Dispute Resolution and Complaint Management Control Policy

INTRODUCTION

  • Disputes may arise when customers use our products and services which VFD Microfinance Bank Limited (VFD MFB or the Company) will seek to resolve expeditiously and amicably, to ensure customer satisfaction. As a result, VFD’s internal dispute resolution and complaint management control policy (thePolicy) is detailed below.

 

PURPOSE

  • The purpose of the Policy is to ensure that complaints and disputes arising from and between Users are resolved promptly, fairly and consistently.
  • This Policy is developed in line with international best practices, and evidencesVFD’s commitment to professionalism, User satisfaction and transparency.

DEFINITIONS

  • In this Policy, except where expressly provided to the contrary, the following terms and expressions shall have the following meanings:

Applicable Law means any national, supranational, regional or local government or governmental, administrative, statute, law (including common law), regulation, rule, ruling, order, writ, injunction, decree or guidelines issued by any authority in Nigeria and any international statute, law (including common law), regulation, rule, ruling, order, writ, injunction, decree or guidelines applicable to VFDMFB;

Complainant means any User who notifies a Receiving Officer of a Dispute;

Dispute means an expression of dissatisfaction made to VFDMFB in writing, related to its products or services, or the complaints handling process itself, where a response or resolution is explicitly or implicitly expected;

Inquiry means a request for information on any of VFDMFB’s products or services, not amounting to a Dispute;

Receiving Officer means the VFDMFB member of staff who receives a complaint or is notified of a Dispute; and

User means any customer who utilizes VFDMFB products or services.

 

OBJECTIVES OF THE POLICY

  • The objectives of the Policy are to:
    • ensure all Disputes are resolved quickly and effectively;
    • identify and address recurring or systematic problems;
    • ensure continued product, process and service improvements;
    • provide internal solutions to Usercomplaints;
    • improve customerconfidence and satisfaction;
    • preserve customerrelations;
    • mitigate reputational risks;
    • determine the documents required to facilitate arbitration for each type of the identified Disputes; and
    • ensure cost-effectiveness in resolving customerchallenges.

SCOPE OF THE POLICY

  • This Policyrelates to all disputes, complaints, transaction errors or related occurrences arising between VFDMFBand its Users.

DISPUTES

  • Disputes are transactional claims or disagreements arising from:
    • unauthorized or excessive charges;
    • failed transactions;
    • technical errors with the V banking app;
    • compromise of account security;
    • card transaction errors;
    • billing errors; and

 

TYPES OF DISPUTES

  • Fraud- Where a Userdisputes having originated or carried out the transaction i.e.
    • the User neither authorized nor participated in the transaction. Fraud related disputes are treated as criminal acts carried out via the stipulated channels.
  • Processing errors- Where a User disputes the details that the transaction was processed with, such as:
    • amount (incorrect amount processed in error);
    • duplicate processing (the transaction was processed more than once in error); and
    • transaction reversal (the transaction was reversed after authorization and sale).
  • Problems with the authorization process such as incomplete transaction due to network breach.

PARTIES TO DISPUTES

  • The Consumer– the party who performed the transaction being disputed.
  • The Merchant–theparty who accepts payment from the Consumer in exchange for goods/services.
  • VFDMFB– asthe service provider and issuing bank.
  • The processor or switch–the organization that processes the transaction or switches and routes transactions involving multiple issuers, acquirers, transaction types and card types.

 

DISPUTE RESOLUTION

  • This Policy provides the workflow for dealing with Disputes. The main objective is to ensure that parties with genuine claims are attended to, inline with the applicable regulatory guidelines.
  • Accordingly, this Policy;
    • requires the creation of a platform for Users to log a Dispute;
    • requires the assignment of a unique identification or tracking number in relation to each Dispute;
    • requires the creation of an interface for parties involved in the dispute to Request for Information (RFI) as regards disputed transactions; and
    • ensures that all Disputes are treated within a maximum period of time from the date of receipt of the Dispute in accordance with applicable regulations.