Customer Complaints Process and Policy

1. Our Commitment

At Pengage, we are committed to providing a professional, accurate and supportive service to all clients.

We recognise that, despite our best efforts, concerns may occasionally arise. We take complaints seriously and regard them as an opportunity to learn, improve our services and strengthen our quality assurance processes.

Our aim is to investigate complaints fairly, promptly and transparently, whilst maintaining a constructive and professional relationship with our clients wherever possible.

2. Resolution Before Complaint

We encourage clients to raise any concerns with us as soon as possible.

Many issues arise from misunderstandings, incomplete information, requests for clarification, or differing expectations and can often be resolved quickly without the need for a formal complaints investigation.

The raising of a query, request for clarification, or expression of dissatisfaction will not automatically be treated as a formal complaint unless:

• The client requests that the matter be treated as a formal complaint; or
• Pengage considers that the issue requires formal investigation.

Where appropriate, we will seek to resolve concerns informally before commencing the formal complaints process.

3. What Is a Complaint?

A complaint is an expression of dissatisfaction about the service provided by Pengage where the client wishes the matter to be investigated and responded to, or where they believe an error, omission, service failure or other issue has occurred.

A complaint will normally identify:

• The aspect of the service considered unsatisfactory
• The reason for the dissatisfaction
• Any impact on the client
• The outcome or resolution being sought, where known
• Pengage will normally only consider complaints raised within 12 months of the event giving rise to the complaint or, where later, within 12 months of the client becoming aware of the issue. We reserve the right not to investigate complaints submitted outside this period, unless there are exceptional circumstances
• Anonymous complaints may be considered at Pengage’s discretion. However, our ability to investigate and respond may be limited where we are unable to verify the identity of the complainant or obtain further information

Not every expression of dissatisfaction will be treated as a formal complaint.

Clients may occasionally express frustration, disappointment or concerns without identifying a specific issue requiring investigation or indicating that they wish to make a formal complaint. Such matters will usually be treated as feedback rather than complaints.

The following would not normally be treated as formal complaints:

• Requests for clarification or additional information
• General feedback, comments or suggestions for improvement
• Expressions of frustration where no specific service issue requiring investigation has been identified
• Disagreement with pension scheme rules, legislation or decisions made by third parties
• Matters that are currently the subject of legal proceedings
• Concerns relating to third-party organisations over which Pengage has no control
• Pengage reserves the right not to investigate complaints that have previously been fully investigated and responded to, unless new and material information becomes available.

Where concerns are raised informally, Pengage will seek to address them promptly and constructively. If the client requests a formal investigation, or if Pengage considers that a formal investigation is appropriate, the matter will be dealt with under this procedure.

4. Relationship to Our Terms and Conditions

This Complaints Procedure should be read alongside Pengage’s Terms and Conditions and any service-specific documentation provided to the client.

When investigating a complaint, Pengage will consider:

• The scope of work agreed with the client
• Any assumptions, limitations, exclusions or disclaimers communicated during the engagement
• Information and documentation provided by the client
• Relevant legislation, scheme regulations and guidance applicable at the time
• The standards reasonably expected of the service purchased
• Complaint records will be retained in accordance with Pengage’s data retention policies and applicable data protection requirements

A complaint will not be upheld solely because a client disagrees with information provided, is dissatisfied with a pension scheme outcome, or had expectations which fell outside the agreed scope of the service.

The complaints process is not intended to provide a mechanism for obtaining a second opinion on pension matters, reopening previously completed advisory work, or requesting additional services beyond the agreed scope of engagement without charge. Complaints will be assessed against the service purchased, the information available at the time, and the agreed scope of work

5. How to Make a Complaint

Complaints should preferably be submitted in writing and include:

• Your name and contact details
• A description of the complaint
• Any relevant supporting information
• The outcome you are seeking, if known

Complaints should be submitted to:

Email: hello@pengage.co.uk with the subject heading ‘complaint’.

If you require assistance in making a complaint, please let us know and we will make reasonable efforts to accommodate your needs.

6. Stage 1: Business Manager Review

Upon receipt of a formal complaint:

• We will acknowledge your complaint within five working days.
• The complaint will be reviewed and investigated by the Business Manager.
• We may contact you to obtain further information or clarification where necessary.

A written response will normally be provided within 20 working days. Where additional time is required due to the complexity of the complaint, the volume of documentation, staff availability, or the need to obtain information from the client or third parties, we will keep the client informed and provide an updated timescale.

Following the issue of Pengage’s response, the complaint will remain open for a period of three months to allow the client an opportunity to raise any outstanding concerns or provide any material information that was not previously available.

If we do not hear from the client within three months of the date of our response, we will assume that the complaint is not being pursued further and the complaint will be formally closed.

Any correspondence received after this period will be considered on its own merits. Pengage reserves the right not to reopen a complaint that has already been fully investigated and responded to

The Stage 1 response will include:

• A summary of the complaint
• Details of the investigation undertaken
• The findings reached
• Whether the complaint is upheld, partially upheld or not upheld
• Any actions that Pengage intends to take

If additional time is required due to the complexity of the complaint or the need to obtain further information, we will keep the client informed and provide a revised timescale.

7. Stage 2: Director Review

If a client remains dissatisfied following the Stage 1 response, they may request a Stage 2 review.

Requests for a Stage 2 review should be made within 20 working days of the Stage 1 response and should explain why the client remains dissatisfied.

The complaint will be reviewed by a Director of Pengage.

The Director will consider:

• The original complaint
• The Stage 1 investigation
• The conclusions reached
• Any additional information provided

A final written response will normally be issued within 20 working days. Where additional time is required due to the complexity of the complaint, the volume of documentation, staff availability, or the need to obtain information from the client or third parties, we will keep the client informed and provide an updated timescale.

Any correspondence received after this period will be considered on its own merits. Pengage reserves the right not to reopen a complaint that has already been fully investigated and responded to

The Stage 2 decision represents Pengage’s final internal response under this Complaints Procedure.

Following the issue of Pengage’s final response, the complaint will remain open for a period of three months to allow the client an opportunity to raise any outstanding concerns or provide any material information that was not previously available.

If we do not hear from the client within three months of the date of our final response, we will assume that the complaint is not being pursued further and the complaint will be formally closed.

Any correspondence received after this period will be considered on its own merits. Pengage reserves the right not to reopen a complaint that has already been fully investigated and responded to.

8. Liability and Remedies

The investigation of a complaint, and any actions taken in response, do not constitute an admission of liability, negligence, breach of contract or any other legal responsibility on the part of Pengage.

Where appropriate, Pengage may:

• Provide further clarification or explanation
• Correct factual or administrative errors
• Amend documentation where necessary
• Review internal procedures
• Implement additional quality assurance measures
• Offer other reasonable remedial action where justified

Any apology, goodwill gesture, refund, amendment, correction or other action offered by Pengage shall not be interpreted as an admission of fault or liability.

Any limitations or exclusions of liability contained within Pengage’s Terms and Conditions shall continue to apply throughout the complaints process.

9. Complaint Outcomes

Following investigation, Pengage may:

• Uphold the complaint
• Partially uphold the complaint
• Not uphold the complaint
• Provide an apology where appropriate
• Correct identified errors
• Provide additional information or clarification
• Review procedures, controls or training
• Take other appropriate remedial action

The submission of a complaint does not automatically entitle a client to a refund, compensation, reimbursement of fees or any other financial remedy.

Any remedy offered will be determined following investigation and having regard to:

• The circumstances of the complaint
• The agreed scope of the engagement
• The work undertaken
• Any actions already taken to resolve the matter
• The applicable Terms and Conditions

10. Timescales

Pengage aims to deal with complaints promptly and efficiently.

Where a complaint is particularly complex or requires information from third parties, response times may be extended. In such cases, we will keep the client informed of progress and provide revised timescales where appropriate.

11. Professional Conduct

Pengage is committed to treating all clients with courtesy, professionalism and respect and expects the same standard of behaviour towards its employees and representatives.

We reserve the right to manage, restrict or cease communications where behaviour of the client or any representative of the client becomes:

• Abusive
• Offensive
• Threatening
• Harassing
• Discriminatory
• Vexatious or unreasonable

Any such action will be proportionate to the circumstances and will not affect a client’s right to have a genuine complaint considered fairly.

12. Learning and Continuous Improvement

All complaints are recorded and reviewed as part of Pengage’s quality assurance process and commitment to continuous improvement.

Lessons identified from complaints may be used to:

• Improve services and client communications
• Update procedures and documentation
• Enhance training and supervision
• Strengthen quality assurance controls
• Reduce the likelihood of similar issues occurring in the future