Introduction

This Complaints Management Policy and Procedure (the “Policy”) is intended to provide direction with regard to the resolution of complaints against Transcorp Hotels Plc (the “Company”) or the Company’s employees.

Meaning of Complaint

For the purpose of this Policy, complaint shall mean any communication that expresses dissatisfaction or displeasure with, or about an action or lack of action, conduct or behaviour of the Company, and /or employee in the course of business, or about the standard or deficiency of service or of the product of the Company and/or any of its duly authorised agents, such shall be deemed to be a complaint.

Scope

• • This Policy applies to the Company and all the employees of the Company, and to the products and services offered by the Company and dealings of the Company with third parties. However, such complaint and this Policy shall not cover the following areas:
  • Complaints on matters that are pending in court or referred to arbitration or other tribunal or administrative panel or institution established by law or pursuant to any law for decision or investigation;
  • Complaint on a matter in which a decision has been reached pursuant to a referral;
  • Complaints that are outside the purview of the Securities and Exchange Commission (SEC);
  • Complaints against private, wound up and liquidated or dissolved companies.
• For hotels under Transcorp Hotels Plc that are managed by International operators under a management agreement, the operator’s Complaints Policy under that Agreement, would apply. (For example Hilton Worldwide).
• Complaints by current employees of the Company against the Company.
• Any complaint which the Company cannot validly entertain by reason of any legal, judicial and/or regulatory provision or decision.

Purpose

The purpose of this Policy is to establish standard procedures and guidelines for dealing with complaints against the Company in an efficient, fair, equitable and impartial manner, and also in compliance with regulatory requirements and standards for public companies in Nigeria for addressing official complaints.

Other purposes of the Policy are:

To provide an avenue for effective communication and feedback from stakeholders to the Company;

• • To recognise, promote and protect the customer, vendor, client or shareholder’s rights, including the right’ to comment and provide feedback on service or product or the Company;
  • To provide an efficient, fair and accessible framework for resolving customer, vendor, client or shareholder’s complaints and monitoring feedback to improve service or product delivery;
  • To inform customers, vendors, clients or shareholders on the feedback handling processes; and
  • To provide the Company and staff with information about the customer, vendor, client or shareholder’s feedback.

Type of Complaints

For the purpose of this Policy, complaints shall be classified into the following categories of allegations:

Fraud and Suppression

• • Misrepresentation and quality assurance issues
  • Forgery
  • Issues relating to shareholding or investment in the Company

Bribery and corruption

Others matters as may be defined by the Complaints Management Committee.

Responsibility

All Employees shall ensure this Policy is adhered to while the Head, Internal Audit shall be entrusted with the ultimate responsibility for the adherence to, and enforcement of this Policy.

Procedure for registering a complaint

All complaints shall be in writing or by e-mail, addressed to the Head, Internal Audit and shall contain all material facts relating to the complaint accompanied by supporting documents. It shall also contain the following details of the complainant:

Name

Full address

GSM number

E-mail address

Signature of the complainant; and

Date.

The fact that a complaint has not complied with this procedure, in full or in part, shall not in any way be a grounds to deprive the complainant from getting the necessary feedback and/or redress from the Company on the issue complained about, provided the information provided will be sufficient for the purpose of contacting the complainant and/or determining the issues raised in the complaint.

For the purpose of this Policy, the Company’s contact, and all complaints shall be addressed to:

Head, Internal Audit

Transcorp Hotels Plc

1 Aguiyi Ironsi Maitama, Abuja e-mail: info@transcorphotelsplc.com

Phone: +234-9-4613000, +234 8039013000

Complaints may be delivered by hand, courier of by e-mail.

Complainant’s conduct

It is expected that a complainant complies with the minimum standards of good conduct, responsible behaviour and honesty based on the principles of personal integrity, relationships with others, respect and accountability.

Where a customer, vendor, client or shareholder raises a complaint, they have the right to have that complaint:

• received and addressed objectively and in strict confidence;
• addressed in a spirit of helpful cooperation and sensitivity; and
• resolved promptly. 

To assist in achieving this, complaints shall be kept in the Register of Complaints and information that would identify complainants will not be released in individual or aggregated form to anyone not involved in the resolution of the complaint without prior written permission of the MD/CEO of the Company.

When a complaint cannot be resolved to the reasonable satisfaction of the complainant by the Company, the complainant shall have the right to refer the complaint to an appropriate external body or seek any other redress provided by law.

Complaints Management Committee

There is hereby established a Complaints Management Committee (hereinafter “the Committee”) which is charged with the responsibility of conclusively resolving any complaints received. The Committee comprises the following officers:

• Head, Internal Audit (as Chairman)
• Group General Counsel (Member)
• Head, Human Capital (Member) (where the complaint is against a staff)
• Head, Administration (Member)
• Head, Marketing and Corporate Communications (Member)
• Company Secretary (Member; where a shareholder or an investors is the complainant)
• The Chief Finance Officer (where the complaint requires financial expertise to resolve)

The Committee shall meet on an ad hoc basis as complaints are received and within 3 days of receiving a complaint. The resolution of the Committee shall be forwarded to the MD/CEO for final approval before the resolution is communicated to the complainant.

The Committee shall have 20 days from the date of receipt of a complaint, or any such extension as may be granted by the MD/CEO, to communicate to the complainant the outcome/resolution of the complaint. The communication shall be in writing (and delivered by hand or courier) or by e-mail with a copy retained by the Company for reference.

The Committee shall have the powers to invite a complainant to appear physically for further verification/clarification of facts or issues complained about, or request further verification/clarification in writing or by e-mail.

Nothing in this Policy shall preclude the right of a dissatisfied complainant from seeking further redress in accordance with the law.

Employee’s right

Where the complaint is written against an employee, the employee shall be entitled to fair hearing in the determination of the complaint.

Register of Complaints

The Company shall keep and maintain an electronic Register of Complaints.

• The Register of Complaints shall contain the following information: 
• Name of the complainant
• Date of the complaint and date received
• Nature of complaint

The Register of Complaints shall be updated as complaints are received by the Company, or at least on a monthly basis.

The status reports of complaints filed with the Company shall be forwarded to the Securities and Exchange Commission (SEC) on a quarterly basis.

Waivers

The MD/CEO shall approve all requests for any waiver to this Policy.

Delegation

The delegation of signatory authority shall be in accordance with the approved procedure for the delegation of authority in the Company. Any exception to be made with regard to this Policy shall be approved by the MD/CEO. 

Review and Amendment

This Policy shall be reviewed annually and may be amended if deemed necessary.

Publicity

This Policy shall be hosted on the Company’s website and shall be made available to shareholders for their information at the annual general meetings.