1. Purpose
1.1 Purpose
The British Business Bank plc and its subsidiaries ("Bank") strives to deliver a fair experience for all individuals engaging with its programmes. As part of this endeavour, the Bank is committed to regularly reviewing and improving both its offering and the way this offering is delivered. The feedback it receives whether positive or negative, is a primary way that the organisation identifies areas for improvement. For this reason, it is essential that there is a clear and effective process for capturing, responding to and resolving complaints.
This policy outlines the Bank's approach to handling complaints. This includes what types of complaints are covered by this policy, how to submit a complaint and who will be responsible for reviewing complaints. Appendix B to this policy is intended for publication on the Bank's website as a guide to individuals on how and to whom their complaint should be made/escalated.
This policy has three key objectives, to:
- Provide a clear outline about how any individual who encounters the Bank can express their dissatisfaction.
- Explain who should be contacted when submitting a complaint, including how and when an individual can escalate a complaint and the timescales expected for a response.
- Explain the Bank's complaint handling process, including timescales and escalations.
1.2 Legal & Regulatory Obligations
The Bank looks to apply regulatory guidelines and requirements on a best practice basis to the extent appropriate.
The Bank is not currently regulated by either the Prudential Regulation Authority or the Financial Conduct Authority (FCA). There is however an expectation that the Bank's Patient Capital Advisory Services (PCAS) subsidiary will become authorised for the provision of investment advice which will bring it under the umbrella of the FCA's regulation. At that point, the FCA itself may hold the Bank and relevant colleagues directly accountable for any breaches of the FCA's Principle 6 regarding Customers' Interests - A firm must pay due regard to the interests of its customers and treat them fairly.
In anticipation of this, the Bank will proactively adopt these standards where applicable and has incorporated them into the policy.
1.3 Alignment to Risk Appetite
Risk appetite is the type and level of risk the Board of the Bank is willing to take to deliver its strategy and public policy objectives.
This policy sits under the Level One Risk category, People.
It aligns to the Level Two Risk Category, Conduct and Culture, which is defined as the 'Risk that Bank employees fail to act in accordance with end customers' best interests, fair market practices, or the Bank's Code of Conduct; or that our culture does not support and drive appropriate colleague behaviours and decision making.'
The Bank's risk appetite in relation to Conduct and Culture is set at Low.
2. Scope
This Policy applies to all BBB entities, operations, subsidiaries and Colleagues.
This policy does not apply to the Bank's Delivery Partners, Business Support Partners or Finance Providers.
3. Key Requirements
The key requirement of this policy is that all colleagues must adhere to the established complaints process as outlined in Appendix B, titled Customer Complaints Process. Colleagues are expected to follow the specific steps and guidelines for submitting, managing, and resolving complaints.
3.1 Roles & Responsibilities
3.1.1 SUL Customer Relations Team
The Customer Relations Team is responsible for the management of complaints across all stages, including:
- Bank Complaints Management: Overseeing all complaints related to the Bank, ensuring proper acknowledgment, conducting thorough investigations, and drafting or issuing the final response in line with policy timescales.
- Complaints Register Maintenance: Ensuring that all complaints are accurately recorded in the Complaints Register and that it is regularly updated.
- Complaints Reporting: Compiling and presenting complaints data for key Risk Indicators, as well as preparing detailed reports for the SUL Monthly Portfolio Review, Executive Risk Committee, and Board Risk Committee.
- Root Cause Analysis: Conducting in-depth analysis to identify the root causes of complaints, contributing to process improvements and long-term risk mitigation.
- Quality Control and Training: Completing regular quality control assessments on Stage One Complaints handled by SUL Customer Relations. This includes providing coaching, training, and ongoing support to ensure best practices are followed in complaint handling and resolution.
3.1.2 All Colleagues - Notification of Complaints
All colleagues must promptly notify the Customer Relations Team of any complaints received in accordance with the process set out in Complaints Handling Guide for Colleagues. Complaints should be forwarded immediately to ensure that they are properly acknowledged and addressed within the specified timescales outlined in this policy.
4. Non-Compliance
All identified breaches of this policy must be reported via the Risk Incident Portal on the Bank's Intranet. Breaches will be assessed by the Policy Owner to determine the further action required and may include disciplinary action in accordance with the Bank's Disciplinary policy.
To support your understanding of this policy you must also complete any relevant training provided by the Bank. Related policies, standards and procedures are available to help you interpret and act in accordance with this policy.
5. Aligned Standards and Procedures
- Approach to Consumer Duty Guidance Document
- Speak Up Policy
- Complaint Handling Guide for Colleagues
6. Key Controls
A key control or a combination of controls which manages the inherent exposure of a risk to an accepted residual level and within the defined risk appetite. The key controls relevant to this policy are contained in the table below:
| Library Reference | Control Title | Control Description |
|---|---|---|
| TBC | Training & Competence | Ensures all employees receive the necessary training and development to maintain required skills, knowledge, and qualifications for their roles. |
| TBC | Management Information | Ensures the accurate, timely, and secure handling of MI to meet operational and strategic objectives, while facilitating appropriate reporting. |
| TBC | Quality Control | Ensures the consistent monitoring, evaluation, and improvement of processes to meet established quality standards within the agreed quality framework. |
| TBC | Root Cause Analysis | Ensures the identification, investigation, and resolution of underlying issues to prevent recurrence and improve organisational processes. |
7. Definition of Terms
Complaints
The FCA defines a complaint as:
'Any oral or written expression of dissatisfaction whether justified or not, about the provision of,or failure to provide, a financial service.
A complaint is not restricted to a formal submission of dissatisfaction. Any individual may communicate an issue or concern at any stage of their engagement with the Bank, through any method and via any channel.
8. Further Information
The Bank reserves the right to take any appropriate action to protect itself from any unfounded, malicious or vexatious allegations or complaints.
The Bank Chair has delegated the responsibility for handling complaints in line with this policy and will not respond personally to a complaint brought directly to them. Untrue allegations could lead to legal action for defamation. This policy does not confer any contractual rights and the Bank reserves the right to update this policy and its key terms at any time.
The Bank's Privacy Notice is available here.
Appendix B – Customer Complaints Process
How to submit a Complaint and Who to Contact
This policy applies to all Bank entities, operations and subsidiaries. This policy does not apply to the Bank’s Delivery Partners, Business Support Partners, or its Finance Provider (partners such as banks, lenders, leasing companies that deliver or support funding). Consequently, any complaints or disputes relating to one of the Bank’s Delivery Partners, Business Support Partners, or Finance Provider should be settled directly with the relevant Delivery Partner/Business Support Partner/Finance Provider.
Depending on the nature of the complaint, it might be more appropriate for one of the Bank’s subsidiaries, or with one of our official partners, including our Delivery Partners, Business Support Partners and Finance Providers to address your issue. For this reason and to ensure that every complaint is reviewed by the appropriate organisation as early as possible, we recommend individuals use the following guidance about who, when and how to submit a complaint:
| Who is the Complaint about? | When to submit a complaint | How to Submit a complaint |
|---|---|---|
| Delivery Partners of the Bank & its subsidiaries | The Bank is not involved in the day-to-day management of these companies. Consequently, any complaints or disputes should be settled directly with the relevant Delivery Partner in the first instance. | |
| British Business Bank (excluding The Start-Up Loans Company & Future Fund). | If you have a complaint regarding service, information or communications provided by the Bank or any of its subsidiaries (excluding Start Up Loans and Future Fund), then this complaint should be submitted directly to the Bank's Customer Relations. Complaints must be submitted within six years after the event which is being complained about. | Bank Customer Relations team: Email:[email protected] |
| Future Fund | If you have a complaint regarding service, information or communications relating to Future Fund then this complaint should be submitted directly to Future Fund Support. | Future Fund Support: Email: [email protected] |
| Delivery Partners, Business Support Partners or Post Loan Support Partner of The Start-Up Loans Company | If you have been assigned to one of Start Up Loan's Delivery Partners, Business Support Partners or Post Loan Support Partner, then complaints should be submitted directly to that organisation in the first instance. This is likely to apply to any complaints regarding:
| Delivery Partner/Business Support Partner/Post Loan Support website, phone or email. You may be redirected to your Finance Provider if the nature of your complaint is better suited to them. You can find up to date contact details of our various Start Up Loans Partners on our website If you need assistance in identifying the relevant Partner or contact, please contact our Customer Service Team, using the details below, and we will ensure your query is directed to the right place: Start Up Loans Customer Service team: Phone: 0344 264 2600 Webchat* on the Start Up Loans website Email**: [email protected] |
| Finance Provider of The Start-Up Loans Company Since 2023, The Enterprise Fund Limited t/a GC Business Finance (GCBF) is our Finance Provider and the regulated lender under the Start Up Loans Scheme. If unsure who is your Lender, you should consult your Loan Agreement or contact Start Up Loans Customer Service team for guidance. | If you have already received a Start Up Loan and your complaint relates to loan administration then complaints should be submitted directly to the Finance Provider organisation that issued your Loan Agreement.
| Finance Provider, The Enterprise Fund Limited t/a GC Business Finance Website: https://businessfinance.growthco.uk/contact/ Phone: 0161 245 4977 Email: [email protected] |
| The Start-Up Loans Company | If you have a complaint about the Start Up Loans Scheme, then this complaint should be submitted directly to Start Up Loans Customer Service Team. Complaints must be submitted within six years after the event which is being complained about. | The Contact page on the SULCo website: startuploans.co.uk/contact-us/ SULCo Customer Service team: Phone: 0344 264 2600 Webchat* on the SULCo website Email**: [email protected] *Services available weekdays (excluding bank holidays) 9.00am – 6.00pm, with closures for staff training noted on our Contact Page, **Individuals should expect a reply from a SUL representative within two working days |
Our Complaint Handling Process
The following process relates to complaints that are submitted pertaining to the Bank and/or its subsidiaries and are within the scope of this policy (see Section 2). Please note that, if you are submitting a complaint to a Delivery Partner, Business Support Partner or Finance Provider, you should request a copy of their specific Complaints policy.
When the Bank receives an individual’s complaint about the Bank and/or its subsidiaries and within the scope of this policy, it will endeavour to address the matter immediately, effectively, and in a fair and reasonable manner.
If a resolution cannot be reached within three working days, we will send you a written acknowledgement. This written acknowledgement will:
- Acknowledge that a complaint has been submitted.
- Advise you that the Complaints Manager is reviewing the matter.
- Inform you that the matter will be investigated and that a Final Response will be provided in writing within eight weeks of the complaint being received (although the Bank aims to resolve all matters sooner than this where possible).
From this point forward, the Complaints Manager will assume responsibility for ensuring your complaint is resolved within eight weeks. The Complaints Manager will ensure that the complaint is investigated by the appropriate individuals within this timescale.
Once the matter has been investigated and the Bank’s Customer Relations Team has made a decision regarding the complaint, you will receive a written Final Response from the Complaints Manager.
This Final Response will be provided to you and will:
- Acknowledge all of the concerns within the original complaint.
- Outline the findings of the investigation.
- Clarify whether the complaint was ‘upheld’ or ‘not upheld’.
- Outline the proposed resolution (if applicable).
- Inform you that if you are not satisfied with the Final Response, you have the right to escalate the matter. You must do this within six months of receiving your Final Response.
In exceptional circumstances, the Complaints Manager may not be able to provide you with a Final Response within eight weeks. In these instances, a holding communication will be sent to you in writing.
This holding communication will:
- Inform you of the delay.
- Outline the reasons for the delay.
- Provide an expected response time for sending the Final Response.
Escalations
In the unfortunate event that you remain dissatisfied with the final outcome of your response provided by us you have the right to escalate your complaint.
If complainants are not satisfied with the response to their complaint, they may ask for the complaint to be reviewed by the Bank’s Complaints Escalation Panel. This must be requested in writing and no longer than six months after receipt of your final outcome.
This panel will be composed of at least two of the Bank’s Senior Leadership Team, together with a representative of the Bank’s Risk & Compliance team, who have no direct involvement with the issue(s) under review.
The complainant will be invited to submit any further written submissions to be reviewed by the panel.
The review should normally take place within thirty working days of receipt of the request. If this is not possible, the complainant will be informed of the review date.
The panel can:
- uphold the complaint in whole or in part.
- decide on the appropriate action to be taken to resolve the complaint.
- dismiss the complaint in whole or in part.
The complainant will be notified of the panel’s decision in writing five working days after the review has been completed.
If you are dissatisfied with our response to a data protection complaint, you can request for your complaint to be reviewed by our Data Protection Officer as part of our escalation panel. If you remain dissatisfied with the response, you have the right to refer your complaint directly to the Information Commissioner’s Office (ICO).
Please note, if you have made a complaint directly to one of the Bank’s Delivery Partners, Business Support Partner or Finance Provider, and they are regulated by the FCA, you have the right to refer the complaint to the Financial Ombudsman Service (FOS). You should be aware that FOS will refer the matter back to the relevant party to resolve if you have not engaged with that party in the first instance and there are some circumstances where they may not be able to consider the complaint. Further information in respect of the services available from FOS are available from their website.
If your complaint is about a Start Up Loans Business Support Partner who is not regulated by the FCA and does not offer the right to refer your complaint to FOS, you can refer your complaint to the Finance Provider for review.
For Future Fund, if complainants are not satisfied with the response to their complaint, they may request for the complaint to be escalated for review by the Bank’s Chief Risk Officer. The Chief Risk Officer may elect to refer the complaint to the Bank’s Complaints Escalation Panel.
For complaints relating to information held by Cifas, if complainants are not satisfied with the response to their complaint, they will need to escalate directly to Cifas as advised on the Cifas website.
The Bank reserves the right to take any appropriate action to protect itself from any unfounded, malicious or vexatious allegations or complaints.
The Bank Chair has delegated the responsibility for handling complaints in line with this policy and will not respond personally to a complaint brought directly to them. Untrue allegations could lead to legal action for defamation. This policy does not confer any contractual rights and the Bank reserves the right to update this policy and its key terms at any time.
The Bank’s Privacy Notice is available here.
Definition of Terms
Delivery Partners/Business Support Partners
These are a network of organisations that work with the Bank to provide essential support for businesses and deliver or support those seeking to access finance.
Finance Provider
This is The Enterprise Fund Limited t/a GC Business Finance, who are the Lender under the Start Up Loans Scheme. The Finance Provider is authorised and regulated by the FCA. They will be a Start Up Loans borrower’s primary point of contact for matters relating to a Start Up Loans loan administration, loan status and repayment arrangements.