Complaints Policy - Just Protect Ltd

Version: 1.9

Effective Date: March 2026

Purpose

This policy sets out Just Protect Ltd's approach to the receipt, handling, and resolution of complaints, in line with applicable UK Financial Conduct Authority (FCA) requirements, including Consumer Duty (PRIN 2A), Dispute Resolution (DISP), the Consumer Credit Sourcebook (CONC), and the rules and guidance of the Financial Ombudsman Service (FOS).

We are committed to treating all customers fairly and ensuring complaints are dealt with promptly, transparently, and effectively, delivering the four Consumer Duty outcomes: products and services that are fit for purpose, clear and accessible information, fair value, and appropriate consumer support.

1. Making a Complaint

Customers can raise a complaint about any aspect of our products or services by:

Complaints may be made by the customer or an authorised representative and can be submitted by any reasonable means (oral or written).

2. Acknowledgement

  • Every complaint will be acknowledged within 24 hours of receipt on a working day, using the same or an appropriate communication channel.
  • Our acknowledgement will include a clear summary of our complaints process and indicative timelines to resolution.

3. Investigation

  • A designated complaints handler (or an appropriate deputy) will carry out a fair, thorough, and independent investigation into each complaint.
  • Where resolution is not achieved within three business days, customers will receive regular progress updates until the complaint is closed.

4. Resolution

  • Where we are able to resolve a complaint by the close of the third business day following receipt, we will issue a Summary Resolution Communication confirming our understanding of the complaint, the outcome, any remedial action, and the customer's right to refer the matter to the Financial Ombudsman Service.
  • Complaints that cannot be resolved within three business days will proceed through our full investigation process. We aim to issue a Final Response within eight weeks of receipt, in line with FCA DISP rules.

5. Final Response

Our Final Response will set out in clear and plain language:

  • The outcome of our investigation
  • Any offer of redress or remedial action
  • Information about the customer's right to refer the complaint to the Financial Ombudsman Service (FOS), including FOS contact details
  • The applicable time limits for referral to FOS, being generally six months from the date of the Final Response, or, for in-scope motor finance commission complaints, any different time limits specified by the FCA from time to time

6. Escalation to the Financial Ombudsman Service

If a customer is dissatisfied with our Final Response or with the time taken to resolve their complaint, they may refer the matter to the Financial Ombudsman Service (FOS):

FOS will consider whether a complaint falls within its jurisdiction and, where it does, will review the case independently of Just Protect Ltd.

7. Motor Finance Complaints

We handle motor finance complaints in accordance with FCA DISP rules and any specific FCA guidance relating to commission arrangements or sector-wide redress schemes.

Customers who believe they were not properly informed about commissions or other benefits received by us in connection with the arrangement of motor finance are encouraged to raise complaints promptly, noting that special complaint-handling timescales, remediation exercises, or redress schemes may apply.

7A. Alternative Dispute Resolution (ADR) – Non-Financial Services Related

If you are a consumer and your complaint cannot be resolved through our internal complaints procedure, you may be able to refer your complaint to an independent dispute resolution provider (known as Alternative Dispute Resolution, or ADR).

Non-financial services related complaints

If a dispute arises that cannot be resolved between us within a reasonable timescale, you may refer your dispute to:

The Motor Ombudsman

For details of this service, you can:

  • Call them on: 0345 241 3008
  • Visit their website at: www.themotorombudsman.org
  • Write to them at: The Motor Ombudsman, 71 Great Peter Street, London, SW1P 2BN

Alternative option

If a dispute arises that cannot be resolved between us within a reasonable timescale, you may refer your dispute to:

National Conciliation Service

This ADR service is independent of Just Protect Ltd and will consider your complaint impartially, although it may only be able to consider certain types of disputes in line with its own rules and eligibility criteria.

Business customers

If you are not a consumer (for example, you are a business or commercial customer), ADR schemes may not be available to you in the same way. If you are dissatisfied with our Final Response, you may wish to seek independent legal advice regarding your options.

8. Obligor Programme – Third-Party Complaints and Reconciliation

Where Just Protect Ltd operates on an "Obligor" basis and utilises third parties (for example, administrators, dealers, or other appointed representatives) to sell, administer, or service products, we retain overall responsibility for ensuring complaints are handled in line with FCA requirements and this policy.

To support robust oversight and Consumer Duty outcomes in relation to the Obligor programme, we will:

  • Require all relevant third parties to have complaint-handling processes that are consistent with FCA DISP rules, including prompt recognition, acknowledgement, and escalation of complaints relating to Just Protect Ltd products or services.
  • Ensure that complaints received directly by third parties in relation to our products are promptly notified to us, alongside all relevant information needed for a fair and timely resolution.
  • Maintain a central complaints log that records both complaints received directly by Just Protect Ltd and those received via third parties in the Obligor programme, ensuring there is a single, reconciled source of record.
  • Operate a regular third-party reconciliation process, under which complaints data held by third parties is reconciled to our central complaints records to confirm:
    • All complaints have been captured
    • Outcomes and redress are consistent and fair
    • Reporting to the FCA and other stakeholders is accurate and complete
  • Use the reconciliation process and associated management information to identify any gaps, inconsistencies, training needs, or control weaknesses in third-party complaint handling, and to agree and track remedial actions.
  • Incorporate findings from the reconciliation process into our broader product governance, fair value, and Consumer Duty monitoring for the Obligor programme.

Third-party arrangements for the Obligor programme will be subject to appropriate contractual obligations, oversight, audit, and assurance to evidence effective complaints handling and accurate, timely sharing of complaints information.

9. Fair Treatment and Vulnerable Customers

We are committed to the FCA's Consumer Duty and Treating Customers Fairly (TCF) principles. All complaints are handled impartially and without discrimination, and we seek to remove barriers to post-sale service or resolution.

We recognise that some customers may be in vulnerable circumstances due to health, life events, capability, or financial resilience. In these cases we will:

  • Proactively identify indicators of vulnerability during the complaints process.
  • Provide additional support, communication adjustments, or extra time where appropriate.
  • Record relevant vulnerability flags in our complaints management information (MI) to support monitoring and improvements.
  • Ensure staff have appropriate training and guidance to identify and respond appropriately to vulnerability.

10. Record Keeping, Learning & Management Information

All complaints and related correspondence are recorded securely and retained for at least five years, or for longer where specific FCA rules apply (for example, until at least 11 April 2031 for relevant motor finance complaints, in line with FCA requirements).

We review complaints on a regular basis to identify opportunities for improvement, undertake root cause analysis, and monitor trends across products, channels, and customer segments.

Complaints Management Information (MI)

Complaints MI is produced for senior management and the Board and covers, among other things:

  • Complaint volumes and types by product, channel, and customer segment
  • Root causes and emerging trends
  • Consumer Duty metrics (products and services, price and value, consumer understanding, and consumer support)
  • Vulnerability indicators and support provided
  • Time to resolution, uphold rates, and redress outcomes

This MI informs our approach to product design and governance, fair value assessments, customer communications, and the identification and mitigation of foreseeable harm under Consumer Duty.

FCA Complaints Reporting

We prepare and submit FCA complaints returns in line with the FCA's reporting framework, including the consolidated reporting requirements that apply from the first reporting period 1 January to 30 June 2027 and for subsequent six-month periods.

Our systems and controls are designed to capture the data required for accurate and timely regulatory reporting, including data arising from third-party and Obligor programme arrangements.

11. Policy Review and Governance

This policy will be reviewed at least annually, and earlier where there are material regulatory, business, or product changes that may impact our complaints handling obligations or approach.

All changes to this policy are approved by Carl Eccles – Development Director. Complaints MI, root cause analysis, and actions taken to improve outcomes are reported regularly to senior management and the Board to ensure effective governance and oversight, in line with Consumer Duty expectations.

12. Accessibility

This policy is available in alternative formats on request, and we will make reasonable adjustments to support customers who have specific communication needs.

Last updated: February 2026

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