July 2022

1. Scope

This policy commenced on 5 October 2021.
Each of the entities below are subject to this policy:

• “Horvat Capital” HD Invest Pty.Ltd. ABN 49 615 049 628

The purpose of this policy is to set out clearly and concisely:

• how to lodge a complaint
• the options available if you require additional assistance to lodge a complaint
• the key steps in the complaint handling process
• response timeframes
• next steps if the complaint cannot be resolved

2. Lodging a Complaint

2.1. What is a Complaint?

A complaint is an expression of dissatisfaction in relation to products, services, staff or the handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required.

Please note that opinions, comments and expressions of interest or concern made directly or indirectly, explicitly or implicitly to or about the organisation, its products, services, staff or its handling of a complaint, are considered to be feedback.

No response will be given if you have provided feedback. You will not be charged any fees to investigate a complaint.

2.2. How to Lodge a Complaint

Complaints may be lodged with the Horvat Capital either verbally or in writing. The latter may include letter, email or a social media post (if we are able to both identify and contact you from that post).2.2.1. Your Mortgage Broker An easy way to lodge your complaint is via your mortgage broker. You can either phone or email your broker. They will then notify the Horvat Capital Complaints Manager of your complaint.

2.2.2. Refer to Website for Contact Details

The website of the Horvat Capital member you have engaged with will display details of how to contact them. This will usually include a phone number to contact the call centre and may provide a portal by which you can leave a message via the website.

2.2.3. Refer to your Credit Guide

When you first dealt with your mortgage broker, you would have been provided with a document called a Credit Guide. This document is designed to assist you to decide whether you use the services of the relevant member of the Horvat Capital.
2 Australian/New Zealand Standard AS/NZS 10002:2014 Guidelines for complaint management in organisations, paragraph 4.2

3 Australian/New Zealand Standard AS/NZS 10002:2014 Guidelines for complaint management in organisations, paragraph 4.5

The information provided includes details of how to lodge a complaint by phone, email or post.

2.2.4. Contact the Complaints Manager Directly You can contact the Complaints Manager directly by phoning 1800 844 223 or by emailing info@horvatcapital.com.

2.2.5. Social Media

Horvat Capital monitors social media platforms where it has a presence, such as Facebook. If you lodge a post that meets the definition of a complaint, and we are able to identify and contact you, we will attempt to do so. However, to ensure that your

complaint is not overlooked, utilising one of the options discussed in sections 2.2.1 to 2.2.4 is suggested.

2.2.6. Can I Nominate an Advocate to Act on my Behalf?

You have the right to nominate another person to act on your behalf. Horvat Capital will accept complaints from authorised representatives of complainants (the “Advocate”). It is preferable to receive your written authorisation before engaging with the Advocate, however if you only give verbal authorisation, the Complaints Manager will provide written confirmation to you (usually via an email) that Horvat Capital will comply with your verbal instruction to engage with your Advocate.
Horvat Capital will seek confirmation from you of the scope of the Advocate’s authorty (e.g. is the Advocate authorised to accept an offer of compensation on your behalf?) If Horvat Capital receives written notification from a legal representative that they act on your behalf, it is not necessary to seek separate authorisation from you.

3. Internal Dispute Resolution (IDR) Procedure

3.1. Acknowledgement of Complaint
The Complaints Manager will provide an acknowledgement within one business day of receipt of a complaint. This will let the complainant know that the Horvat Capital has received the complaint.

3.2. Types of Complaints

There are no restrictions on the nature of complaints that can be referred to Horvat Capital. If you have a situation that meets the complaint definition in section 2.1 above, then you are entitled to lodge a complaint.

3.3. Objective of Complaint Investigation

The Complaints Manager will investigate the issues raised in the complaint, with the objective being to find a mutually agreeable resolution to the complaint. In order to reach this conclusion, the Complaints Manager must understand what:

• you believe occurred
• the mortgage broker believes occurred
• should reasonably have occurred in the circumstances
• 3.4. Investigation Process

The Complaints Manager will seek information from:

• your mortgage broker
• Horvat Capital systems

This is an iterative process and you may be asked to provide further information during the investigation process, until the Complaints Manager is satisfied that they are in a position to assess what should reasonably have occurred in the circumstances.

3.5. IDR Response

You will be provided with a written response within 30 calendar days of lodging your complaint. This will inform you of the final outcome of your complaint, including the reasons for our decision and how to contact the relevant external dispute resolution

(EDR) scheme if you are not satisfied.

If we are unable to determine the final outcome within this timeframe, we will give you prior notification, informing you of the reasons for the delay and of your right to refer your complaint to the relevant EDR scheme.

3.6. Resolution of Complaint

We will ask you for the remedy you are seeking to resolve your complaint. These remedies may range from (but is not limited to) an apology, the waiving of a fee, or a payment of compensation.

If the resolution of a complaint involves a payment of compensation, we may require you to sign a Deed of Release. Upon receipt of your validly executed Deed of Release, we will arrange for the payment to be made into your nominated bank account.

3.7. IDR Timeframes

Your complaint must be lodged within 6 years of the date when you first became aware (or should reasonably have become aware) of the issue or that you suffered a loss.

4. External Dispute Resolution (EDR) Process

4.1. EDR Timeframes
If you are dissatisfied with the final outcome of your complaint and wish to refer your matter to the relevant EDR scheme, you must do so within 2 years of receiving you IDR response.

4.2. EDR Schemes
At the time of writing, the Australian Financial Complaints Authority (“AFCA”) is the only EDR scheme available to consumers.

• AFCA’s contact details are:
• Australian Financial Complaints Authority
• Telephone 1800 931 678
• Email info@afca.org.au
• Post GPO Box 3 Melbourne VIC 3001
• Website www.afca.org.au

4.3. Resolution of Complaint

Horvat Capital will comply with any instructions or determinations given by AFCA.
A complaint being referred to AFCA does not limit the ability of the parties to negotiate a mutually agreeable outcome to the complaint.

If the resolution of a complaint involves a payment of compensation, we may require you to sign a Deed of Release. Upon receipt of your validly executed Deed of Release, we will arrange for the payment to be made into your nominated bank account.