Purpose
Conduct a fair, thorough, confidential and documented investigation using relevant evidence and competent input, as mandated by section 8 (Investigation Process) of the approved Client Complaints Handling Manual.
Investigation Requirements
The Complaints Officer will conduct an impartial and thorough investigation, collect and review all relevant evidence, documentation, and witness statements, engage relevant internal teams (Compliance, Finance, IT) or external experts where necessary, ensure confidentiality at all times protecting personal data and sensitive information, and document all steps taken to create a clear audit trail.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Review the complaint and investigation scope | Complaint, requested outcome, prior communications, and investigation scope. | Investigation plan |
| 2 | Collect and review relevant evidence | Evidence, documentation, and witness statements. | Evidence index |
| 3 | Engage relevant teams and experts | Internal teams (Compliance, Finance, IT) or external experts where necessary to support the investigation. | Engagement record |
| 4 | Conduct interviews | Interview the complainant, employees, witnesses, or experts where necessary. | Interview notes |
| 5 | Preserve evidence and build the audit trail | Preserve original evidence, record provenance, and document every material investigation step to create a clear audit trail. | Evidence index / audit trail |
| 6 | Test facts against applicable requirements | Applicable terms, policies, controls, legal and regulatory duties, and fair-treatment expectations. | Findings record |
| 7 | Maintain confidentiality | Ensure confidentiality at all times, protecting personal data and sensitive information; avoid disclosure that would breach legal or anti-tipping-off duties. | Confidentiality confirmation |
| 8 | Document findings and root cause | Facts, evidence, credibility, findings, root cause, and any control weakness. | Findings and root-cause record |
Records
- Investigation plan and evidence index
- Collected evidence, documentation, and witness statements
- Engagement records for internal teams (Compliance, Finance, IT) and external experts
- Investigation notes and complete audit trail documenting all steps taken
- Findings, root cause, and control-gap assessment
- Confidentiality and personal-data protection confirmation
Relationships
- Policy: POL-COMP-001 Client Complaints Handling Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-COMP-004 Ensure Complaint Investigations Are Fair Complete and Evidenced
History
- 2026-07-28: Enriched with full operational details from PDF section 8 (impartial investigation, evidence/witness collection, internal team engagement, confidentiality, audit trail).
- 2026-07-26: Created from section 8 of the approved COMP Manual.