Complaints Management Policy
Guinness Nigeria Plc (“GNPLC” or “the Company”) is committed to providing excellent service to all our shareholders. Our aim is to continuously improve our service to ensure we are meeting their needs and expectations and to encourage feedback on our performance. This Policy provides comprehensive guidelines for the management of shareholders’ issues and complaints by the Company and our Registrar.
We recognize that complaints and compliments provide unique information about the quality of service our shareholders receive. The management of a complaint provides the opportunity for complainants to have their issues resolved promptly and efficiently ensures that any identified risks are managed appropriately, and that action is taken to minimise or eliminate those risks.
Guinness Nigeria Plc has therefore issued this Complaint Management Policy (“the Policy”) in line with the requirements of the Securities and Exchange Commission’s Rules Relating to the Complaints Management Framework of the Nigerian Capital Market (“SEC Rules”) issued on 16th February, 2015 and the Nigerian Stock Exchange’s Directive (NSE/ LARD/LRD/CIR6/15/04/22) to all Listed Companies (“the NSE Directive”) issued on 22nd April, 2015.
The objectives of this Complaints Management Policy are to:
- Assist the Company with the timely and effective management of complaints.
- Establish a standard approach to complaints handling including the establishment of performance indicators to monitor compliance.
- Ensure that the relevant employees of the Company and our Registrar are aware of their responsibilities and are empowered to manage complaints
- Ensure that complaints and enquiries from the Company’s shareholders are managed in a fair, impartial and efficient timely manner.
This Complaints Management Policy is underpinned by the following guiding principles:
- The management of Guinness Nigeria Plc and our Registrar are committed to providing quality service to all our shareholders.
- Shareholders are encouraged and enabled to provide feedback about the service they receive from the Company and our Registrar.
- All complaints are acknowledged and responded to promptly.
- All complaints are dealt with in a manner that is effective, complete, fair to all parties and provides just outcomes.
- Complaint information is openly communicated while protecting confidentiality and personal privacy.
- All complaints are recorded to enable review of individual cases and report on aggregated complaints information
- Our Complaint Management Policy and practices are regularly evaluated and the information is used to improve services.
4.1 - This Policy shall apply to issues, enquiries or complaints from shareholders to the Company or the Registrar regarding shareholders’ rights, interests or privileges and requiring a formal or informal response.
4.2 - The Policy shall not apply to complaints on matters that are sub-judice or which do not relate to shareholders’ rights, interests or privileges.
5. Roles and Responsibilities
5.1 – The Company Secretary
The Company Secretary has ultimate responsibility for ensuring that shareholders’ complaints are received and attended to in a timely and efficient manner and shall ensure that the Registrar and all employees of the Company charged with the implementation of this Policy discharge their responsibilities efficiently and in a timely manner.
5.2 - The Registrar
The Registrar shall be the first point of call for all shareholders’ issues and complaints and shall ensure that these are attended to courteously, promptly and efficiently.
6. Steps in the Complaints Management Process
6.1 - Complaints and enquiries by shareholders may be made as follows:
- a) Contact the Registrar: Shareholders who wish to make a complaint/enquiry shall in the first instance contact the Registrar. The Registrar manages all the registered information relating to all shareholdings, including shareholder name(s), shareholder address and dividend payment instructions amongst others.
Upon receipt of a complaint or an enquiry, the Registrar shall immediately provide the relevant details of such complaint or enquiry to Guinness Nigeria Plc for monitoring, record keeping and reporting purposes.
In resolving complaints or enquiries, the Registrar shall be guided by the timelines stipulated in clause 5 (c-f) of this Policy.
- b) Contact Guinness Nigeria Plc’s Company Secretary: If the Registrar is unable to satisfactorily address and resolve a complaint, issue or enquiry by a shareholder within ten (10) working days, the shareholder may contact the office of the Company Secretary.
6.2 - Where a complaint or an enquiry is sent to Guinness Nigeria Plc directly, the Company upon receipt of the complaint or enquiry, shall use its best endeavours to ensure that:
- relevant details of the complaint or enquiry are immediately recorded.
- a response is provided by the Company or the Registrar within the time frame set out in sub-clauses c-f below.
- complaints or enquiries received by e-mail are acknowledged within two (2) working days of receipt.
- complaints or enquiries received by post are responded to within five (5) working days of receipt.
- all other complaints or enquiries are resolved within ten (10) working days of receipt.
- The Nigerian Stock Exchange is notified, within two (2) working days, of the resolution of a complaint or enquiry.
- where a complaint/enquiry cannot be resolved within the stipulated timeframe set out above, the shareholder shall be notified that the matter is being investigated. It should be noted that delays may be experienced in some situations, including where documents need to be retrieved from storage.
- the same or similar medium that was used for the initial enquiry is used in providing a response (whether by email, phone, post or fax), unless otherwise notified to or agreed with the shareholder.
7. Electronic Complaints Register
7.1 - The Company shall maintain an electronic complaints register.
7.2The electronic complaints register shall include the following information:
- The date that the enquiry or complaint was received.
- Complainant’s information (including name, address, telephone number, e-mail address).
- Nature and details of the enquiry or complaint.
- Action taken/status.
- Date of the resolution of the complaint.
The Company shall also provide information on the details and status of complaints to the Securities and Exchange Commission and The Nigerian Stock Exchange on a quarterly basis.
8. Liaison with the Registrar
During the course of investigating a shareholder’s enquiry, complaint or feedback, the Company may liaise with the Registrar to:
- determine the facts;
- determine what action has been undertaken by the Registrar (if any); and
- coordinate a response with the assistance of the Registrar.
9. Contact Details of the Registrar
The Registrar may be contacted as follows: Veritas Registrars Limited (formerly Zenith Registrars Limited) Plot 89A, Ajose Adeogun Street, Victoria Island, Lagos
Telephone: +234 1 2708930 -4;
+234 1 2793873;
+234 1 2716116
10. Contact Details of the Company Secretary
Shareholders seeking to escalate unresolved complaints are invited to contact the Company Secretary as follows:
The Company Secretary Guinness Nigeria Plc
24, Oba Akran Avenue P.M.B. 21071, Ikeja, Lagos
Telephone: +234 1 2709100
11. Communication of this Policy
This Policy shall be communicated as follows:
- The Policy shall be available on Guinness Nigeria Plc’s website (www.guinness-nigeria.com).
- A shareholder may request a copy of this by contacting the Office of the Company Secretary.
- The Policy shall be made available for perusal at General Meetings of the Company.
Wherever possible, and subject to statutory requirements, the Company will not charge shareholders for making enquiries, giving feedback, providing a response or for any aspect in the course of resolving a shareholder matter.
However, in some circumstances, the Registrar may charge shareholders a fee (for example, to resend previous dividend statements upon request by the shareholder).
13. Review of this Policy
This Policy may be reviewed from time to time by management and all changes, amendments or subsequent versions of this Policy will be published on Guinness Nigeria Plc website (www.guinness-nigeria.com).
Approved by the Board of Guinness Nigeria Plc and signed on its behalf by:
BAKER MAGUNDA ROTIMI ODUSOLA
Managing Director/ Chief Executive Officer Company Secretary