Complaints Handling Policy

This Complaints Handling Policy sets out how Lightning IP receives, records, investigates and resolves complaints from our customers, and how to take a complaint further if you're not satisfied with our response.

This policy is made available to meet our obligations under the Telecommunications (Consumer Complaints Handling) Industry Standard 2018 (the Complaints Standard), made under the Telecommunications Act 1997, and reflects the guidance the Australian Communications and Media Authority (ACMA) has published on how telcos must handle complaints.

This policy sits under Section D (Policies) of our Standard Form of Agreement and applies alongside our other Section D policies, including our Financial Hardship Policy and Privacy Policy.

This policy applies to every consumer of a Lightning IP telecommunications product or service, including residential customers and small business customers, and to anyone you've authorised to act on your behalf (for example, an authorised representative, financial counsellor, or a person you've nominated under our Financial Hardship Policy).

It applies to complaints about any of our products or services, our sales and billing conduct, and about the complaints handling process itself.

Under the Complaints Standard, a complaint is an expression of dissatisfaction made to us in relation to our telecommunications products or the complaints handling process itself, where you explicitly or implicitly expect a response or resolution.

You don't need to use the word "complaint" for something to be treated as one. If you tell us you're unhappy about something and you expect us to do something about it — for example, a billing dispute, a service fault that hasn't been fixed, a missed appointment, or dissatisfaction with how an earlier complaint was handled — we will record and handle it as a complaint under this policy.

If we're not sure whether you want something treated as a complaint, we will ask you.

A first-time request for information, technical support, or a fault report is not automatically a complaint. For example, telling us "my internet isn't working" is a fault report, not a complaint — unless you also tell us you're dissatisfied, or you ask for it to be treated as a complaint.

We recognise that some customers may not clearly express frustration due to personal, cultural or other factors even when they are unhappy. If there's any doubt, our staff will ask whether you'd like the matter treated as a complaint, and if you say yes, we will record it as one — even if we resolve it on the spot.

You can make a complaint with us free of charge through any of the following channels:

• Phone: Lightning IP complaints line — number to be confirmed
• Online / email: Lightning IP complaints webform or email address — to be confirmed
• In writing: by post to our registered business address
• In person: at any Lightning IP store or office, where applicable

You can also authorise someone else — such as a family member, financial counsellor, or other representative — to make or manage a complaint on your behalf.

We will help you formulate, make and progress a complaint if you have a disability, come from a non-English-speaking background, or are experiencing financial hardship. This includes, where reasonably necessary, arranging interpreter services (including the Translating and Interpreting Service), accepting complaints via the National Relay Service, and communicating with you in the way that best suits your needs once you've told us what those needs are.

If you're experiencing financial hardship, complaints connected to that hardship will also be handled in line with our Financial Hardship Policy.

We will acknowledge receipt of your complaint:

• Immediately, if you make your complaint in person or by phone; or
• Within 2 working days, if you make your complaint in writing (including by email or webform).

When we acknowledge your complaint, we will give you a unique reference number (or another way of identifying your complaint) so you can track its progress and refer to it in future contact with us.

We will always try to resolve your complaint the first time you contact us. If we can do this, we will still record it as a resolved complaint. If we can't resolve it on first contact, we will investigate and respond within the timeframes set out in this policy.

We treat a complaint as urgent if:

• you are experiencing financial hardship, assessed in accordance with our Financial Hardship Policy;
• your complaint relates to a service for which you receive Priority Assistance (for example, due to a life-threatening medical condition); or
• we have disconnected, or are about to disconnect, your service without following the correct process.

We will resolve urgent complaints within 2 working days of receiving them.

For complaints that are not urgent, we will:

• explain how we propose to resolve your complaint, and resolve most non-urgent complaints, within 15 working days of receiving them; and
• once you've agreed to a proposed resolution, carry out any agreed action within 10 working days, unless you agree to a different timeframe.

If we can't meet a timeframe in this policy, we will contact you before it passes to explain the reason for the delay, give you a new expected timeframe, and — if the delay will be 10 working days or more — tell you what options are available to you, including contacting the Telecommunications Industry Ombudsman (see Section 8).

Where a complaint can't be resolved at first contact, we will investigate it in a manner proportionate to its seriousness and complexity. Our investigation will consider the circumstances you've told us about, and we will aim to offer a remedy that addresses the underlying cause of your complaint, not just its symptoms.

We will resolve your complaint in the way that best suits your needs where you've told us about them — for example, by communicating with you in a particular format or through a particular channel.

We will consider a complaint resolved once it reaches a conclusion, regardless of whether the outcome is what you originally asked for. We will confirm the agreed resolution with you, including any commitments and dates, and will provide written confirmation of the outcome if you ask for one.

If we decide a complaint is frivolous or vexatious and won't be taken further, we will tell you this decision and explain your options for external dispute resolution.

If your complaint relates to part of a bill, we ask that you continue to pay any undisputed amounts while we investigate. We will not take debt recovery action or restrict your service solely because you have a genuine complaint on foot about a disputed amount.

Where you contact us because your service isn't working and we determine this is connected to a network outage or planned maintenance event, we will manage your complaint under our dedicated network outage complaints handling process, consistent with the network outage complaints provisions of the Complaints Standard.

Where reasonably practicable, we will also try to notify customers likely to be affected by a known outage (for example, by SMS, email, or through our outage status page) — see also our published Outage information.

If you're not satisfied with how your complaint is progressing or has been resolved, you can ask for it to be escalated to a manager or team leader at any time. We will review the handling and outcome of your complaint and respond to you.

At any time — including before you've finished raising a complaint with us — you may contact the Telecommunications Industry Ombudsman (TIO), a free and independent external dispute resolution service. Our membership of the TIO scheme is required under section 128 of the Telecommunications (Consumer Protection and Service Standards) Act 1999.

You can contact the TIO by:

• Phone: 1800 062 058
• Website: tio.com.au

We will never suspend, restrict or cancel your service solely because you have made, or are pursuing, a complaint with the TIO instead of resolving it directly with us.

If your complaint has not been resolved within 30 calendar days of us receiving it, and we haven't already given you information about the TIO, we will provide you with the TIO's contact details so you can seek external review if you wish.

For every complaint, we keep a record that includes: your name and contact details (or those of your representative); a unique reference number; details of the complaint and the issues raised; any proposed resolution and the date you were asked to respond by; the results of any investigation; the reasons for our proposed resolution; your response to it; the final agreed resolution and any commitments made; confirmation that agreed actions were completed; and copies of relevant correspondence.

We formally classify and analyse our complaints data at least once every 3 months to identify recurring or emerging issues, track our progress in addressing them, and improve our products, processes and customer communications.

If Lightning IP supplies more than 30,000 services in operation, we will also be subject to the Telecommunications (Consumer Complaints) Record-Keeping Rules 2018, which impose additional complaint record-keeping and quarterly reporting obligations to ACMA, recorded in calendar days. This policy will be reviewed if and when that threshold is reached.

This policy should be read together with the other Section D policies referenced in our Standard Form of Agreement, including our Financial Hardship Policy (for complaints connected to financial hardship) and our Privacy Policy (for complaints about how we handle personal information, which may also be raised with the Office of the Australian Information Commissioner).

Where our General Terms (Section A), Product Specific Terms (Section B) or Common Terms (Section C) refer to a complaints process, that reference means the process set out in this policy.

The Telecommunications (Consumer Complaints Handling) Industry Standard 2018 is periodically reviewed and amended by ACMA, and the industry Code that historically sat alongside it (the TCP Code, C628:2019) is currently being replaced by a new ACMA-made industry standard. Because of this, this policy is maintained as a standalone Section D document so it can be updated independently of the main Standard Form of Agreement text as those instruments change. Customers are encouraged to check this page for the current version.