Target Australia Complaints Handling Policy

1. Introduction

1.1 Purpose

This Policy is intended to ensure that we handle complaints fairly, efficiently and effectively. Our complaint management system is intended to:

enable us to respond to issues raised by people making complaints in a timely and cost-effective way;
boost public confidence in our administrative process; and
provide information that can be used by us to deliver quality improvements in our products, services, team members and complaints handling.

This Policy provides guidance to our team members and people who wish to make a complaint on the key principles and concepts of our complaint management system.

1.2 Scope

This Policy applies to all team members receiving or managing complaints from the public made to, or about us, regarding our products, services, team members and complaints handling.

Team member grievances, code of conduct complaints and public interest disclosures are dealt with through separate mechanisms and are outside of the scope of this Policy. Please refer to Target’s Whistleblower Policy.

1.3 Organisational Commitment

Target expects team members at all levels to be committed to fair, effective and efficient complaints handling. The following table outlines the nature of the commitment expected from team members and the way that commitment should be implemented.

Who

Commitment

How

Managing Director of Target Australia

Promote a culture that values complaints and their effective resolution

Provides adequate support and direction to key team members responsible for handling complaints.

Regularly review reports about complaint trends and issues arising from complaints.

Encourage all team members to be alert to complaints and assist those responsible for handling complaints resolve them promptly.

Encourage team members to make recommendations for system improvements.

Recognises and rewards good complaint handling by team members.

Support recommendations for products, service, team members and complaints handling improvements arising from the analysis of complaints data.

Manager responsible for complaints handling

Establish and manage our complaints management system

Provide regular reports to relevant Business Managers on issues arising from complaints handling work.

Ensure recommendations arising out of complaints data analysis are canvassed with relevant Business Managers and implemented where appropriate.

Recruit, train and empower team members to resolve complaints promptly and in accordance with Target Australia’s policies and procedures.

Encourage team members managing complaints to provide suggestions on ways to improve the organisation’s complaints management system.

Encourage all team members to be alert to complaints and assist those responsible for handling complaints resolve them promptly.

Recognise and reward good complaints handling by team members.

2. Terms and Definitions

Complaint

An expression of dissatisfaction made to or about us, our products, services, team members or the handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required.

A complaint covered by this Policy can be distinguished from:

a customer complaint about a Target product;
a customer complaint about the service Target provides, which includes instore experience or online experience;
responses to requests for feedback about the standard of our service provision [see the definition of ‘feedback’ below];
reports of problems or wrongdoing merely intended to bring a problem to our notice with no expectation of a response [see definition of ‘feedback];
service requests [see definition of ‘service request’ below]; and
requests for information.

Complaint Management System

All policies, procedures, practices, team members, hardware and software used by us in the management of complaints.

Dispute

An unresolved complaint escalated either within or outside of our organisation.

Feedback

Opinions, comments and expressions of interest or concern, made directly or indirectly, explicitly or implicitly, to or about us, about our products, services or complaint handling where a response is not explicitly or implicitly expected or legally required.

Service Request

requests for action
routine inquiries about Target and its business
reports of failure to comply with laws regulated by the organisation
requests for explanation of policies, procedures and decisions.

Grievance

A clear, formal written statement by an individual about a product or service provided by Target.

Policy

A statement of instruction that sets out how we should fulfil our vision, mission and goals.

Procedure

A statement or instruction that sets out how our policies will be implemented and by whom.

3. Guiding Principles

Step 1 Facilitate complaints

Step 2 Respond to complaints

Step 3 Manage the parties to a complaint

3.1 Facilitate Complaints

People Focus

We are committed to seeking and receiving feedback and complaints about our services, systems, practices, procedures, products and complaint handling.

Any concerns raised in feedback or complaints will be dealt with in a reasonable time frame, if not immediately.

People making complaints will be:

provided with information about our complaints handling process
provided with multiple and accessible ways to make complaints
listened to, treated with respect by team members and actively involved in the complaint process where possible and appropriate, and
provided with reasons for our decision/s and any options for redress or review.

No Detriment to People Making Complaints

We will take all reasonable steps to ensure that people making complaints are not adversely affected because a complaint has been made by them or on their behalf.

Anonymous Complaints

We can accept anonymous complaints and will carry out an investigation of the issues raised where there is enough information provided.

Accessibility

We will ensure that information about how and where complaints may be made to or about us is well publicised. We will ensure that our systems to manage complaints are easily understood and accessible to everyone, particularly people who may require assistance.

If a person prefers or needs another person or organisation to assist or represent them in the making and/ or resolution of their complaint, we will communicate with them through their representative if this is their wish. Anyone may represent a person wishing to make a complaint with the appropriate consent of the individual who is making the complaint.

No Charge

Complaining to Target is free of charge.

3.2 Responding to Complaints

Early Resolution

Where possible, complaints will be resolved at first contact with Target Australia.

Responsiveness

We will promptly acknowledge receipt of complaints.

We will assess and prioritise complaints in accordance with the urgency and/or seriousness of the issues raised. If a matter concerns an immediate risk to safety or security the response will be immediate and will be escalated appropriately.

We are committed to managing people’s expectations, and will inform them as soon as possible, of the following:

the complaints process;
the expected time frames for our actions;
the progress of the complaint and reasons for any delay;
their likely involvement in the process; and
the possible or likely outcome of their complaint.

We will advise people as soon as possible when we are unable to deal with any part of their complaint and provide advice about where such issues and/or complaints may be directed (if known and appropriate).

We will also advise people as soon as possible when we are unable to meet our time frames for responding to their complaint and the reason for our delay.

Objectivity & Fairness

We will address each complaint with integrity and in an equitable, objective and unbiased manner.

Conflicts of interests, whether actual or perceived, will be managed responsibly. In particular, internal reviews of how a complaint was managed will be conducted by a person other than the original decision maker.

Responding Flexibly

Our team members are empowered to resolve complaints promptly and with as little formality as possible. We will adopt flexible approaches to service delivery and problem solving to enhance accessibility for people making complaints and/or their representatives.

We will assess each complaint on its merits and involve people making complaints and/or their representative in the process as far as possible.

Confidentiality

We will protect the identity of people making complaints where this is practical and appropriate.

Personal information that identifies individuals will only be disclosed or used by Target Australia as permitted under the relevant privacy laws, secrecy provisions and any relevant confidentiality obligations.

Empowerment of Team Members

All team members managing complaints are empowered to implement our complaints management system as relevant to their role and responsibilities.

Team members are encouraged to provide feedback on the effectiveness and efficiency of all aspects of our complaints management system.

Managing Unreasonable Conduct by People Making Complaints

We are committed to being accessible and responsive to all people who approach us with feedback or complaints. At the same time our success depends on:

our ability to do our work and perform our functions in the most effective and efficient way possible’
the health, safety and security of our team members; and
our ability to allocate our resources fairly across all the complaints we receive.

When people behave unreasonably in their dealings with us, their conduct can significantly affect

the progress and efficiency of our work. As a result, we will take proactive and decisive action to manage any conduct that negatively and unreasonably affects us and will support our team members to do the same in accordance with this policy.

4. Complaints Management System

Receive
Acknowledge
Assess and Investigate
Provide reasons for decision
Options for redress and close complaint

4.1 Introduction

When responding to complaints, team members should act in accordance with our complaints handling procedures as well as any other internal documents providing guidance on the management of complaints.

Team members should also consider any relevant legislation and/or regulations when responding to complaints and feedback.

The five key stages in our complaints management system are set out below.

4.2 Receipt of Complaints

We will always document the complaint and any supporting information when it is received. We will also assign a unique identifier to the complaint file.

The record of the complaint will document:

the contact information of the person making a complaint;
issues raised by the person making a complaint and the outcome/s they want;
any other relevant information; and
any additional support the person making a complaint requires.

4.3 Acknowledgement of Complaints

We will acknowledge receipt of any written complaint promptly, and preferably within 5 working days.

Consideration will be given to the most appropriate medium (e.g. email, letter or phone call) for communicating with the person making the complaint.

4.4 Initial Assessment and Addressing of Complaints

Initial Assessment

After acknowledging receipt of the complaint, we will confirm whether the issue/s raised in the complaint is/are within our control. We will also consider the outcome/s sought by the person making a complaint and, where there is more than one issue raised, determine whether each issue needs to be separately addressed.

When determining how a complaint will be managed, we will consider:

How serious, complicated or urgent the complaint is;
Whether the complaint raises concerns about people’s health and safety;
How the person making the complaint is being affected;
The risks involved if resolution of the complaint is delayed; and
Whether a resolution requires the involvement of other departments within the business.

In performing this assessment, complaints will be rated using the Target CSC Rating Escalation Matrix.

Addressing Complaints

After assessing the complaint, we will consider how to manage it. To manage a complaint, we may:

Give the person making a complaint information or an explanation;
Gather information from within the business that the complaint is about; or
Investigate the claims made in the complaint.

We will keep the person making the complaint up to date on our progress, particularly if there are any delays. We will also communicate the outcome of the complaint using the most appropriate medium.

Any material complaints received will also be subject to review and oversight by the Target Customer Care Forum. This Forum has several key Target senior managers as its members and is scheduled to meet weekly. It is governed by a Terms of Reference to ensure appropriate investigation and resolution of any material complaints that occur, and to minimise or negate the potential for re-occurrence.

4.5 Providing Reasons for Decisions

Following consideration of the complaint and any investigation into the issues raised, we will contact the person making the complaint and advise them:

the outcome of the complaint and any action we took;
the reason/s for our decision;
the remedy or resolution/s that we have proposed or put in place; and
any options for review that may be available to the complainant, such as liability claim to be lodged with our Insurance company.

4.6 Closing the Complaint, Record Keeping, Redress and Review

We will keep records about:

how we managed the complaint;
the outcome/s of the complaint (including whether it or any aspect of it was substantiated, any recommendations made to address problems identified and any decisions made on those recommendations); and
any outstanding actions that need to be followed up.

4.7 Alternative Avenues for Dealing with Complaints

We will inform people who make complaints to, or about us, or a product we sell about our insurance claim process, if required. This is only necessary when a customer wishes to lodge a liability claim.

4.8 The Three Levels of Complaint Handling

We aim to resolve complaints at the first level, the frontline. Wherever possible team members will be adequately equipped to respond to complaints, including being given appropriate authority, training and supervision.

Where this is not possible, we may decide to escalate the complaint to a more senior officer within Target Australia. This second level of complaint handling will provide for an assessment and possible investigation of the complaint and decision/s already made. This second level escalation may also involve review and oversight by the weekly Target Customer Care Forum.

Where a person making a complaint is dissatisfied with the outcome of Target Australia’s review of their complaint, they may refer their complaint to a Regulator for further consideration or if it is a liability claim, they may refer their complaint to our Insurance company.

Level 3 – Liability claim managed by our insurance company or an escalated complaint to a regulator

Level 2 – Internal review of complaints and/or complaint handling (may include further investigation of issues raised and use of Alternative Dispute Resolution options)

Level 1 – Frontline complaint handling and early resolution of complaints

5. Accountability and Learning

5.1 Analysis and Evaluation of Complaints

We will ensure that complaints are recorded in a systematic way so that information can be easily retrieved for reporting and analysis.

Regular reports will be run on:

the number of complaints received;
the outcome of complaints, including matters resolved at the frontline;
issues arising from complaints
systemic issues identified; and
the number of requests we receive for internal and/or external review of our complaint handling.

A weekly meeting with Senior Management will be scheduled to discuss the complaints received and what actions are required out of those meetings. These meetings will be undertaken to monitor trends, measure the quality of our products and service and make agree to make any improvements, as required.

5.2 Monitoring of the Complaints Management System

We will continually monitor our complaint management system to:

ensure its effectiveness in responding to and resolving complaints; and
identify and correct deficiencies in the operation of the system.

Monitoring may include the use of audits, complaint satisfaction surveys and online listening tools and alerts.

5.3 Continuous Improvement

We are committed to improving the effectiveness and efficiency of our complaints management system. To this end, we will:

support the making and appropriate resolution of complaints;
implement best practices in complaints handling;
recognise and reward exemplary complaints handling by team members;
review the complaints management system and complaints data; and
implement appropriate system changes arising out of our analysis of complaints data and monitoring of the system.