Compliance Officer (“CO”)   

Natural person primarily responsible for overseeing and managing regulatory compliance issues within an organisation. The CO (including Local Head of Compliance) typically reports to the Chief Executive Officer and/or Chief Operations Officer, Managing Director, Regional or Global Compliance or directly to the Board of Directors in other cases as appropriate. CO as used herein may encompass the duties of the Money Laundering Reporting Officer in certain jurisdictions.


A Complaint is defined as an expression of dissatisfaction (oral or written) from an Apex client or any counter-party to an administrative fund services or corporate services agreement, as applicable (jointly referred to as “Client”), about the provision of, or failure to provide a service under such agreement(s). The Complaint must have caused, or may cause:

  • Financial loss;
  • Material distress; or
  • Material inconvenience.

Risk Officer (“RO”)

Natural person primarily responsible for overseeing and managing risk issues within the organisation. The RO typically reports to the Chief Risk Officer or Regional Head of Risk.

Event Management Log

Complaints Log to be maintained for Complaints filed by clients or customers to be kept by the local CO with respect to any and all Complaints lodged.


An individual making a formal Complaint


As an AFS Licensee, Apex entities in Australia ensure that our dispute resolution system meets the requirements of the Corporations Act 2001, ASIC Regulatory Guide 165, and ASIC Regulatory Guide 271.

This procedure has been developed having regard to relevant legal requirements and current best practices, including the guidance provided in Australian/New Zealand Standard AS/NZS10002:2014 Guidelines for complaint management in organisations



Apex Group Ltd. and wholly owned entities of Apex in Australia  (hereafter “Apex”) are committed to delivering the highest standard of service to our clients and ensuring that all complaints are resolved satisfactorily and in a timely manner. We will work with you to resolve any concerns raised and treat you with respect throughout the resolution process.

The objective of this policy is to assist the company, its executive team, and employees in resolving complaints in an efficient, effective, and professional manner.

This Complaints policy is written to comply with and in accordance with the regulatory obligations as an AFS Licensee. We ensure that our dispute resolution system meets the requirements of the Corporations Act 2001, ASIC Regulatory Guide 165, and ASIC Regulatory Guide 271.

We have developed this policy, having regard to relevant legal requirements and current best practices, including the guidance provided in Australian/New Zealand Standard AS/NZS10002:2014 Guidelines for complaint management in organisations. The legislation provides a framework to the processing of complaints made by a person or organisation  ‘the Complainant’ in a timely and appropriate manner and sets the minimum criteria for Apex’s investigation into a complaint to be conducted in a prudent manner.

For complaints in respect of, or requests for refunds by, the Registered Training Organisation (RTO) services provided by Apex Compliance Solutions (Australia) Pty Ltd please refer to the Addendum. 


The purpose of this document is to provide clear, precise and up-to-date information on the procedures implemented by Apex, in regards to how it manages the complaints process for any Customer that wishes to make a Complaint, or expresses dissatisfaction with the services provided by Apex.

What is a complaint?

Apex has adopted the following definition of a ‘complaint’ which is set out in RG 271.27 (AS/NZS 10002:2014)

“[An expression] of dissatisfaction made to or about an organization, related to its products, services, staff or the handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required”.

Any person or organisation (the “complainant”) who is dissatisfied with a product or service provided by the company, may contact Apex to make a complaint. A complaint may be oral or written.

Our internal dispute resolution (IDR) process is free, and you can lodge your complaint to Apex online by email, by phone or in person (contact details are outlined below under the subheading ‘. Lodging a Complaint’).

What is not a complaint?

Apex has adopted the definition of what is not a complaint in line with RG 271. In accordance with RG 271, the following is not considered a complaint:

“For avoidance of doubt, we do not consider the following to be ‘complaints’: employment-related complaints raised by financial company staff; [1]

  • comments made about a company where a response is not expected, such as: (i) feedback provided in surveys; or (ii) reports intended solely to bring a matter to a financial company’s attention—for example, that an automatic teller machine (ATM) is damaged. [2]
  • Financial company’s structure and resource their complaint management function(s) differently. Smaller companies may have one person responsible for complaints, along with other duties. Medium-sized and large companies may empower their frontline staff to resolve complaints at the first point of contact, and also provide further opportunities for matters to be considered by a specialist complaints team if complainants are not satisfied with the initial action taken. Some companies, especially in the banking sector, also offer customer advocates as an additional escalation point.
  • Regardless of a company’s structure, it is the complainant’s expression of dissatisfaction (that meets the definition of ‘complaint’ in RG 271.27) that triggers a company’s obligation to deal with the matter according to our IDR requirements, not the referral of a complaint to a specialist complaints or IDR team.” [3]

The specific objectives of this policy are to:

  • To deal with Complaints fairly, efficiently and effectively;
  • To ensure that all Complaints are handled in a consistent manner throughout;
  • To increase Client satisfaction;
  • To use Complaints constructively in the planning and improvement of all services.


Our Internal dispute resolution matrix outlines our commitment to providing fair and effective outcomes.




Our Complaints Handling Policy is available on the Apex Group Website and also available internally. Our Complaints Handling Policy is accessible to all executives, directors, employees, and customers.


Our Complaints Handling Policy is readily accessible to all executives, directors, employees, and customers. The Policy is easy to understand and includes details on making and resolving complaints.


Upon receipt of each complaint, Apex Group will acknowledge each complaint by way of written letter or email to the complainant within 24hours (or as soon as practicable). Complaints will be handled in a fair, efficient, and effective manner. Complainants will be treated courteously and kept informed of the progress of their complaint throughout the complaint-handling process.


Each complaint is addressed in an equitable, objective, and unbiased manner through the Complaints-handling process.

No Fees

There will be no charges or fees to the complainant for making a complaint or for our internal dispute resolution process.


Information that is personally identifiable that concerns the complainant is actively protected from disclosure unless the complainant expressly consents to disclosure.

Customer Focus

All employees of Apex Group, including the members of the Board, the Chief Executive Officer, and the executive team, are committed to efficient and fair resolution of complaints. We actively solicit feedback from our clients on a regular basis and acknowledge a client’s right to complain.


All employees accept responsibility for effective complaints handling. The Chief Executive Officer and members of the executive team will ensure that, where appropriate, issues raised in the complaints handling process are reflected in employee performance evaluation.


Our complaints handling process will be reviewed periodically in order to enhance its efficient delivery of effective outcomes.



Apex will publicise information about how and where complaints may be made, by publishing our complaints policy online, and this will be available in hard copy on request Apex will endeavour to be proactive and innovative in its approach to promoting awareness about the IDR process and sourcing complaints from vulnerable people and groups


You may lodge your complaint through the following methods—including telephone, email, letter, in person, or online. The details of which, are outlined below under subheading ‘4. Lodging a Complaint’. Should you prefer to have an authorised representative lodge your complaint or act on your behalf, please advise us of this. We will require your verbal or written consent.

No charges

The IDR process is free and there will be no fee charged in sending you material explaining the IDR process. There will also be no fee for making or pursuing your complaint via the IDR process.

What does this Policy not apply to?

In order to continuously better the company, whilst valuable, feedback that is negative may not require a resolution or formal complaint. This Policy does not apply to feedback of this nature. Nor does this policy apply to recruitment or employment-related complaints and grievances. Any such inquiries will be forward to the appropriate person in Apex for consideration in accordance with legal requirements. This Policy only applies to complaints about services or products provided Apex. Furthermore, this policy does not apply to complaints made about Apex Group outside of Australia; however, if a complaint is regarding any of the offices located outside of Australia, the complaint will be addressed by the relevant jurisdiction or by our external providers. The policy will however apply to any Australian domiciled fund administered from our Singapore and Hong Kong offices.

This Policy does not apply to Complaints made about our clients, in which case, we will send you an acknowledgement letter and refer your complaint directly to the fund manager or responsible entity.


We are committed to acknowledging all complaints upon receipt and we will email you an acknowledgement within twenty-four (24) hours (or as soon as practicable) of receiving your complaint. Once a complaint has been received, we will undertake an initial review of the complaint.


Once we have reviewed your complaint, we will endeavour to resolve your complaint by the end of the fifth (5th) business day after receiving the complaint. However, if we cannot resolve your complaint, we will then provide you with a written response within thirty (30) days of receiving your complaint. If in the event the complaint is not resolved within thirty (30) days we will provide regular updates on any progress. If you are dissatisfied with Apex’s response to your complaint, you have a right to refer the matter to an independent external organisation, the Australian Financial Complaints Authority (AFCA). Apex has membership with AFCA. The service provided to you by AFCA and our efforts in resolving your complaint through our IDR process, both of which are completely free of charge to you. We will provide an IDR response to you within the timeframes ([4]) set out below (and in accordance with RG 271).


If you have a complaint about one of our clients (Financial Company, Responsible Entity or Fund Manager), Apex will only send you an acknowledgement letter and then escalate your complaint directly to the Financial Company, Responsible Entity or Fund Manager; they will contact you directly in relation to your complaint.


In some instances, we may require more time to investigate your complaint and we will notify you by way of your preferred method of communication. However, Apex will endeavour to respond to your complaint as prescribed by the timeframes outlined in RG 271 and as set out in Table 2 below.


We will use the information you have provided us to assess your complaint, conduct the investigation and seek a resolution. In order to effectively investigate your complaint, we may need to share the information you give us with:

  • The people or team your complaint is about;
  • Other people within Apex who may assist us with investigation of your complaint;
  • Where your complaint is made on behalf of an organisation, that organisation.
  • Where your complaint involves multiple parties, including Apex or Apex clients, those other parties.

We will comply with privacy legislation at all times. Personally, identifiable information will not be disclosed to third parties unless the complainant expressly consents to its disclosure or applicable privacy legislation allows us to do so. We may also collect information about you from the parties listed above where it is necessary to investigate your complaint. We may also need to collect further information from you in order to investigate your complaint. If you do not provide this information, we may need to discontinue investigating your complaint as the investigation may be hindered by the lack of required information. We will inform you if that is the case.


 Please note that all correspondence from Apex in relation to your complaint (wholly or in part) is strictly confidential and should not be shared with any person or company without consent from Apex (with the exception of AFCA and if you have legal representation).


Complaints will be reviewed by the Compliance Team to identify any ongoing systemic or recurring issues. If such issues are identified,  Apex will determine what actions to take to in order to address these problems. Apex’s complaints handling process and this policy will be reviewed periodically to enhance its delivery of timely and effective outcomes. This review will be performed by the Compliance Team or an appropriate appointee.

Apex believes that responding to and learning from these processes is an essential part of Apex’s commitment to continuous quality improvement.

  • Employee Responsibilities
    • Initial Notification

The potential Complaint must be notified by email to the local CO and local RO with their line manager in copy immediately on receipt of the potential Complaint. The email notification must include:

  • The date the complaint was received;
  • The employee who received the complaint;
  • The name of the complainant;
  • Details of the nature of the complaint;
  • Whether the complaint involves a breach of the regulatory requirements;
  • If the complaint has been able to be resolved
  • A complaint acknowledgement must be sent to the complainant within 24 hours of receiving the complaint and must include a complaint identifier number.
  • The complaint team will notify the Client of the complaint with 24 hours of receipt to advise that;
      • A complaint has been received
      • A short description of the complaint and
      • To let client know that Apex is investigating the complaint details and will provide a timeline of events to support the complaint resolution

A Complaint Report must also be prepared and needs to include all the details of the potential Complaint. The template Complaint Report is available from the local CO. This Complaint Report must be sent to the MD, local CO and local RO within 5 business days of the potential Complaint being made.

A Complaint received from investors, fund promoters, management companies or distributors of an investment fund managed under a sub-delegation arrangement, the local Apex office must forward the Complaint Report to the relevant Apex entity directly appointed as the Fund Administrator (eg Apex Bermuda) plus the relevant local RO for that entity (if different from the local RO already included in the initial notification) with regular updates provided on the status of the Complaint.

  • Management and Compliance Responsibilities

Line managers are responsible for the investigation of potential Complaints directly related to their areas of operation.

The Compliance Team and Line Managers are responsible for overseeing the process of monitoring and reporting the progress of the potential Complaint and any responses made.

The local CO is responsible for:

  • coordinating this procedure, including the analysis of data alongside Risk;
  • forwarding the Complaints Report and updating other Apex offices (under sub-delegation arrangements);
  • recording the Complaint Report in the Complaint Management register.
  • report the Complaint in the monthly compliance report;
  • record any/all updates to the status of the Complaint in the Complaint Management register


    • Making a Complaint

 You can contact us by using the details below:


The Compliance Officer

Apex Fund Services Pty Ltd

Level 10, 12 Shelley St

Sydney NSW 2000


Email: registry@apexgroup.com
international: +61 2 8259 8888


Apex Fund Services (Sydney) Pty Ltd

Level 10, 12 Shelley St

Sydney NSW 2000



Apex Fund Services (Australia) Pty Ltd

Level 13, 459 Little Collins Street

Melbourne, VIC 3000



Apex Superannuation (Australia) Pty Ltd

GPO Box 137

Brisbane QLD 4001

Email: info@apexgroup.au 

Phone 07 3238 1200 (8.30 am – 5.00 pm AEST, weekdays)

If you are not satisfied with our response to your complaint, you may lodge a complaint with the Australian Financial Complaints Authority (AFCA) for an independent review of your matter. AFCA is a free and independent external dispute resolution scheme to deal with complaints from consumers in the financial system.  Apex Fund Services and Apex Superannuation Services are members of AFCA.

Contact details for AFCA

Australian Financial Complaints Authority GPO Box 3 Melbourne VIC 3001 (Australia) Email:  info@afc.org.au

Phone:  1800 931 678

More information about AFCA is available at www.afc.org.au

  • Handling the Complaint

Upon receipt of any Complaint (written or otherwise), Apex will record the relevant details, including the date and time of receipt. A written acknowledgement will be issued to the Complainant within 24 hours unless the Complaint has been fully resolved within the intervening period.

The acknowledgment letter will also include the name and contact details of the person in charge of the Complaint handling process.

In accordance with the Apex procedures, Apex will provide the Complainant with a written explanation of the outcome of the investigation and any actions taken to solve the Complaint. This will be issued no later than 30 days after date of receipt of the Complaint.

If required by local legislation, the Complainant must be informed of their right to seek legal advice or other avenues for the resolution of the Complaint, if they are not satisfied with the result of the investigation.

  • Risk Incidents Reports:

Serious Complaints involving any of the below will be escalated to the Regional MD, the Regional CO, Regional RO, Group HR and the Executive Committee of Apex Group, as applicable:

  • Inappropriate behaviour of staff (e.g. rudeness, discrimination or harassment) will be directed to the relevant Risk Committee, and if appropriate, the Human Resource Manager. As in (1), the initial acknowledgement by the responsible officer, detailing the likely action to be taken, will occur within 10 working days.
  • Serious Complaints involving personal injury, a breach of the law or financial implications. Once again, the initial acknowledgement should be made within 10 working days by the responsible Complaint owner.
  • Any appeal against a response from a Complainant should be referred to the Regional MD or Regional CO and Regional RO for resolution.


  • Other Circumstances:

In instances where an answer or mutual resolution cannot be provided within the above stated timescale, Apex will inform the Complainant of the causes of the delay and indicate the date at which a response is likely to be provided.


If you require further assistance:

National Relay Service

Phone:1800 555 660

Website: https://www.communications.gov.au

Translation/Interpreting Service

Phone: 131 450

Website: https://www.tisnational.gov.au/

Sign Language

Phone: 1300 287 526

Website: https://auslanservices.com/


























  1. Addendum


Complaints Policy



1.    A complaint should first be lodged with RTO administration within 20 business days of the issue arising, where practicable.  This can be undertaken in writing, over the phone, or in person.

In writing GPO Box 2404 Brisbane Qld 4001

In person Level 1, East Tower 410 Ann Street Brisbane Qld 4001

By phone 07 3238 1272

By email training@apexcompliancesolutions.com.au


2.    A written response will be provided within 10 business days.

3.    Where the outcome is not satisfactory to the learner/client, the RTO Manager should be contacted in writing (mail/email), setting out:

·         The circumstances surrounding the issue

·         Who was involved

·         Why a complaint is being lodged

·         Any evidence including dates and documentation

·         The name of any witnesses who could support the case

4.    Management will consider the complaint and the learner/client will be notified in writing of the outcome.

5.    Where a complaint will take longer than 60 calendar days to finalise, the RTO must inform the complainant.

6.    If the learner/client is not satisfied with the outcome, the complaint will be referred to an independent person, who is agreed to by both parties, and the learner/client will have an opportunity to formally present their case.

7.    Complaint and outcome must be entered into the Complaints and Appeals Log.










RTO administration




Assessment Appeals Policy



1.    Where appropriate the candidate should first approach the assessor concerned within 20 business days of receiving the assessment result, where practicable.

2.    A written response will be provided within 10 business days.

3.    Where the outcome is not satisfactory to the candidate, the RTO Manager should be contacted in writing (mail/email), setting out:

·         The circumstances surrounding the issue

·         Who was involved

·         Why an appeal is being lodged

·         Any evidence including dates and documentation

·         The name of any witnesses who could support the appeal

4.         Management will consider the appeal and the candidate will be notified in writing of the outcome and the reason for the decision.

5.         Where an appeal will take longer than 60 calendar days to finalise, the RTO must inform the appellant.

6.         If the candidate is not satisfied with the outcome, the appeal will be referred to an independent person, who is agreed to by both parties, and the candidate will have an opportunity to formally present their case.

7.         Appeals must be entered in the Complaints and Appeals Log – including corrective action and outcomes.




RTO Manager




Referrals Policy



If a learner/candidate is still unsatisfied  with the outcome, they must be informed that they can contact the National Training Complaints Hotline on 13 38 73.


RTO Manager


Refund Policy

The RTO Refund Policy (Policy) applies to the RG146 General Advice in Superannuation and RG146 Refresher (Superannuation) qualifications delivered by Apex Compliance Solutions (Australia) Pty (a Registered Training Organisation RTO #32151).


This Policy provides learners and clients with the applicable information about when a refund may be provided, how to apply for a refund and any applicable fees.


Cancellation of training

A refund of course fees will be provided where Apex Compliance Solutions is required to cancel a course before it commences.


Where a learner wishes to cancel an enrolment, the level of refund will be based on the timing of the cancellation. A cancellation fee of 50% applies where a learner cancels within 14 days of the commencement date.


Student substitution can occur without additional fees being charged provided advice is given in writing prior to the course commencing.


In the case of online learning, training and assessment is deemed to have commenced once the learner has been issued a username and login and these have been used to access the online material.


Refund process

Steps taken


1.      The learner or client must provide written notice (i.e. by email to training@apexcompliancesolutions.com.au  )of the cancellation.

Learner or client

2.      Confirmation of request to cancel will be provided.

RTO administrator

3.      Refunds will be paid to the person or organisation that made the original payment. Compliance Solutions may contact an employing organisation to confirm the refund rather than reallocation of an enrolled space.

RTO administrator

4.      A record of the refund process and correspondence will be maintained in the learner’s electronic file.

RTO administrator


Publication of the Policy

This Policy is made available prior to enrolment or at the commencement of the training or assessment through the:


  • Student Handbook
  • RTO’s website



[1] RG 271.33.

[2] RG 271.33.

[3] RG 271.35.

[4] Maximum timeframes for financial firms to provide an IDR response table can be found in ASIC Regulatory Guide 271, at page 21-22 or  https://asic.gov.au/media/3v2oejls/rg271-published-30-july-2020-20210608.pdf



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