Complaints Handling System Policy
(Competition and Consumer Law)

1. Our commitment
   1. We at Techtronic Industries Australia Pty Limited (TTI/Us/We/Our) strive to deliver quality service and the best possible products for our customer’s needs. TTI is committed to compliance with all laws. Compliance with the Competition and Consumer Act 2010 (CCA) is a critical element of this commitment.
2. Policy
   1. We understand that sometimes you may feel dissatisfied with the services or products that we provide, or you may feel dissatisfied with our customer service, and you may wish to make a complaint. This Complaints Handling System Policy (Policy) is intended to ensure that we handle complaints effectively and promptly.
3. Definitions
   1. In this Policy:
      1. Complaint means an expression of dissatisfaction made to us or about us, relating to our products, services, customer service, staff, or our handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required; and
      2. Complainant means any person, organisation or their representative making a complaint.
4. How to make a complaint
   1. You may make a complaint:
      1. Via our website https://www.harttools.com.au/;
      2. By calling our Customer Service Team on 1300 698 130;
      3. Email - for all consumer law complaints, product enquiries and Product warranty claims or complaint by email to customerservice@ttibrands.com.au, or
      4. Email - for all competition law complaints only by email to complianceofficer@ttibrands.com.au, or
      5. By post to Techtronic Industries Australia Pty Ltd, 31 Gilby Road, Mount Waverley Vic 3149.
   2. We will acknowledge your complaint. All complaints will receive a written acknowledgement confirming the complaint has been received and a response will be provided in a reasonable and timely manner. We may request additional information be provided to ensure an efficient resolution.
   3. Your complaint will be handled in each case in accordance with the Complaint Handling Flowchart at Annexure A.
   4. We will assess your complaint and keep you informed about the progress of your complaint.
   5. Upon resolution, you will be provided with an outcome.
5. Acknowledgement and consent
   1. You acknowledge that the information you provide in feedback (including compliments) or a complaint that you submit by email, phone, or mail, may involve the sharing of your personal information with other relevant areas within our business.
   2. This occurs so that:
      1. your feedback and complaint can be further discussed; and
      2. information or documents can be obtained from them relating to your feedback or complaint.
   3. By submitting your feedback or complaint you consent to the disclosure of the feedback or complaint in the manner and for the purpose/s described here unless you advise otherwise in your submission.
   4. If you do not provide us with information regarding your feedback or complaint or consent to disclose your personal information to relevant areas within our department, this may limit our ability to assist you.
   5. We may also seek further information from you in relation to your feedback or complaint.
   6. For information on how we collect, use and store personal information, you should refer to the TTI Privacy Policy on our website at https://www.harttools.com.au/privacy-policy-cookie-restriction-mode
   7. We will endeavour to resolve your complaint and/or acknowledge your feedback in an efficient and timely manner.
6. Principles of objectivity
   1. Your complaint will be handled in an equitable, unbiased, and objective manner. We aim to resolve the complaint without assigning blame.
   2. We shall comply with the below principles when managing your complaint:
      1. Impartiality – We will avoid any bias in dealing with your complainant, the person you complain about or TTI.
      2. Confidentiality – We will treat your identity confidentially.
      3. Completeness – We will investigate all the facts in handling the complaint.
      4. Accessibility – You may make your complaint at any reasonable point or time.
      5. Equitability – We will give equal treatment to all people.
7. Three level model of complaint handling
   1. Our complaint management system incorporates three levels of complaint management:
      1. Level 1: Frontline complaint handling – early resolution.
      2. Level 2: Internal assessment, internal investigation, facilitated resolution or review.
      3. Level 3: External assessment, investigation, or review.
   2. We aim to resolve most complaints at the first level - ‘the frontline’. At each level, either the complainant or we can decide to escalate the issue to a higher level. However, there may be some serious cases where either party can escalate the case to the highest level.
   3. Level 1: Frontline complaint handling – early resolution
      1. We aim to address most complaints by frontline or early resolution.
   4. Level 2: Internal assessment, internal investigation, facilitated resolution or review
      1. The seriousness of some complaints will require them to be escalated to the second level of complainant handling. Or if a complainant is dissatisfied with how their complaint was handled at Level 1, they can request that the complaint proceed to the second level.
         1. Internal assessment - The information provided by you will be assessed to determine whether, and if so how, the complaint can be dealt with by TTI. Such an assessment might consider such issues as:
            1. the nature and seriousness of the matters alleged.
            2. the complainant's desired outcome.
            3. whether there is any utility in taking the matter further.
            4. the adequacy of the information provided.
            5. the options available to address the complainant's concerns.
            6. the appropriate level at which the matters alleged or complained about can be addressed by TTI.
         2. Internally facilitated resolution – This is where TTI’s line manager talks with you to see if some form of mutually acceptable resolution can be achieved. Where appropriate, this process may include facilitating a discussion between the frontline staff member, line manager and the complainant.
         3. Internal investigation - Investigating allegations that raise significant issues for either TTI or you. Depending on the circumstances, such investigations may be undertaken by an appropriate manager or an external legal advisor.
         4. Internal review - A senior member of staff or a line manager may review the decision of the frontline staff member or the outcome of any internal assessment or investigation of the complaint. Appropriate senior staff are given broad discretion to overturn previous decisions and apply remedies.
   5. Level 3: External assessment, investigation, or review
      1. If we are unable to resolve your complaint in Level 1 and/or Level 2, or if you are dissatisfied with the outcome that we have made in Level 1 and/or 2, then you may refer the matter as follows:
         1. Consumer Affairs/Fair Trading/Australian Competition & Consumer Commission
            
            If you are not satisfied with the outcome of your complaint, you may refer your complaint to the relevant Consumer Affairs/Fair Trading office in your State/Territory or to the ACCC.
         2. Court or Tribunal
            
            If you are still not satisfied with the outcome of your complaint by Consumer Affairs/Fair Trading or the ACCC, then you may approach the relevant Court or Tribunal in your State/Territory.
8. Complaints Register
   1. All complaints, and outcomes of each complaint will be logged in our Complaints Register.
9. Keeping you informed
   1. We will advise you as soon as possible of receipt of your complaint and the expected timeframe for resolution of that complaint.
10. How long will we take to deal with your complaint
    1. We will advise you of the outcome of your complaint within 21 days of receipt.
    2. However, where additional time is required, we will inform you of the need for more time to complete the investigation and we will complete the investigation within 45 days of receipt of the complaint.
11. No cost
    1. There is no cost to you to make a complaint to us.
12. Unreasonable conduct
    1. Complaint conduct is likely to be unreasonable where it involves behaviour which, because of its nature or frequency, raises substantial health, safety, resource, or equity issues for TTI or its staff. Examples include unreasonable behaviour (e.g. verbal abuse of our staff), unreasonable persistence, unreasonable demands or unreasonable lack of cooperation.
    2. We require and expect that complainants treat our staff with respect at all times.
13. Acknowledgments
    1. This Policy has been drafted considering the Australian and New Zealand Standard Guidelines for complaint management in organizations AS 10002:2022.
14. Review
    1. We will review this Policy regularly.
    2. This is version 1.0 of the Policy and was created on 9 May 2024.

ANNEXURE A - COMPLAINT HANDLING FLOWCHART