Bristow & Sutor Group (hereinafter referred to as “BSG”, “we”, or “us”) comprises Bristow & Sutor, Debt Recovery Plus Ltd., and Credit Style Ltd.

BSG aims to achieve the highest possible standards in all areas of our business, and particularly in dealing with our customers and with those we contact regarding accounts we are collecting. There are of course times when things go wrong. We treat all expressions of dissatisfaction with our service seriously and we seek feedback from our customers and clients so that we can respond effectively and make improvements where necessary.

This policy outlines our commitment to receiving, addressing, and acting upon the feedback we receive via complaints to continually improve the way we deliver our services.

All companies will receive complaints from time to time, and it is vital that we use the information provided by our complaints to inform the way we develop our services. As we deal with a range of debt types across our different teams and locations, it is also important that we ensure that all complaints are dealt with fairly, accurately, and consistently, regardless of how the complaint is received or what it relates to. This policy is supported by our Complaints Procedure documents, which lay out in detail the process that each debt type follows as this may differ due to regulatory or industry requirements; however, in all cases our procedures are governed by the overarching principles outlined in this policy.

Complaints can be made via any channel by which we communicate to customers, clients, and third parties. This includes by telephone, by email, via our website contact form, by webchat, by post, by SMS and by WhatsApp where available.

If you, as the complainant require support in making a complaint, you can contact us via any channel and one of our colleagues would be pleased to assist you. This includes by telephone, by email, via our website contact form, by webchat, by post, by SMS and by WhatsApp.

When a customer expresses dissatisfaction with our service, the colleague who receives the communication will try to resolve it immediately where possible on the day of receipt. Where immediate resolution is not possible, the expression of dissatisfaction is escalated to an appropriate subject matter expert or manager who will try to resolve the matter without the need for the formal complaints process within a maximum of 3 working days.

In cases where neither the recipient nor the subject matter expert or manager can resolve the matter, the complaint is escalated to the Customer Resolution Team, which will issue an acknowledgment of the complaint within a reasonable timeframe. At this point, the complaint enters the relevant Complaints Investigation Procedure for the case debt type which can be found in that debt type’s Procedure document. The colleague that escalates the complaint to the Complaints Team has the responsibility to ensure it is correctly logged, and that the case is placed on hold while the complaint is investigated.

With all complaints, our aim must be to resolve the issue as early in the process as possible while ensuring the complaint is fully investigated. Where appropriate we will seek to resolve the complaint by telephone, as this affords the opportunity to provide a more personal and empathetic response in the quickest possible time. In circumstances where this is not possible, then complaints will be responded to in writing.

The formal stage lasts 20 working days, during this period the Customer Resolution Specialist investigates the complaint and will issue a full response. If any further clarification or investigation is needed in order to resolve the complaint this will take place during that 20-working day period, with an aim to resolve the complaint at this stage. Where it is not possible to complete a satisfactory investigation within that time, the Customer Resolution Specialist sends a holding communication to the complainant, outlining the reason for the delay and confirming the timescale for a full response.

If you, as the complainant, are dissatisfied with the response at the end of this period, you can request for the complaint to be reviewed by The Enforcement Conduct Board. This request can come via any communication channel.

The Customer Resolution Specialist investigates the complaint and issues a full response to you (as the complainant) within ten days. Where it is not possible to complete a satisfactory investigation within that time, the Customer Resolution Specialist sends a holding communication to you as the complainant, outlining the reason for the delay and confirming the timescale for a full response. If you (as the complainant) are dissatisfied with the response at this stage, you can request for the complaint to be escalated to Stage 2. This request can come via any communication channel outlined in paragraph 4 above.

The complaint is escalated to the Group Head of Customer Services who reviews the original complaint, the investigation and the Stage 1 response, and issues a full response to the complainant within ten days. Where it is not possible to complete a satisfactory investigation within that time, a holding communication will be sent to the complainant, outlining the reason for the delay and confirming the timescale for a full response.

If you (as the complainant) are dissatisfied with the response at this stage, you can request for the complaint to be escalated to Stage 3. This request can come via any communication channel as set out above.

The complaint is escalated to the Chief Operating Officer who reviews the original complaint, the investigation and the Stage 2 response, and issues a full response to the complainant within a maximum of ten days. Where it is not possible to complete a satisfactory investigation within that time, a holding communication will be sent to the complainant, outlining the reason for the delay and confirming the timescale for a full response.

The complaint is reviewed by a Customer Resolution Specialist who acknowledges the complaint within 5 working days. The Customer Resolution Specialist conducts a full investigation into the complaint with the applicable Line Manager and any other relevant colleagues. The Customer Resolution Specialist completes the Complaint Investigation Record, and issues a full response to the complainant within a maximum of four weeks. This Final Response will include details of the complaint, the investigation, and the actions taken to resolve it. It will also include information about the complainant’s rights under the Financial Ombudsman Service, or the Legal Ombudsman Service where the complaint relates to Legal Services.

Where it is not possible to complete a satisfactory investigation within four weeks, the Customer Resolution Specialist sends a holding communication to you within 15 days, as the complainant, outlining the reason for the delay and confirming the timescale for a full response. If a Final Response is not issued within eight weeks, you (as the complainant) will receive regular updates from us until the complaint is satisfactorily resolved. These updates will include details of your rights as the complainant under the Financial Ombudsman Service, or the Legal Ombudsman Service where the complaint relates to Legal Services.

Whether or not a complaint reaches the formal investigation process, it is recorded using the Complaints Recording Spreadsheet. The responsibility for initially recording a complaint lies with the colleague that receives the complaint, and the record is updated at every stage of the process to document the responsible party at each stage.

All complaints that progress to the formal investigation process are investigated using the Complaint Investigation Record. This record and any additional supporting information are saved to the case file. Records of all complaints are kept for three years.

Sometimes we may receive complaints from customers relating to our client, or we may be told that our customer has lodged a complaint with our client directly. In these cases, we will ensure we pass this information to our client and place the case on hold until the complaint is investigated.

Where the client is FCA regulated, or where requested by the customer, this will be confirmed in writing.

While we strive to resolve all complaints that are raised to us through our complaints process, in some cases complainants may feel we are unable to deal with the complaint to their satisfaction. In these cases, we provide information about external escalation routes which are suitable for their case type.

Local Authority Debts or Local Government Body (Council Tax, Non-Domestic Rates, Penalty Charge Notices, Commercial Rent Arrears)

Complainants can progress their complaint to:

Enforcement Conduct Board

By email to contact@enforcementconductboard.org

Via their website by visiting https://enforcementconductboard.org

By post to Enforcement Conduct Board
10 Queen Street
London
EC4R 1BE

The Local Authority that instructed us to recover the debt.

If you need assistance on contacting the Local Authority, we will be happy to help. You can contact us by telephone, by email, via our website contact form, by webchat, by post, by SMS and by WhatsApp.

Local Government and Social Care Ombudsman (LGSCO)

Via their website by visiting https://www.lgo.org.uk

By telephone on 0300 061 0614

By post to Local Government and Social Care Ombudsman
PO Box 4771
Coventry
CV4 0EH

Public Services Ombudsman for Wales (PSOW)

Via their website by visiting https://ombudsman.wales

By telephone on 0300 061 790 0203

By post to Public Services Ombudsman for Wales
1 Ffordd yr Hen Gae
Pencoed
CF35 5LJ

Escalation to the Enforcement Conduct Board or to the Local Authority does not affect your right to escalate your complaint to the Local Government and Social Care Ombudsman (LGSCO) / Public Services Ombudsman for Wales (PSOW). The Enforcement Conduct Board may also refer the complainant directly to the LGSCO/PSOW where it is deemed appropriate to do so.

High Court Writs of Control

Complaints that relate to the action of the Enforcement Agent or Enforcement Agent firm to:

Enforcement Conduct Board

By email to contact@enforcementconductboard.org

Via their website by visiting https://enforcementconductboard.org

By post to Enforcement Conduct Board
10 Queen Street
London
EC4R 1BE

A dispute about the contractual obligations and commercial agreements that exist between the creditor and the accredited firm to:

High Court Enforcement Officers Association

Bristow & Sutor Group abides by the Code of Best Practice issued by the High Court Enforcement Officers Association (HCEOA). If the complaint relates to the enforcement of a High Court writ, the complainant can refer their complaint to the HCEOA. The complaint must be directed in the first instance to Bristow & Sutor Group for consideration and the complaints process exhausted before the HCEOA will take on the complaint. Full details on making a complaint to the HCEOA can be found at the following website: https://www.hceoa.org.uk/about-us/make-a-complaint

All complaints must be submitted in writing within 12 months of the date of the incident to:

By post to The Complaints Officer/Secretary
High Court Enforcement Officers Association
Suite S31, Northwich Business Centre
Meadow Street
Northwich
Cheshire
CW9 5BF

By email to complaints@hceoa.org.uk

If a written complaint cannot be made to the HCEOA’s Complaints Officer/Secretary (for example, if the complainant has a disability), please call 0844 824 4575 and a written record of the complaint will be made.

Private Parking (Parking Charge)

If the parking company who issued the original Parking Charge is a member of the British Parking Association (BPA): By telephone on 01444 447 300

By email to info@britishparking.co.uk

Via their website by visiting https://portal.britishparking.co.uk/compliance/LogComplaint

By post to: British Parking Association
Stuart House
41-43 Perrymount Road
Haywards Heath
Sussex
RH16 3BN

If the parking company who issued the original Parking Charge Notice is a member of the International Parking Community (IPC):

By telephone on 01565 655 467

Via their website by visiting https://theipc.info/login/complaints

By post to The International Parking Community
PO Box 431
Knutsford
Cheshire
WA16 1EP

Consumer Credit Agreements

Credit Style Limited is regulated by the Financial Conduct Authority for agreements formed under the Consumer Credit Act 1974 (as amended). If the complaint relates to a Consumer Credit Agreement, such as a loan or finance agreement, you, as the complainant, can refer your complaint to the Financial Ombudsman Service. This must be done within six months of the date of our final response.

By telephone on 0800 023 4567

Via their website by visiting https://www.financial-ombudsman.org.uk/contacthttps://www.financial-ombudsman.org.uk/contact-us/complain-onlineus/complain-online

Credit Services Association

Credit Style Limited is a full member of the Credit Services Association and abides by its Code of Conduct. If the account is a private sector debt, but does not relate to a Consumer Credit Agreement, you (as the complainant) can refer you complaint to the Credit Services Association. Complaints must include a signed complaints form which can be downloaded from the following website: https://www.csa-uk.com/page/complaint

If you, as the complainant, aren’t able to submit your complaint in writing, you can contact the CSA to discuss this further.

By telephone on 0191 217 0775

By email to info@csa-uk.com

Information Commissioner’s Office

If the complaint relates to how or why we are processing your personal information as an individual, we have very able data protection teams and a Data Protection Officer and, in the vast majority of situations, will make best efforts to resolve the complaint ourselves. However, in the unusual situation where we are not able to resolve the issue, you should refer the complainant to the website of the Information Commissioner’s Office (ICO) at https://ico.org.uk/

Legal Ombudsman Service

If the complaint relates to legal services we have provided to you, the Legal Ombudsman can help you if we are unable to resolve your complaint ourselves. They will look at your complaint independently and it will not affect how we handle your case. Before accepting a complaint for investigation, the Legal Ombudsman will check that you have tried to resolve your complaint with us first. If you have, then you must take your complaint to the Legal Ombudsman:

• Within 6 months of receiving a final response to your complaint; and,
• No more than 1 year from the date of act/omission; or,
• No more than 1 year from when you should reasonably have known there was cause for complaint.

By telephone on 0300 555 0333

By email to enquiries@legalombudsman.org.uk

By post to Legal Ombudsman
PO Box 6167
Slough
SL1 0EH

Solicitors Regulation Authority

If your complaint relates to our behaviour as providers of legal services, for example if you believe we have behaved dishonestly, taken or lost your money, or treated you unfairly due to a protected characteristic, you can raise your concerns with the Solicitors Regulation Authority. More information is available on their website at: https://www.sra.org.uk/consumers/problems/report-solicitor/

Bristow & Sutor Group recognizes that complaints can come from a variety of different sources, and we have briefly outlined how our policy applies to each of these parties below.

Customer Complaints

Complaints may be made by customers who we contact in order to resolve debts in their name.

Client Complaints

Complaints may be made by clients who have instructed us to resolve debts on their behalf.

Third Party Complaints

Complaints may be made by individuals or organisations who are not directly connected to a case but have been affected by the actions of our business, or who are complaining on behalf of someone who has.

Anonymous Complaints

Anonymous complaints will be investigated as far as is possible and a record of the complaint will be kept in accordance with our normal procedure.

This policy is related to and impacted by our Customer Service Framework and our Group Vulnerability Policy. It is applied in tandem with the Complaints Procedure documents.

Feedback and lessons learned from complaints will be provided to those involved in handling cases which gave rise to complaints via their manager on a timely basis.

Complaints are analysed for trends and common causes by Customer Resolution Specialists in conjunction with the Customer Resolution Manager and reported monthly to the Operations Senior Leadership Team to identify actions that can be taken to prevent the occurrence of similar complaints, and to continually improve our internal processes, training and the Complaints Process. Actions resulting from this analysis are tracked and reported by the Customer Feedback Manager, with escalation to the Group Head of Customer Services and Chief Operating Officer where necessary.

A complaint summary detailing relevant trends such as the volume of complaints as a percentage of total caseload and upheld vs not found will be reported to the Risk, Audit and Compliance Committee. All customer-facing colleagues and Customer Resolution Specialists receive annual complaint-handling training to ensure complaints are managed effectively.

Complaint responses will be regularly checked for quality and accuracy by the Customer Resolution Manager. This policy will be reviewed annually in line with an overview of the year’s complaints to ensure it remains effective and fit for purpose.

Bristow & Sutor Group deals with a range of scenarios that can give rise to disputes; however, it is important to recognize that a dispute is not a complaint, and the resolution process is therefore different.

A dispute is a disagreement with certain facts of the debt itself. A dispute may include:

• Disputing the merits of a parking charge notice or penalty charge notice that has been registered against the customer.
• Disputing the customer liability for a debt that we are collecting.

Disputes do not constitute a complaint against our services and therefore cannot be resolved through the complaints process. Disputes should be dealt with as part of our normal customer service conversations.

A grumble is a communication received about dissatisfaction with our service or colleague which does not seek redress. A grumble may include:

• A customer mentions the length of time they were waiting for the phone to be answered.
• A customer mentions they found it difficult to find information on our website.

Grumbles do not require elevation to the complaints process but provide a key source of feedback on friction in the customer experience and offer us additional opportunities for improvement.

A complaint is a communication received about dissatisfaction with our service or colleagues which seeks redress. A complaint may include:

• We have failed to do something we agreed to do.
• We have not acted within regulatory requirements.
• We have treated a complainant unfairly or rudely.
• We fail to provide information.
• The complainant is concerned with the quality of the service we provide.

For the areas of our business which are regulated by the Financial Conduct Authority, we use their definition of a complaint, which states:

“Any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, or failure to provide, a financial service, claims management service or a redress determination, which:
(a) alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience; and
(b) relates to an activity of that respondent, or of any other respondent with whom that respondent has some connection in marketing or providing financial services or products or claims management services, which comes under the jurisdiction of the Financial Ombudsman Service.”

In order to be an FCA regulated complaint, the complainant must allege that they have suffered (or may suffer) one of the below:

• Financial loss – An example would be incurring bank charges as a result of our actions.
• Material distress – An example of material distress is a customer feeling highly stressed due to our collection strategy or the consequences of our actions could result in the customer feeling ill or not being able to sleep due to the worry.
• Material Inconvenience – An example of this would be a customer having to wait so long on hold that they missed an appointment.

The complaint must also be from someone who the Financial Ombudsman Service have jurisdiction over. This means any consumer accounts and the below guidelines for businesses:

If the complaint is about an event that took place before 1st April 2019, then complaints from micro-enterprises, which means a business with:

• a turnover or annual balance sheet that does not exceed two million euros and
• fewer than 10 employees.

Or, if the complaint is for events that took place after 1st April 2019, we can also deal with complaints from small businesses that have:

• an annual turnover of less than £6.5 million (or its equivalent in any other currency); and either:
• a balance sheet total of less than £5 million (or its equivalent in any other currency); or
• fewer than 50 employees.