Wholesale Advice Complaints Policy

About this Document

This policy outlines how wholesale clients can make a complaint, how we will respond, and the options available if a client is dissatisfied with our handling of their concerns. As a wholesale-only advisory business, we are not required to be a member of the Australian Financial Complaints Authority (AFCA) and external escalation options differ from those available to retail clients.

We remain committed to professional, fair and timely resolution of all complaints and expect all parties to engage respectfully in the process.

This version of the Complaints Policy was adopted on 27 March 2026.

How to Make a Complaint

You can make a complaint in any of the following ways:

• Email: shannon@grimsey.com.au
• Phone: (03) 8341 8888 (or +61 3 8341 8888 if calling from overseas)
• Mail: Ground Floor West, 32 Lincoln Square North, Carlton VIC 3053

Please include:

• Your name
• how you would like us to contact you (for example, by phone, email)
• what your complaint is about; and
• the outcome you are seeking.

If You Need Help to Make a Complaint

If you need help to make or manage your complaint, you can appoint someone (for example, a relative or friend) to represent you. Please note that we will need your authority to speak to any representative that you appoint.

How We Will Deal With Your Complaint

Acknowledgement

We will acknowledge receipt of your complaint and try to resolve it as quickly as possible. Generally, where your complaint is made:

• Verbally – we will acknowledge your complaint in the same manner.
• In Writing – by email or via post, we will acknowledge your complaint, in writing, within one business day or as soon as practicable thereafter.

When acknowledging your complaint, we will also have regard to any preferences you have communicated to us in relation to the way in which you wish for us to communicate with you.

Investigation

If we cannot resolve your complaint immediately, we will need some time to investigate your concerns. We may also request that you provide us with further information to assist with our investigation.

Our Response

We will provide a written response outlining the outcome of our review and the reasons for our decision. While wholesale clients are not covered by the retail client Internal Dispute Resolution (IDR) timeframes, we aim to respond within 30 calendar days, or sooner where possible.

Our written response will:

• address the issues raised in your complaint.
• outline our findings and the information relied upon; and
• provide sufficient detail for you to understand the basis of our decision.

If your complaint is resolved sooner to your complete satisfaction, and you do not request a written response, we may not issue a formal written outcome.

Delays

If unforeseen circumstances or complexity prevent us from providing a response within our targeted timeframe, we will notify you of the delay and provide an indicative timeline for completion.

Escalating Your Complaint

If you are not satisfied with our response to your complaint, or the manner in which we have handled it, you may escalate the matter through the following avenues:

1. Internal Escalation
You may request that your complaint be reviewed by a senior manager or director who was not directly involved in the original matter.

2. Privacy‑related Complaints (if applicable)
If your concern relates to the handling of personal information, you may contact:

Office of the Australian Information Commissioner (OAIC)

• Email: enquiries@oaic.gov.au
• Phone: 1300 363 992
• Online: www.oaic.gov.au

3. Independent External Options
As a wholesale‑only advice business, external dispute resolution schemes such as AFCA do not apply. If you remain dissatisfied, you may seek independent legal advice or pursue resolution through mediation, arbitration, or the courts, depending on the nature of the matter.

Our Commitment

We aim to handle all complaints promptly, professionally, and respectfully. We value feedback as an opportunity to strengthen our governance, improve our services, and address any issues identified.