and landlines.
If you are dissatisfied with the final outcome from SULCo and wish to escalate your complaint to the Chief Risk Officer at BBB please use the following details:
The British Business Bank (BBB)
FAO The Chief Risk Officer
British Business Bank plc
Steel City House
11. Further information
SULCo will not reimburse any fees, expenses or costs involved in raising a complaint. Nothing in this Policy should be interpreted to restrict any rights of redress a Complainant has in law.
Please note that this Complaints Policy cannot be used to deal with an issue that is part of any legal action against SULCo.
SULCo reserves the right to take any appropriate action to protect itself from any unfounded, malicious or vexatious allegations or complaints. Untrue allegations could lead to legal action for defamation. This Policy does not confer any contractual rights and SULCo reserves the right to update this policy and its key terms at any time.
SULCo will always respect data confidentiality and any comments complainants make about the scheme, its Delivery partners or Finance Partners, and will be dealt with in accordance with current Data Protection legislation.
It is SULCo’s policy to present information on complaints to its Board at least quarterly.