Complaint Management Policy

Wahed Invest (Pty) Ltd (hereinafter referred to as "Wahed" or "the Firm") is a Financial Services Provider ("FSP") duly authorized, licensed and regulated by the Financial Sector Conduct Authority (FSCA) in South Africa (FSP Number: 51684) to provide financial advisory and intermediary services.

Purpose

This policy outlines the process and procedures for the fair, timely, and transparent resolution of disputes and complaints involving clients, investors, and other stakeholders, in compliance with:

• The FSCA's Complaints Management Framework (as per the General Code of Conduct)
• All applicable regulatory guidelines issued by the FSCA

Scope

This policy applies to:

1. All clients and investors dealing with Wahed Invest (Pty) Ltd
2. All staff members directly or indirectly involved in complaints handling
3. All authorized representatives and service providers acting on behalf of the Firm
4. All complaints relating to services provided by the Firm

Lodging Complaints

Clients may lodge complaints at no cost via email at: zafsupport@wahed.com 

Key Individual | Complaints Officer

Alternatively, clients may lodge complaints at no cost, via email, with the Key Individual or Complaints Officer at: zaf.key@wahed.com‍

Complaints Management Framework

(A) Internal Complaints Handling

1. Receipt and Acknowledgement

• All complaints submitted via email shall be received by the Key Individual or Complaints Officer or designated Client Support team member.
• The Key Individual or Complaints Officer shall send written acknowledgement to the complainant:
  
  • Via Email: Within 2 (two) working days of receipt
  • Acknowledgement shall reference a unique Complaint Reference Number

2. SOP: Complaint Registration and Recording

All complaints received through any channel must be recorded promptly in the Complaints Register maintained by the Key Individual or Compliance Officer.

A unique Complaint Reference Number must be allocated immediately upon registration.

The following minimum details must be recorded:

• Complaint Reference Number
• Date complaint received
• Complainant name and contact details
• Nature of complaint
• Root cause of the complaint
• Full details of complaint
• Date assigned to responsible department
• Action taken
• Resolution status and resolution date

The complaint must be assigned to the appropriate responsible department without undue delay.

The Complaints Register must be updated each time a material action is taken on the complaint.

No complaint may be regarded as closed unless the outcome, action taken, resolution status, and closure date have been recorded.

Where a complaint indicates possible fraud, impersonation, unusual transaction activity, sanctions exposure, or CDD/EDD concerns, the matter must be escalated immediately to the Key Individual for review.

The Key Individual or Compliance Officer must conduct periodic reviews of the Complaints Register to ensure completeness, accuracy, timely allocation, and proper closure of all complaints.

All client-facing and operations staff must be trained on complaint identification, immediate registration, and mandatory data fields.

Refresher training is to be conducted at least annually and after any material complaint-handling failure.

(The Complaints Register format is detailed in Annexure 1)

3. Classification and Escalation

The Complaints Officer shall classify complaints based on:

• Nature: General inquiry, technical issue, service failure, fraud/misconduct, data protection, or other
• Urgency: Low Priority (General Complaints) or High Priority
• Department: Operations, Compliance, Data Protection Officer, Management, or Board (if applicable)

Complaints shall be escalated to relevant departments on a daily basis.

4. Resolution of General Complaints

General complaints (Examples: onboarding issues, login problems, portfolio guidance) that do not involve potential fraud or misconduct shall be:

• Investigated by the appropriate department
• Resolved where possible within 10 (ten) working days
• Communicated to the complainant with explanation of resolution
• Confirmed in writing to the complainant
• Where resolution is not achieved within 10 (ten) working days, the complaint may be escalated as detailed in the Escalation Procedure section.

5. Resolution of High-Priority Complaints

High-priority complaints (including potential fraud, suspected misconduct, monetary loss, or system failures affecting multiple clients) shall be:

• Immediately escalated to the Compliance Officer 
• Investigated thoroughly with documented findings
• Resolved or referred within 10 (ten) working days of receipt
• Notified to the FSCA within 2 (two) working days of resolution or referral

6. Financial Sector Conduct Authority (FSCA) Notification Requirements

Where a complaint:

• Relates to suspected fraud, financial misconduct, or AML concerns,
• Involves monetary loss,
• Cannot be resolved within 10 (ten) working days; and/or
• Relates to potential regulatory breaches, then

The Compliance Officer shall notify the FSCA with:

• Full details of the complaint,
• Summary of proceedings and actions taken,
• Copies of relevant supporting documents, and
• Status of resolution or reason for referral.

(B) Escalation Procedure: Referral to the Office of the FAIS Ombud 

The Compliance Officer shall refer the complaint to the Office of the FAIS Ombud if:

1. The complaint is not resolved within 20 (twenty) working days of receipt
2. The complaint relates to:
   
   • Suspected fraud or financial crime,
   • Potential regulatory breach, and/or
   • Misconduct by the Firm or its representatives.
3. The complainant requests FAIS Ombud intervention
4. The complaint involves monetary loss and cannot be resolved internally

FAIS Ombud Referral Procedure

• The Compliance officer shall include the following in the notification via a formal email to the FAIS Ombud:
  
  • Complete complaint details
  • Summary of investigation findings
  • Copies of all supporting documentation
  • Explanation of escalation reasons
  • Any interim remedial actions taken

FAIS Ombud Response and Investigation

The FAIS Ombud shall:

• Acknowledge receipt of referral within 5 (five) working days
• Assess the complaint for jurisdiction within 5 (five) working days
• Conduct investigation within 30 (thirty) days (or an extended timeframe as determined by FAIS Ombud)
• Communicate findings to the Firm and complainant

FAIS Ombud Determination

The FAIS Ombud may:

• Issue remedial instructions to the Firm
• Impose sanctions or penalties
• Refer the matter to law enforcement agencies
• Dismiss the complaint if outside jurisdiction

Engagement with FAIS Ombud by the complainant

If a complaint is not resolved to the complainant's satisfaction, the complainant has the right to independently approach the FAIS Ombud, an independent, impartial dispute resolution service.

FAIS Ombud Contact Details

• Website: www.faisombud.co.za
• Email: info@faisombud.co.za
• Telephone: +27 (0)12 762 5000

FAIS Ombud Engagement

Wahed Invest (Pty) Ltd:

• Recognizes the jurisdiction of the FAIS Ombud
• Commits to engaging transparently with the FAIS Ombud
• Shall implement FAIS Ombud determinations

Record-Keeping and Reporting | Complaint Register Maintenance

The Compliance Officer shall:

• Maintain an electronic Complaints Register (Annexure 1)
• Ensure accurate and timely recording of all complaint details
• Update register with resolution status and outcomes
• Retain records in secure, confidential manner

Retention Period

All complaint records shall be retained for a minimum of 5 (five) years from date of complaint receipt, in accordance with FSCA requirements.

Reporting Obligations: Quarterly Reporting to FSCA

The Compliance Officer shall submit quarterly reports to the FSCA containing:

• Total number of complaints received in quarter
• Categorization of complaints by type
• Number of complaints resolved and timeframes
• Number of complaints escalated to FSCA
• Status of unresolved complaints
• Complaint trend analysis
• Any systemic issues identified

Assessment and Monitoring

• All complaints received by the firm shall be assessed to determine the appropriate resolution path.
• Complaints falling outside the Firm’s jurisdiction will be referred to the appropriate authority or regulator.
• A regular review of complaint trends and outcomes shall be conducted to improve customer service and risk management processes.

Training and Awareness

All staff involved in handling complaints shall receive ongoing training to ensure effective complaint resolution in line with regulatory requirements.

Review of Policy

This policy shall be reviewed annually or upon significant regulatory changes as may be advised by the FSCA or relevant authorities.

Annexure 1

Example of the “Complaints Register”

Complaints Register

Date Received

Complaint ID

Complainant Name

Complainant Contact and phone number

Complaint Type

Against (Entity/Person)

Details of Complaint

Action Taken

Resolution Status

Date Resolved

Escalated (Yes/No)

Escalation to other Unit/Department

Escalation Date

Referred To

Remarks

1

2

3