Complaints Handling  Policy

1. Purpose

FundsConnect Platform Pty Ltd is committed to handling complaints fairly, efficiently, and in a timely manner. This Policy sets out how we receive, manage, and resolve complaints about our technology platform services. While FundsConnect is not required to comply with ASIC Regulatory Guide 271 (Internal Dispute Resolution) as it does not hold an Australian Credit Licence or Australian Financial Services Licence, we adopt best-practice complaints handling consistent with the principles of RG 271 as a matter of good governance.

2. Scope

2.1 Complaints FundsConnect Will Handle

This Policy covers complaints relating to:

• The operation, functionality, or availability of the FundsConnect platform
• Platform account administration, registration, or access issues
• Commission calculations, commission payments, or commission disputes
• Lender matching results or comparison outputs
• Data handling or privacy concerns relating to information held by FundsConnect
• Conduct of FundsConnect staff or representatives
• Platform Terms of Service matters
• Website content or functionality

2.2 Scope of Platform Services

FundsConnect provides technology services exclusively for commercial and investment-purpose lending. All borrowers accessing funding through the Platform are either companies or corporate trustees. All transactions are business or investment purpose private credit transactions with terms of 1 to 36 months. These transactions are entirely outside the National Consumer Credit Protection Act 2009 (Cth) and the National Credit Code.

FundsConnect is not a lender and does not make lending decisions. The Platform facilitates connections between registered brokers and private credit lenders. Any complaint relating to a lending decision, loan terms, or lender conduct must be directed to the relevant lender directly.

3. What is a Complaint?

A complaint is an expression of dissatisfaction made to FundsConnect, related to our platform services, where a response or resolution is explicitly or implicitly expected. A complaint may be made verbally or in writing.

A complaint does not include: routine service requests, technical support enquiries (unless a response is overdue), or general feedback or suggestions.

4. How to Lodge a Complaint

You can lodge a complaint with FundsConnect by:

When lodging a complaint, please provide: your name and contact details, a description of the issue, the outcome you are seeking, and any relevant reference numbers or documents.

5. Our Complaints Process

Step 1: Acknowledgement

We will acknowledge receipt of your complaint within 1 business day (or as soon as practicable) and provide you with a complaint reference number and the name of the person handling your complaint.

Step 2: Assessment and Investigation

We will assess your complaint and determine the appropriate course of action. This may involve reviewing platform records, speaking with relevant staff, and contacting you for additional information. We will keep you informed of progress.

Step 3: Resolution

We aim to resolve most complaints within 30 calendar days. If we need more time due to the complexity of the complaint, we will inform you of the reason for the delay, provide an expected timeframe, and keep you updated at least every 10 business days.

Step 4: Written Response

Once we have reached a resolution, we will provide you with a written response setting out: a summary of the complaint, our findings, the outcome or proposed resolution, and your options if you are not satisfied.

6. If You Are Not Satisfied

You may request that your complaint be escalated to a senior manager or director of FundsConnect for review.

6.2 External Dispute Resolution

As FundsConnect does not hold an Australian Credit Licence or Australian Financial Services Licence, and all Platform transactions are outside the National Consumer Credit Protection Act 2009 (Cth), complaints about our technology platform services are not within the jurisdiction of the Australian Financial Complaints Authority (AFCA). If you remain dissatisfied after exhausting our internal complaints process, you may:

• Seek independent legal advice\
• Contact the relevant state or territory fair trading body or small business commissioner
• Contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au for complaints relating to privacy matters

7. Complaints Register

FundsConnect maintains a Complaints Register recording all complaints received, including the date, nature of the complaint, actions taken, outcome, and timeframes. The Register is reviewed quarterly by management to identify systemic issues and opportunities for improvement.

8. Review of This Policy

This Policy is reviewed at least annually and updated as necessary to reflect changes in best practice, regulatory expectations, or business operations.