Complaints policy

---

JA Group Services Ltd (“the Company”) is committed to handling complaints in a manner that is fair, consistent, transparent, and proportionate.

This Stage 1 Complaints Policy establishes the Company’s informal complaints-handling framework, designed to:

• Resolve issues as early as possible
• Minimise distress or inconvenience to complainants
• Prevent unnecessary escalation
• Ensure consistent handling across all operating divisions
• Protect staff from inappropriate or abusive conduct
   

The Company will act in good faith and will use its best endeavours to resolve complaints at Stage 1 wherever reasonably practicable.

This policy applies to complaints concerning:

• Services delivered or administered by JA Group Services Ltd
• Customer, member, or stakeholder communications
• Administrative processes or decision-making
• Conduct or behaviour of staff, contractors, or representatives
• Activities undertaken by the Company’s trading divisions
   

JA Group Services Ltd is the sole handler of Stage 1 complaints.
No other group company or external party is involved at this stage.

A complaint is:

Any expression of dissatisfaction, whether justified or not, about the standard of service, conduct, actions, decisions, or omissions of JA Group Services Ltd.

The following do not constitute complaints under this policy:

• Routine enquiries or requests for information
• Marketing opt-out requests
• Suggestions or feedback not expressing dissatisfaction
   

Such matters may be responded to but are not processed as complaints.

Stage 1 is an informal resolution stage intended to:

• Clarify misunderstandings
• Provide explanations or context
• Correct errors where identified
• Offer proportionate remedies where appropriate
• Identify service or process improvements
   

At Stage 1:

• No formal investigation is conducted
• No legal findings are made
• No admission of liability is given
• Responses are issued on a without prejudice basis
   

All Stage 1 complaints must be submitted directly to the Company via:

• Email: complaints@jagroupservices.co.uk
• Written correspondence:
  JA Group Services Ltd
  167–169 Great Portland Street
  5th Floor
  Westminster
  London
  W1W 5PF

Complaints should include:

• Full name and contact details
• Clear description of the complaint
• Relevant dates, references, or interactions
• Any supporting documents or evidence
   

Anonymous complaints may be considered, but anonymity may limit the Company’s ability to respond or resolve the issue.

Upon receipt, each complaint will:

• Be logged in the Company’s internal complaints register
• Be assigned a unique reference number
• Be allocated to a Complaints Officer (CO)

The Complaints Officer is responsible for:

• Managing the complaint end-to-end
• Acting as the sole point of contact
• Ensuring consistency and impartiality
• Maintaining appropriate records
   

• Complaints will be acknowledged within 3–5 working days

The acknowledgement will confirm:

• Receipt of the complaint
• The assigned Complaints Officer
• Next steps in the process
   

The Company aims to provide a substantive response as promptly as possible, taking into account:

• The nature of the complaint
• The information required
• Any internal clarification needed
  

Where additional time is required, the complainant will be informed.

The Complaints Officer may:

• Review internal records or correspondence
• Seek clarification from relevant staff
• Request additional information from the complainant
   

All reviews are conducted proportionately and objectively.
The Company reserves the right to limit repeated requests for information where they are unreasonable.

Stage 1 outcomes may include:

• Explanation or clarification
• Apology where appropriate
• Correction of an error or omission
• Administrative adjustment
• Referral for internal service improvement
   

Stage 1 outcomes:

• Are informal
• Do not constitute a formal determination
• Do not create contractual or legal rights
   

JA Group Services Ltd expects all staff and representatives to behave professionally, courteously, and respectfully.

If a complaint relates to staff conduct, this must be reported immediately to:

complaints@jagroupservices.co.uk

Such matters may be reviewed separately under internal procedures and may result in management action where appropriate.

The Company will not tolerate:

• Abusive or offensive language
• Threatening behaviour
• Harassment of staff
• Persistent or unreasonable contact
   

Where such behaviour occurs, the Company may:

• Restrict communication to written correspondence only
• Cease engagement entirely
• Blacklist the individual from future engagement
   

This does not remove the Company’s obligation to consider the complaint fairly, but engagement must remain respectful.

A complainant may withdraw their complaint at any time by notifying the Complaints Officer in writing.

The Company reserves the right to continue internal review where:

• There are safeguarding, legal, or regulatory considerations
• Service improvement issues have been identified
   

If a complaint cannot be resolved at Stage 1, or where escalation is appropriate, the Complaints Officer may refer the matter to Stage 2 (Formal Complaints Procedure).

• Escalation is initiated internally only
• The Complaints Officer must issue the referral
• JSDS Group Ltd will engage only following a formal referral
   

JSDS Group Ltd will not communicate with any individual who approaches them directly without referral.

Complaints relating specifically to data protection or privacy matters fall outside this policy.

Such complaints must be handled by the Company’s Data Protection Team.
Individuals may also contact the Information Commissioner’s Office (ICO).

All complaints are handled confidentially and in accordance with:

• UK GDPR
• Data Protection Act 2018
• The Company’s Privacy Policy
   

Complaint records are retained securely and only for as long as necessary.

This policy does not apply to:

• Legal claims or pre-action correspondence
• Subject Access Requests
• Matters under litigation or formal investigation
• Vexatious or malicious complaints
   

This policy is subject to periodic review to ensure:

• Legal compliance
• Operational effectiveness
• Alignment with group governance

Last Updated: 13 Jan 2026