Complaints Handling Policy

1. Policy Statement

Cromwell is committed to:

• A dispute resolution system that consists of:
  • an Internal Dispute Resolution (IDR) process that is accessible and easy to use for
    complainants and aligns with ASIC’s Regulatory Guide 271; and
  • Maintain membership of an external dispute resolution scheme (EDRS). Cromwell Licensees
    are members of the Australian Financial Complaints Authority (AFCA) – membership numbers
    are:
    • Cromwell Funds Management Limited 14336;
    • Cromwell Property Securities Limited 10341; and
    • Cromwell Real Estate Partners Limited 87283.
• Actively respond to complaints received, online, by email, by phone or in person.
• Ensure the below timeframes are met for each complaint:
  • Response acknowledgement – Immediate, within 24 hours (or one business day) of receipt,
    or as soon as practicable
  • 5 day rule – if response provided within 5 business days, no formal IDR response required
    unless the complainant requests a written response or complaint is about hardship
  • Standard complaints response – No later than 30 calendar days after receiving the
    complaint in accordance with ASIC RG 271.56
  • IDR delay notification – Required if the relevant maximum IDR timeframe is unable to be
    met, and prior to the 30th calendar day
• Establish consistence with IDR responses to include:
  • Issue raised – details of complaint
  • What we found – Brief description of assessment/investigation
  • The final outcome – our proposal to resolve issue
  • The right to take the complaint to AFCA if complainant is not satisfied with the IDR response
  • Contact details for AFCA
• Maintain an up-to-date record of complaints within the Complaints register.
• Continuously improving all aspects of our complaints handling processes and IDR system, having
  regard to relevant laws, industry standards and best practice.
• Ensure all employees (new and old) undergo annual training on Complaints Handling.

2. Definition of a Complaint

A complaint is an expression of dissatisfaction made to or about Cromwell, related to its products or services, staff or the handling of a complaint, where a response or resolution to the complaint is explicitly or implicitly expected or legally required.

3. How to lodge a complaint

If you wish to make a complaint, Cromwell can be contacted via:

Cromwell’s Investor Service Team contact details:
Address: Level 10, 100 Creek Street, Brisbane QLD 4001, AUSTRALIA
Phone: 1300 268 078
Email: invest@cromwell.com.au

Cromwell’s Dispute Resolution Officer
Address: GPO Box 1093, Brisbane QLD 4001, AUSTRALIA
Email: complaints@cromwell.com.au

We will also respond to complaints made through other methods, including complaints made on social media, in person, or online.

We will accept a complaint made by a representative on your behalf. A representative includes a person who is your financial counsellor, legal representative, family member or friend.

4. Assistance making complaints

The person receiving or managing your complaint will give you any assistance you need to make the complaint to Cromwell. Please ask this person if you need additional assistance. If, after requesting assistance, for some reason you consider you need further assistance or the person receiving your complaint cannot assist you, please contact:

Cromwell Relationship Manager
Phone: 1300 268 078
Email: invest@cromwell.com.au

5. How Cromwell deals with complaints

Acknowledgement
We will acknowledge your complaint within 24 hours (or one business day) of receiving it or as soon as practicable.

Review
We will review your complaint and may contact you to ask for additional information or documentation required to investigate your complaint.

Investigation
We will investigate your complaint in an equitable, objective and unbiased manner based on the information and documents you have provided us, any other available information and our own investigations into the complaint.

Response
Following our investigation, we will generally respond to your complaint in writing setting out:

1. the final outcome of the complaint, including any actions we are taking to resolve the complaint and the basis of our decision
2. the right to take the complaint to AFCA if you are not satisfied with our response; and
3. the contact details for AFCA.

In some cases, we may respond to your complaint verbally where you are satisfied with our resolution or we cannot take any further action to reasonably address your complaint.

We may, at our discretion, resolve your complaint in a number of ways, including by providing:

• information and explanation regarding the circumstances giving rise to the complaint;
• an apology;
• compensation for loss incurred by you as a direct result of the breach (if any); and/or
• other such remedies as we consider appropriate.

Action
We will implement any actions set out in our response to your complaint.

6. Response timeframes

We will typically respond to your complaint within 30 calendar days of receiving the complaint
unless:

1. the complaint is complex; or
2. there are circumstances beyond our control which are causing delays.

If we cannot respond to your complaint within 30 calendar days, we will notify you in writing.

7. Accessing AFCA

If you are dissatisfied with our decision for your complaint, you may refer the complaint to AFCA, an external, independent and impartial ombudsman service of which we are a member. It is free for you to refer your complaint to AFCA. You can contact AFCA using the details below:

Australian Financial Complaints Authority
Address: GPO Box 3, Melbourne VIC 3001, AUSTRALIA
Phone: 1800 931 678 (toll free)
Website: www.afca.org.au
Email: info@afca.org.au