Complaints Handling Policy

1. Purpose

GoReg sells personalised and cherished vehicle registration plates online. At checkout, customers may choose to Pay in 3 (three equal interest-free instalments, currently unregulated BNPL), Pay in 30 (full payment deferred 30 days, interest-free, currently unregulated), and regulated finance (6-36 months, interest-bearing, fully regulated under CONC and the CCA 1974).

This policy sets out how GoReg handles complaints in full compliance with the FCA's Dispute Resolution sourcebook (DISP 1) and the Consumer Duty (PRIN 2A). GoReg's primary complaint categories are likely to involve: the presentation or selection of Klarna finance at checkout; confusion between the BNPL and 6-36 month credit products; post-purchase cancellation or refund queries; and customer service interactions by email or telephone.

GoReg is committed to handling every complaint promptly, fairly and impartially, and to using complaint insights to drive continuous improvement in customer outcomes.

2. Scope

This policy applies to:

All complaints from eligible complainants about GoReg's regulated and unregulated activities
All Directors and staff of GoReg Ltd, including those involved in website management, checkout design, marketing and product decisions
All credit broking activities, including the presentation of both Klarna finance options at checkout
Any complaints that relate wholly or partly to Klarna's conduct as lender, where a forwarding or splitting process may be required under DISP 1.7

3. Definition of a Complaint

In line with DISP, a complaint is any oral or written expression of dissatisfaction, whether justified or not, from or on behalf of an eligible complainant, about the provision of, or failure to provide, a regulated or unregulated financial service or product, which alleges that the complainant has suffered, or may suffer, financial loss, material distress or material inconvenience.

GoReg will treat any expression of dissatisfaction as a complaint unless it is clearly an enquiry or a routine service request that can be resolved immediately to the customer's satisfaction without any investigation. When in doubt, GoReg will treat the contact as a complaint.

Complaints may be made by the customer or by an authorised representative acting on their behalf, including a debt adviser, consumer body or third party with the customer's permission.

4. Consumer Awareness

GoReg will ensure customers are aware of how to complain and of their right to refer complaints to the Financial Ombudsman Service (FOS). GoReg will:

Publish clear information about its internal complaints handling procedures on the GoReg website, in a location that is easy to find
Refer customers to the availability of that information at or immediately after the point of sale (i.e. at checkout and in order confirmation communications)
Provide written details of the complaints process, free of charge, on request and when acknowledging any complaint
Display information about the Financial Ombudsman Service, including the FOS website address (www.financial-ombudsman.org.uk), on the GoReg website and, where applicable, in the general conditions of GoReg's contracts with customers

Complaints can be submitted free of charge by any of the following means:

Email to the address published on the GoReg website
Written correspondence to GoReg's registered address
Telephone, using the number published on the GoReg website. Any telephone number used for complaints will be a basic-rate number (beginning 01, 02, 03, 07, 0800 or 0808).

Where a customer contacts GoReg other than as part of a transaction, for example, a customer who emails or calls with a query before making a purchase, or a customer who contacts GoReg post-purchase without it forming part of a sale interaction, GoReg will refer the customer to the availability of its complaints information at or immediately after that first point of contact. In practice this means that any customer-facing email response or telephone call will include or reference GoReg's complaints contact details, regardless of whether a transaction is involved.

5. Named Complaints Oversight Individual

GoReg has appointed Wesley Parker (Director, SMF29, Limited Scope Function) as the named individual responsible for oversight of GoReg's compliance with DISP 1. Wesley Parker satisfies the condition in DISP 1.3.7R(4) as a person approved to perform the limited scope function.

This responsibility includes:

Ensuring this policy is implemented, maintained and kept up to date
Reviewing and signing off all final responses before they are issued
Overseeing root cause analysis and complaints MI reviews
Ensuring lessons from complaints are fed back into staff training and process improvements
Being able to demonstrate to the FCA, on request, how GoReg's complaints handling culture and processes deliver fair outcomes for customers

6. Complaints Handling Process

6.1 Receipt and Acknowledgement

On receipt of a complaint, GoReg will send the customer a prompt written acknowledgement, in practice, the same working day or the next working day. The acknowledgement will confirm that the complaint has been received, provide an indication of the next steps, and include the name of the person handling the complaint.

GoReg will keep the customer informed of the progress of the complaint throughout the process. If the complaint is more complex and requires additional time to investigate, GoReg will contact the customer proactively with an update rather than waiting for the customer to chase.

GoReg's target is to acknowledge all complaints on the day of receipt or by 9am the following working day.

6.2 Two Resolution Routes: Fast-Track (3 Days) and Standard (8 Weeks)

Given the nature of GoReg's business, where many complaints will concern Klarna confusion, checkout queries or cancellation requests, the fast-track route is expected to apply to the majority of complaints received.

6.3 Fast-Track Route: Resolution by Close of the Third Business Day

A complaint is considered resolved under this route where the customer has indicated acceptance of GoReg's response, this does not need to be in writing.

Where GoReg considers a complaint resolved under this route, it will promptly send the customer a Summary Resolution Communication (SRC):

Confirm that the customer made a complaint and that GoReg now considers it resolved
Inform the customer that if they remain dissatisfied, they may be able to refer the complaint to the Financial Ombudsman Service
State whether or not GoReg consents to waive the relevant FOS time limits, using the appropriate wording from DISP 1 Annex 3R
Provide the FOS website address (www.financial-ombudsman.org.uk)
Refer to the availability of further information on the FOS website

The SRC will be sent by email as standard, unless the customer has requested a different communication format or has been identified as vulnerable, in which case GoReg will adapt the format accordingly (see Section 10 and GoReg's Vulnerable Customer Policy).

6.4 Standard Route: Final Response Within Eight Weeks

Where a complaint cannot be resolved under the fast-track route, GoReg will investigate the complaint and send a final response within eight weeks of receipt. The final response will either: uphold the complaint and offer redress or remedial action; or reject the complaint and give reasons for doing so.

In either case, the final response will:

Acknowledge the complaint and state whether GoReg upholds it
Detail the investigation steps taken and the findings
Set out GoReg's decision and the reasons for it
Detail any offer of redress or remedial action (e.g. refunding checkout options, fast-track fees, or offering general compensation)
Enclose a copy of the Financial Ombudsman Service's standard explanatory leaflet
Provide the FOS website address (www.financial-ombudsman.org.uk)
Inform the customer that if they remain dissatisfied, they may refer their complaint to the FOS
State whether or not GoReg consents to waive the relevant FOS time limits, using the appropriate wording from DISP 1 Annex 3R

Where GoReg is not in a position to issue a final response within eight weeks, for example, because it is waiting for information from Klarna, GoReg will by the eight-week deadline send the customer a written holding response explaining why a final response cannot yet be given, indicating when it expects to provide one, informing the customer that they may now refer the complaint to the FOS, enclosing the FOS explanatory leaflet, and providing the FOS website address.

Where a customer has already indicated in writing their acceptance of a response from GoReg before the eight-week deadline, the obligation to send a final response by eight weeks does not apply, provided that the response the customer accepted: informed them how to pursue the complaint further if they remained dissatisfied; referred to the ultimate availability of the FOS; enclosed the FOS standard explanatory leaflet; provided the FOS website address; and included the appropriate Annex 3R time-limit wording. GoReg will ensure any such response meets all five conditions before treating the eight-week obligation as discharged under DISP 1.6.4R.

6.5 Factors in Assessing a Complaint

In assessing any complaint, Wesley Parker will take into account:

All available evidence and the particular circumstances of the complaint
Whether the complaint is similar to other complaints previously received by GoReg, and the outcomes of those complaints
Relevant guidance published by the FCA, the Financial Ombudsman Service or other relevant regulators
Relevant FOS decisions on similar complaints received by GoReg
Whether the customer's circumstances indicate they may be a vulnerable customer, and whether this affected their ability to make an informed decision (see Section 10 and GoReg's Vulnerable Customer Policy)
Whether the complaint may indicate a wider or systemic issue with GoReg's products, processes or communications that requires a root cause analysis (see Section 9)

7. Complaints Forwarding, Klarna and the Distribution Chain

GoReg acts as a credit broker, not a lender. Complaints received by GoReg may relate to GoReg's own conduct as broker, to Klarna's conduct as lender, or to both.

When any complaint is received, Wesley Parker will assess which firm's conduct is at issue as the first step of the investigation. The following process applies:

Scenario	GoReg's obligation	Process
Complaint relates solely to GoReg's conduct as broker (e.g. how finance was presented at checkout, customer service, website design, communications)	GoReg investigates and responds in full	Standard investigation under Section 6. No forwarding required.
Complaint relates solely to Klarna's conduct as lender (e.g. interest charges applied by Klarna, Klarna's own customer service, Klarna repayment disputes)	GoReg forwards the complaint to Klarna promptly in writing.	GoReg issues its own final response to the customer explaining that the complaint has been forwarded to Klarna, why, and Klarna's contact details. GoReg's obligations under DISP cease for the forwarded element. The complaint clock runs from the date Klarna receives it.
Complaint relates to both GoReg's conduct and Klarna's conduct (shared responsibility)	GoReg investigates its own role in full and forwards the relevant part to Klarna.	GoReg issues a final response addressing its own conduct. The Klarna element is forwarded with written notice to the customer. GoReg does not use Klarna's involvement as a reason to delay its own response.
Responsibility is unclear at the point of receipt	GoReg investigates first and assesses responsibility as part of the investigation	Wesley Parker will determine split of responsibility during investigation. Where GoReg has reasonable grounds to be satisfied that Klarna may be solely or jointly responsible, it will apply DISP 1.7.1R promptly once that determination is made.

In all cases where a complaint is referred to the Financial Ombudsman Service, GoReg will cooperate fully with the FOS and comply promptly with any settlements or awards made by it.

8. Time-Barred Complaints

If GoReg receives a complaint that falls outside the time limits for referral to the Financial Ombudsman Service (as set out in DISP 2.8), GoReg may, reject the complaint without considering its merits.

The relevant FOS time limits are generally:

Six years from the act or omission giving rise to the complaint; or, if later,
Three years from the date the customer knew, or ought reasonably to have known, that they had cause to complain

Before rejecting any complaint on time-barring grounds, Wesley Parker will review the position and be satisfied that the relevant time limits have genuinely expired. GoReg will not use time-barring as a basis to avoid investigating a complaint where there is any genuine doubt about whether the limits have expired.

Where a complaint is rejected on time-barring grounds, the final response will:

Clearly explain why GoReg considers the complaint to fall outside the applicable time limits
Acknowledge that whether the complaint is in fact time-barred is ultimately a matter for the FOS to determine
Inform the customer of their right to refer the complaint to the FOS within six months of the date of GoReg's response
Include the appropriate wording from DISP 1 Annex 3R regarding the time limits
Provide the FOS website address

GoReg will retain a record of every time-barred rejection and the reasoning applied, as part of its complaints records under Section 11.

9. Complaint Reviews, Root Cause Analysis and Reporting

9.1 Individual Complaint Review

Every complaint, regardless of the resolution route, will be reviewed by Wesley Parker before a final response or Summary Resolution Communication is issued. This review will consider: whether the complaint has been investigated competently, diligently and impartially; whether the outcome is consistent with how similar complaints have been handled; and whether the complaint reveals any issue with GoReg's products, processes or communications that requires wider action.

9.2 Root Cause Analysis

GoReg is required to identify and remedy recurring or systemic problems. Wesley Parker will conduct a root cause analysis review of all complaints on a quarterly basis, as part of GoReg's quarterly MI review. This process will:

Analyse the causes of individual complaints to identify root causes common to types of complaint, for example, recurring confusion about the difference between the BNPL and 6-36 month credit products, patterns of customers not understanding that GoReg is a broker not a lender, or a checkout design feature that is regularly generating complaints
Consider whether any identified root cause may also be affecting GoReg's processes or products more broadly, including affecting customers who have not complained
Determine what corrective action is appropriate and reasonable, including changes to the website, checkout flow, communications, staff training or signposting
Record findings and any actions taken in writing, and document these as part of the quarterly MI review
Feed lessons learned back into GoReg's annual staff training refresh and, where relevant, into the Vulnerable Customer Policy

In addition, where the quarterly review identifies a root cause that may have caused detriment to customers who did not complain, Wesley Parker will assess whether it is fair and reasonable for GoReg to proactively contact those customers to offer redress or the opportunity to raise a complaint.

Where the Financial Ombudsman Service issues a determination against GoReg, Wesley Parker will review the determination, assess whether it indicates a systemic issue, and communicate the relevant learning to any staff involved in the relevant complaint and to the wider team as part of training.

9.3 Management Information

Wesley Parker will review complaints management information quarterly. The following metrics will be captured, reviewed and documented each quarter:

MI metric	Purpose / what it tells us
Total complaints received (by channel and subject matter)	Overall volume and nature of complaints; identifies trends in complaint type
Number resolved by close of third business day (fast-track)	Proportion of complaints resolved quickly; tests whether SRC process is operating correctly
Number closed within eight weeks	Compliance with DISP 1.6.2R time limits
Number exceeding eight weeks	Flags any process failures; triggers immediate review
Number upheld / partially upheld / rejected	Fairness of outcomes; high rejection rates may indicate systemic under-investigation
Number forwarded to Klarna (in whole or part)	Volume of complaints with a Klarna element; tests whether forwarding process is working
Number referred to the FOS and outcomes	Customer dissatisfaction rate; FOS decisions inform root cause analysis
Total redress paid	Financial impact of upheld complaints; trends may indicate product or process issues
Complaints where vulnerability was identified as a factor	Ensures vulnerable customers are not receiving worse outcomes (links to Vulnerable Customer Policy)
Comparison of upheld rates: vulnerable vs all complainants	Detects whether vulnerability is affecting complaint outcomes adversely
Root causes identified and actions taken	Evidence that DISP 1.3.3R obligations are being met and improvements are being made

Where the MI indicates that complaints are not being resolved within the required time limits, that a high proportion are being upheld in a particular area, that vulnerable customers are experiencing worse outcomes, or that the same root cause is recurring without correction, Wesley Parker will investigate the cause, implement improvements and document the action taken.

9.4 FCA Complaints Reporting

Upon authorisation, GoReg will comply with complaints reporting requirements applicable to limited permission firms.

In accordance with DISP 1.10.1A of the Financial Conduct Authority Handbook, GoReg is not subject to the standard complaints return under DISP 1 Annex 1R. Instead, GoReg will report complaints data through the consumer credit reporting framework under SUP 16.12.

GoReg will submit complaints data using the applicable consumer credit reporting data items assigned by the FCA via RegData.

This will include high-level information on:

Number of complaints received
Number of complaints closed
Number of complaints upheld
Any redress paid

Frequency and submission

Reporting frequency will be as specified by the FCA following authorisation (expected to be annual or half-yearly). Reports will be submitted via RegData within 30 business days of the end of the relevant reporting period. Wesley Parker (SMF29, upon authorisation) will be responsible for ensuring that all submissions are complete, accurate, and submitted on time.

GoReg will retain records of all complaints, including those forwarded to Klarna, and will assess whether any aspect relates to GoReg's credit broking activity when determining inclusion in regulatory reporting and internal MI.

10. Vulnerable Customers in Complaints

Where vulnerability is identified or suspected during a complaint, GoReg will handle the complaint with additional care and sensitivity, in line with the FCA's expectations under FG21/1 and GoReg's Vulnerable Customer Policy. This policy should be read alongside that document.

In practice, this means:

Applying the BRUCE framework to assess whether the customer's capacity to engage with the complaints process may be affected
Applying the TEXAS model to handle and record any vulnerability disclosure made during the complaints process
Making reasonable adjustments to how GoReg communicates, including using simpler language, providing written summaries, allowing additional time, or offering an alternative communication channel
Considering whether the customer's vulnerability may have been a factor in the original purchase decision, for example, whether they understood the Klarna finance product they selected
Ensuring the outcome of the complaint is fair and does not disadvantage the customer because of their vulnerability
Escalating the complaint to Wesley Parker for review before a final response is issued where vulnerability is a material factor

Complaints where vulnerability is identified will be flagged in GoReg's complaints records (Tab 9 of the Vulnerable Customer Compliance Log) and will be included in the quarterly MI comparison of outcomes for vulnerable versus non-vulnerable complainants.

11. Record Keeping

GoReg will maintain a record of every complaint received and the measures taken for its resolution. Records will be retained for a minimum of six years from the date the complaint was received.

Each complaint record will include:

The date the complaint was received and the channel through which it was received
The nature of the complaint and the customer or account details
Whether the fast-track (3-day) or standard (8-week) route was applied
The investigation steps taken and information obtained
Whether any element was forwarded to Klarna and the outcome of that forwarding
Whether the complaint was upheld, partially upheld or rejected, and the reasons
Any redress or remedial action offered and whether it was accepted
The date and content of the final response or Summary Resolution Communication
Whether a vulnerability factor was identified and how it was addressed
Whether the customer referred the complaint to the FOS and the FOS outcome

Complaints records are maintained in GoReg's Vulnerable Customer Compliance Log and in GoReg's secure file storage. Records are available for inspection by the FCA on request.

12. Financial Ombudsman Service, Cooperation and Referrals

Where a complaint is referred to the Financial Ombudsman Service, GoReg will cooperate fully with the FOS and comply promptly with any settlements or awards made by it.

Full cooperation includes:

Responding promptly to any requests for information or evidence from the FOS
Providing complete and accurate records of the complaint and GoReg's investigation
Complying with any directions on evidence issued by the FOS
Paying any award made by the FOS within the required timescale

Where the FOS issues a determination against GoReg, Wesley Parker will review the determination within 10 working days, assess whether it reveals a root cause requiring wider action, and ensure the relevant learning is communicated to all relevant staff.

13. Staff Training

All Directors and staff with any involvement in customer interactions, website management, checkout design or marketing will receive training covering:

GoReg's complaints handling process, including the two resolution routes and the Summary Resolution Communication
The difference between GoReg's role as credit broker and Klarna's role as lender, and how to handle complaints that involve both
The DISP 1 time limits and the consequences of failing to meet them
How to identify and handle vulnerable customers within the complaints process (BRUCE and TEXAS frameworks)
How to apply root cause analysis to identify systemic issues from complaints
The FOS referral process and GoReg's obligations once a complaint is referred

Training will be refreshed at least annually, and following any material FOS determination, any significant regulatory change, or any quarterly MI review that identifies a training gap. Wesley Parker maintains the training log in GoReg's Vulnerable Customer Compliance Log.

14. Governance and Policy Review

Wesley Parker (Director, SMF29) is the named accountable owner of this policy and the named oversight individual. This policy will be:

Reviewed at least annually
Updated following any material change to GoReg's business model, product range or customer journey
Updated following any FCA guidance change or FOS determination that requires a policy-level response
Updated where the quarterly MI review identifies a systemic issue that requires this policy to be amended

This policy forms part of GoReg's wider regulatory compliance framework alongside the Vulnerable Customer Policy and the Vulnerable Customer Compliance Log.