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COMPLAINTS PROCEDURE

Complaints & Escalation Procedure

1. Who can complain

Customers, employees, workers, contractors, managers, owners and members of the public can use the Help & Complaint Desk.

2. Intake

The system records the reporter, category, subject, details, confidentiality request and contact details, issues a case reference and creates an append-only case event.

3. Automated triage

Automated rules prioritise cases and route them to support, complaints officer, manager or owner. Automated triage assists routing only and does not determine legal liability, misconduct, credibility or final outcome.

4. Serious matters

Privacy/security incidents, fraud/scam concerns, safety matters, serious staff conduct allegations and legal/regulator correspondence receive elevated handling. Critical cases can trigger configured in-app, email, SMS and automated Telnyx voice alerts to an authorised senior recipient.

5. Conflicts and confidentiality

A complaint about a manager should be capable of bypassing that manager. Confidential cases should be limited to designated authorised recipients. Confidentiality may be subject to lawful investigation, procedural fairness, legal obligations and regulator/court requirements.

6. Fair process

Relevant people should be treated fairly, evidence should be preserved, conflicts documented, and the complainant kept informed where appropriate. Consequential decisions require authorised human review.

7. Closure and review

Resolution, closure and re-opening actions should be recorded. Material changes should create new audit events rather than silently rewriting history.

8. Protected disclosures

Do not assume every complaint is a statutory whistleblower disclosure. Reports that may qualify should be restricted to an authorised eligible recipient and escalated for specialist/legal review.