Astat Complaints Procedure

Policy Name
Astat Complaints Procedure Guidance
Policy Number
02
Date of Last Revision
17.09.2021
Effective Date
10.08.2021
Version Number
Caroline Hunter
legal@astat.app
Caroline Hunter
Contact
legal@astat.app

Table Of Contents

PURPOSE

PROCEDURE

REPORTING

TIMELINE

ESCALATIONS TO ASTAT

IMMEDIATE ESCALATION

FURTHER ESCALATIONS

RECORD KEEPING             

3

3

5

5

5

5

7

7

Introduction to document

Complaint Procedures

It is the policy of Astat to respond to customer complaints, disputes and issues swiftly and to
take each complaint seriously. Astat promotes a quick, decisive and accurate response to all
inquiries, questions and concerns brought to our attention. Not all of these situations are in the
form of a written complaint presented to the bank by a customer.

Purpose

The purpose of this procedure is to give guidance in order to ensure any complaints received by
Astats Clients / Program Managers (Astats customer service team) are dealt with in a timely
manner and are resolved to the customer’s satisfaction.

Definiton of a Complaint

Any expression of dissatisfaction, justified or not, that the customer service team is unable to
resolve or which the customer requires to be escalated by the formal complaints procedure.

Procedure

All complaints should be first directed to the appropriate Customer Service Team at Astat, in an
effort to resolve any issues quickly and amicably. (This can be done via our Intercom, customer
service number or hello@astat.app)

(Should a complaint be first directed to Astat, this will be redirected to the appropriate person in
order for them to have the opportunity to resolve the complaint, the complaint will still be
registered and a follow-up requested from the customer success Manager.)

RAISING A COMPLAINT

A complaint can be sent via our chat or customer service. A formal complaint should be sent by
email to hello@astat.app and the customer will receive a confirmation of the complaint when
registered and get followed up on the procedure by email, within 24 hours.

Note: Complaints are to be raised in writing, however verbal complaints will be accepted and
dealt with as per the same procedures.

If a customer calls in to complain to customer service, they should be passed through to a leader
or senior member of the staff who will try to resolve the complaint then and there.

Even if the complaint is resolved on the phone, the customer must still be offered the option of
receiving the complaint form by email with a finished conclusion in writing. The complaint form is
to be logged and retained in the complaints record.

ACKNOWLEDGEMENT

An acknowledgement to a customer's complaint is to be sent within 24 hours of receipt, the
acknowledgement should also advise the complaint reference number to be used within all
correspondence, along with the expected timeline. E.g.

Subject – Complaint Acknowledgement – Reference - xxxx

Dear (card holder name)

Thank you for your email.

Your complaint has been registered with us and allocated with reference number xxxx.
We will fully investigate your concerns and a response will be issued to you within 14
days of the customer success manager receiving your complaint.

Kind Regards

PROCESS

The complaint is to be registered in a Complaints Register detailing the complaint typology along
with a brief description and the date on which the complaint was received. All correspondence
should be stored together and an investigation should be undertaken in order to resolve the
complaint.

INFORMAL COMPLAINT RESOLUTION

Astat considers and responds to all complaints and issues, no matter how they are raised or what
they refer to. Some issues and complaints we can resolve immediately or within a 2-working day
timeframe and are referred to asinformal complaints.Such instances are where an investigation
is not required because the nature of the complaint is clear, and a resolution can be obtained
without further review of the facts. When we resolve a complaint within the timeframe, the details
are still logged on our complaint register, and the complainant is still informed of their rights.

Astat takes every opportunity to resolve complaints at the first initial point of contact where
feasible and possible. Informal resolution is always attempted where the issues raised are
straightforward and potentially easily resolved, requiring little or no investigation. Most chat and telephone issues can be resolved in this manner, however the complainant is always offered the
option of making the complaint formal if the resolution is not to their satisfaction.

Where an informal complaint is received, it is acceptable for the point of contact or addressed
employee to attempt to resolve the issue without involving the leader. However, any issue relating
to data protection infringes or breaches, no matter how small or informal, are always brought to
the attention of the leader group or appointed person.

Support staff are trained to deal with basic issues and informal complaint resolution and are
aware of their obligations and the subsequent reporting lines. Such employees are equipped to
attempt to resolve a complaint relevant to their area of service or expertise, wherever possible.

REPORTING

Astat requests that Clients/Program Managers advise on a monthly basis, the complaints
received in the preceding month. This can be reported within the Monthly Compliance Report.

TIMELINE

Complaints are to be acknowledged within 24 hours working days of receipt.

Every possible effort should be made to respond to the complainant, addressing all points raised,
within an adequate time frame and at the latest within 14 business days of receipt of the
complaint.

If the answer cannot be given within 14 working days for reasons beyond the control of the
Program Complaint Manager, an email is to be sent to the complainant clearly indicating the
reasons for a delay in responding to the complaint and specifying the deadline by which the
complainant will receive the final reply (a further 20 business days), the complainant should also
be advised that the complaint has been escalated to the issuer.

Astat AS are to be notified at this stage that a complaint has been raised, as well as the
timeframe that has passed, the notification should advise the details of the complaint and an
explanation as to why the complaint cannot be resolved. All communication to (and from) the
complainant should also be sent along with any transactional information, where applicable.

At such time the Program Manager should stop all communications to the complainant.

Astat will advise the complainant that the complaint has been escalated, as well as the expected
timeline (a further 20 business days) for the resolution of the complaint.

Astat will investigate the complaint, with the help of the Program Manager’s Complaints
department and respond to the complainant (and the Program Manager) with our findings.
In any event, the deadline for receiving the final reply from Astat shall not exceed 35 business
days from the date the complaint was first made.

TIMELINE FOR INFORMAL RESOLUTION

It is the aim of Astat to resolve informal complaints immediately, or at least within the first 24-hours.
Such complaints and issues will have a quick, but informative response and do not need to have an
investigation or enter the formal complaint process.

No matter how small or informal the complaint, if a satisfactory resolution has not been achieved
within 3 working days of the complaint being raised or identified, the issue is passed to the Complaints
Officer to enter the formal complaint process.

ESCALATIONS TO TPL/TPML

The email address for complaint escalations iscomplaints@transactpaymentslimited.com.This is
also listed on TPL’s Client Terms & Conditions for complaint escalations , therefore, on occasion,
an email may be received by TPL which is not considered a complaint but an enquiry which is
best dealt with by the appropriate Customer Service Team. At such time, this will be forwarded to
the client/PM contact in a timely manner, requesting that they contact the cardholder directly. A
response should also be sent to the cardholder advising the same.

IMMEDIATE ESCALATION

There may be cases which require escalation to TPL’s Compliance Team immediately, the
following are examples of when a Complaint should be escalated, at such time the Customer
Services Team should stop all communications with the customer unless otherwise requested by
the TPL Compliance Team.

  • Violation of Law Complaint
  • Threat of Legal Action
  • Regulatory Body Inquiry
  • Threat of Violence or Bodily Harm
  • Systemic Errors impacting multiple accounts
  • Consumer Protection Authority Referral

Or via email - psdcomplaints@fsc.gi.

TPML Escalations Process for European Issuance:
Should TPML be unable to resolve a customer’s complaint to their satisfaction they can refer their
complaint to TPML’s regulator: Malta Financial Services Authority:
Office of the Arbiter for Financial Services on+35680072366or+356 21249245. Further details
regarding the Arbiter’s complaint procedure are accessible via the Office of the Financial Services

Arbiter website:https://www.mfsa.mt/consumers/complaints/
                             https://financialarbiter.org.mt/oafs/complaint

FURTHER ESCALATIONS

Should Astat be unable to resolve a customer’s complaint to their satisfaction they can refer their
complaint to Astat’s regulator.

RECORD KEEPING

Records are to be kept for at least 5 years following the end of the relationship and is compliant
according to Norwegian GDPR regulations.

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