Internal Dispute Resolution Policy

1. Introduction

Stormrake Pty Ltd (“Stormrake”) maintains an internal dispute resolution system to address client complaints in accordance with regulatory requirements. If you have concerns about our services or wish to raise a dispute, please contact us. See the guidance below on how to contact us and raise your concern(s).

2. Internal Dispute Resolution (“IDR”)

This Policy complies with ASIC Regulatory Guide 271: Internal Dispute Resolution and outlines Stormrake’s process in handling client complaints. This process provides:

a. an opportunity for Stormrake to resolve any issue with the complainant prior to external escalation;
b. the ability to identify and address recurring or systemic issues which can lead to product and service improvements; and
c. improved levels of client confidence and satisfaction.

Stormrake’s internal dispute resolution process is available to complainants free of charge and this Policy is accessible on the Stormrake website.

3. What is a Compliant?

A complaint is defined as “an expression of dissatisfaction made to or about an organisation, related to its products, services, staff or the handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required.” Expressions of dissatisfaction include posts on a social media channel or account owned or controlled by the organisation that is the subject of the post, where the author is identifiable and contactable.

4. Making a Complaint

There are several methods for clients to lodge a complaint. We aim to resolve all issues as quickly as possible and the quickest method is for clients to submit their complaint by phone to +61 (3) 8594 1454 or by email to complaints@stormrake.com. This ensures that the complaint is referred to and reviewed by the designated team in a timely manner.

Stormrake will take reasonable steps to assist complainants who may have difficulty lodging or progressing a complaint, including by providing assistance with communication or alternative formats where appropriate.

If your complaint is regarding a trade, please provide the details of the trade(s), which may include, but is not limited to:

a. the order submission date and time;
b. execution date and time; and
c. execution price.

We have detailed the best methods for making a complaint below:

a. Email
Please write to complaints@stormrake.com

b. Telephone
By dialling +61 (3) 8594 1454
By dialling your dedicated broker

c. Representatives
You may authorize a third party to act on your behalf.
We will provide a 'Complaints Letter of Authority' form upon request to facilitate this.

5. Complaints Handling Procedures

5.1. Receiving Complaints:

Stormrake will make every reasonable effort to address all complaints promptly and in a professional manner. Upon receiving a client complaint, Stormrake will acknowledge receipt of the complaint within 1 business day or as soon as is practicable. This acknowledgement will:
a. state that your complaint is being investigated;
b. explain the courses of action available to you; and
c. request further information from you if appropriate.

5.2. Investigating Complaints

Stormrake will make every reasonable effort to investigate all relevant circumstances and information surrounding the complaint, make a determination and provide a written response to the complainant within 30 calendar days (“maximum timeframe”) upon receipt of the complaint, or as soon as practicable.

5.3. Recording Complaints

Stormrake will keep a record of complaints and use these to identify systemic issues and drive improvements within the company.

5.4 IDR Response

If it takes longer than 5 business days from our receipt of the complaint to resolve the complaint, Stormrake will provide a written response to the complainant with the following information:

a. The final outcome of the dispute which can be either confirmation of actions taken to fully resolve the complaint or reasons for rejection or partial rejection of the complaint.For decisions to reject or partially reject the complaint, the reasons or justification will be set out in the response, including:
i. issues in the complaint identified and addressed;
ii. findings on material questions of fact and supporting information to back up those findings; and
iii. sufficient details for the complainant to understand the basis for the decision and be fully informed when deciding whether to escalate the matter with AFCA or another forum.

b. If the complainant is not satisfied with the IDR provided by Stormrake, the complainant may lodge a complaint with the Australian Financial Complaints Authority (“AFCA”), contact details are set out below:

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

c. In circumstances where the complainant has not attempted to resolve the complaint with Stormrake first, AFCA may direct the complaint to Stormrake to provide a response in accordance with Stormrake’s IDR process.

5.5 Complaints resolved within 5 business days of receipt of the complaint

Unless requested by the complainant, Stormrake is not required to provide an IDR response if the complaint is resolved by the end of the fifth business day of receipt of the complaint.

A complaint is considered to be resolved if:

a. the complainant has confirmed (verbally or in writing) that they are satisfied with the action(s) taken by Stormrake in response to the complaint and do not wish to take the matter further;
b. other circumstances exist that make it reasonable for Stormrake to form the view that the complaint has been resolved to the complainant’s satisfaction; or
c. Stormrake determines that the only reasonable course of action to resolve a complaint is an explanation and/or apology. This includes where the complaint relates to:

i. Stormrake’s commercial decision, such as a refusal to grant access to our services on certain terms; or
ii. reasonable initial contact by Stormrake about debt collection.

5.6. Exceptions to provide an IDR within the relevant timeframe

There are many variables that can affect complaint response times. This includes the complexity of the issues raised and the availability of information, including from third parties.

If Stormrake is unable to provide an IDR before 30 calendar days following the receipt of the complaint, it must provide the complainant an IDR delay notification with the following details:

a. the reasons for the delay;
b. their right to complain to AFCA if they are dissatisfied; and
c. the contact details for AFCA.

6. Review

This policy will be regularly reviewed to assess the efficiency and effectiveness of Stormrake’s IDR process, and updated to ensure compliance with relevant laws and regulations.