Complaints Handling Policy

1. Purpose

1.1 Purpose

The British Business Bank plc and its subsidiaries (BBB Group) strive to deliver a fair and positive experience for all individuals engaging with their programmes. As part of this endeavour, BBB is committed to continually reviewing and improving both its offering and the way this offering is delivered. The feedback it receives whether positive or negative, is a primary way that the organisation identifies areas for improvement. For this reason, it is essential that there is a clear and effective process for capturing, responding to and resolving complaints.

The purpose and objectives of this policy are to outline the BBB Group’s approach to handling complaints. This includes what types of complaints are covered by this policy, explains how to submit a complaint and who will be responsible for reviewing complaints. This also informs how individuals can escalate their complaints and explains how complaints data is held.

This Policy has three key objectives, to:

1. Provide a clear outline about how any individual who comes into contact with the BBB Group can express their dissatisfaction.
2. Explain who should be contacted when submitting a complaint, including how and when an individual can escalate a complaint and the timescales expected for a response.
3. Explain BBB’s complaint handling process, including timescales and escalations.

This policy applies to all BBB entities, operations and subsidiaries. This Policy does not apply to the BBB Group’s Delivery Partners, Business Support Partners, or its Finance Provider (partners such as banks, lenders, leasing companies that deliver or support funding). Consequently, any complaints or disputes relating to one of BBB’s Delivery Partners, Business Support Partners, or Finance Provider should be settled directly with the relevant Delivery Partner/Business Support Partner/Finance Provider.

1.2 Legal & Regulatory Obligations

The BBB Group is not regulated by the Financial Conduct Authority (FCA).
The BBB Group will endeavour to adhere to the FCA industry and regulatory requirements where relevant and strive to deliver a fair and positive experience for all individuals engaging with the BBB Group.

1.3 Alignment to Risk Appetite

Risk appetite is the type and level of risk the Board of BBB is willing to take in order to deliver its strategy and public policy objectives.

This policy sits under the Level One Risk category, People.

It aligns to the Level Two Risk Category, Culture & Behaviours, which is defined as ‘the risk that our culture does not support and drive the appropriate colleague behaviours and decision making, negatively impacting our ability to deliver our objectives.’

BBB’s risk appetite in relation to Culture & Behaviours is set at Low.

2. Scope

This Policy applies to all BBB entities, operations, subsidiaries and Colleagues (please see Appendix C Policy Scoping in the Policy Governance Framework document).

This Policy does not apply to the BBB Group’s Delivery Partners, Business Support Partners or Finance Providers.

If you have any complaints with your Delivery Partner, Business Support Partner or Finance Provider, you should take this matter up with them directly. 

3. Key Requirements

3.1 Submitting a Complaint

Depending on what stage of a journey you are at, you may find yourself working directly with one of the BBB Group’s subsidiaries, or with one of our official partners, including our Delivery Partners, Business Support Partners and Finance Providers. For this reason and to ensure that every complaint is reviewed by the appropriate team as early as possible, we recommend individuals use the following guidance about who, when and how to submit a complaint:

3.2 Complaints Handling Process

The following process relates to complaints that are submitted pertaining to BBB and/or its subsidiaries and are within the scope of this Policy (see Section 2). Please note that, as referenced in Section 3.1, if you are submitting a complaint to a Delivery Partner, Business Support Partner or Finance Provider, you should request a copy of their specific Complaints Policy.

When BBB receives an individual’s complaint, pertaining to BBB and/or its subsidiaries and within the scope of this Policy, it will endeavour to address the matter immediately, effectively, and in a fair and reasonable manner.

If a resolution cannot be reached within three working days, we will send you a written acknowledgement. This written acknowledgement will:

• Acknowledge that a complaint has been submitted;
• Advise you that the Complaints Manager is reviewing the matter;
• Inform you that the matter will be investigated and that a Final Response will be provided in writing within eight weeks of the complaint being received (although BBB aims to resolve all matters sooner than this where possible).

From this point forward, the Complaints Manager will assume responsibility for ensuring your complaint is resolved within eight weeks. The Complaints Manager will ensure that the complaint is investigated by the appropriate individuals within this timescale.

Once the matter has been investigated and BBB Customer Relations has made a decision regarding the complaint, you will receive a written Final Response from the Complaints Manager.

This Final Response will be provided to you and will:

• Acknowledge all of the concerns within the original complaint;
• Outline the findings of the investigation;
• Clarify whether the complaint was ‘upheld’ or ‘not upheld’;
• Outline the proposed resolution (if applicable);
• Inform you that if you are not satisfied with the Final Response, you have the right to escalate the matter. You must do this within six months of receiving your Final Response.

In exceptional circumstances, the Complaints Manager may not be able to provide you with a Final Response within eight weeks. In these instances, a holding communication will be sent to you in writing.

This holding communication will:

• Inform you of the delay;
• Outline the reasons for the delay;
• Provide an expected response time for sending the Final Response.

3.3 Escalations

In the unfortunate event that you remain dissatisfied with the final outcome of your response provided by us you have the right to escalate your complaint.

If complainants are not satisfied with the response to their complaint, they may ask for the complaint to be reviewed by the BBB Complaints Escalation Panel. This must be requested in writing and no longer than six months after receipt of your final outcome.

This panel will be composed of at least two of BBB’s Senior Leadership Team, together with a representative of BBB’s Risk & Compliance team, who have no direct involvement with the issue(s) under review.

The complainant will be invited to submit any further written submissions to be reviewed by the panel.

The review should normally take place within thirty working days of receipt of the request. If this is not possible, the complainant will be informed of the review date.

The panel can:

• uphold the complaint in whole or in part;
• decide on the appropriate action to be taken to resolve the complaint;
• dismiss the complaint in whole or in part;

The complainant will be notified of the panel’s decision in writing 5 working days after the review has been completed.

Please note, if you have made a complaint directly to one of BBB’s Delivery Partners, Business Support Partner or Finance Provider, and they are regulated by the FCA, you have the right to refer the complaint to the Financial Ombudsman Service (FOS). You should be aware that FOS will refer the matter back to the relevant party to resolve if you have not engaged with that party in the first instance and there are some circumstances where they may not be able to consider the complaint. Further information in respect of the services available from FOS are available from their website: financial-ombudsman.org.uk/consumer/complaints.htm

For Future Fund, if complainants are not satisfied with the response to their complaint, they may request for the complaint to be escalated for review by the BBB Chief Risk Officer. The BBB Chief Risk Officer may elect to refer the complaint to the BBB Complaints Escalation Panel.

4. Definition of Terms

Complaints

The Financial Conduct Authority (FCA) defines a complaint as:

‘Any expression of dissatisfaction, whether oral or written, and whether justified or not, from or on behalf of a Complainant about the firm’s provision of, or failure to provide, a financial service’. 

A complaint is not restricted to a formal submission of dissatisfaction. Any individual may communicate an issue or concern at any stage of their engagement with the BBB Group, through any method and via any channel.

Delivery Partners/Business Support Partners

The BBB Group and its subsidiaries work with a network of Delivery Partner/Business Support Partner organisations that deliver or support funding to start ups or small and medium sized enterprises.

Finance Provider

Successful Start Up Loan applications are passed to SUL’s Finance Provider, The Enterprise Fund Limited t/a GC Business Finance, who are authorised and regulated by the Financial Conduct Authority (FCA). The Enterprise Fund Limited t/a GC Business Finance will administer the loan agreement and funds to successful applicants and will be the primary point of contact for matters relating to loan administration, loan status and repayment arrangements.

5. Further Information

Complaints records are kept on file for a six-year period and the BBB Group will co‐operate with any official investigations or requests for information, as required by the relevant authorities. In the case of programmes which include an element of State aid or Subsidy Control, information is expected to be kept for a minimum of 10 years.

The BBB Group will not reimburse any fees, expenses or costs involved in raising a complaint. Nothing in this policy should be interpreted to restrict any rights of redress a Complainant has in law.

The BBB Group reserves the right to take any appropriate action to protect itself from any unfounded, malicious or vexatious allegations or complaints.

The BBB Chair has delegated the responsibility for handling complaints in line with this policy, and will not respond personally to a complaint brought directly to them.  Untrue allegations could lead to legal action for defamation. This policy does not confer any contractual rights and the BBB Group reserves the right to update this policy and its key terms at any time.

The BBB Group will always respect data confidentiality and any comments complainants make about the BBB Group, its Delivery Partners, Business Support Partners or Finance Provider, and will be dealt with in accordance with current Data Protection legislation.

BBB’s Privacy Notice is available here: https://www.british-business-bank.co.uk/privacy-notice/