Complaints Management Policy
I. Scope: This policy sets out the manner and circumstances in which 11 PLC (The Company) shareholders may contact the company and how it will provide assistance in addressing shareholders’ concerns. It also provides the opportunity for the company shareholders to provide feedback on matters that affect shareholders. This policy only relates to 11 PLC shareholders, and does not extend to the company’s customers, suppliers or other stakeholders. 11 PLC’s share registry has its own resolutions handling procedures and policies, which are not governed by this policy. The share registry may be contacted on the details provided in section 13 of this policy.
II. Objective: This policy is designed to ensure enquiries and complaints from 11 PLC’s shareholder are managed in an efficient, fair and timely manner. It enables 11 PLC shareholders to access the appropriate company’s contacts who will handle their specific complaints, resolutions and feedback.
III. 11 PLC’s commitment: The Company is committed to providing high standards of services for shareholders, including:
A. Providing efficient and easy access to shareholder information;
B. Enabling shareholders to have shareholder related matters acknowledged and addressed; and
C. Providing the means for shareholder enquiries and complaints to be appropriately handled.
IV. Terminology: Unless otherwise described in this policy, the following terms and definitions apply throughout this policy:
A. 11 PLC means the company (RC 914), which has ordinary shares quoted on the Nigerian Stock Exchange
B. Shareholder means the registered owner of ordinary shares in 11 PLC.
V. Procedures for shareholders to make enquiries and complaints: There are a number of ways shareholders can access relevant information about their shareholdings and make related enquiries and complaints.
VI. Shareholders can access 11 PLC’s website detailed information on 11 PLC’s website at www.11plc.com to assist shareholders with managing their shareholdings.
A. Contact the Registrar: Shareholders who wish to make an enquiry or complaint about their shareholding should initially contact 11 PLC’s share Registrar (see the contact details set out in section 13 of this policy). The share registry manages all the registered information relating to all shareholdings, including:
I. Shareholder name(s);
II. Shareholder address;
III. Whether information is sent to shareholders by email or post;
IV. Whether shareholders wish to receive the annual report; and
V. Dividend payment instructions.
Contact 11 PLC’s Company Secretary: If the share registry is unable to satisfactorily fulfil shareholders’ enquiries and resolve complaints then shareholders should contact 11 PLC’s Company Secretariat (see the contact details set out in section 14 of this policy).
Enquiries and complaints to 11 PLC: 11 PLC is committed to responding to shareholders’ enquiries and complaints fairly and promptly, whether by email, telephone, or post. Once the enquiry has been received, the Company Secretariat will:
A. Answer helpfully;
B. Carefully listen and consider the enquiry or complaint;
C. Record all relevant details;
D. Confirm the particulars received (if the enquiry is by phone);
E. Explain the courses of action available;
Clearly and concisely articulate the response;
F. Refer and escalate the call (if required); and
G. Follow-up and keep the shareholder informed (if required), until the matter is resolved.
VII. 11 PLC ‘s response: 11 PLC will commence an investigation into the enquiry or complaint within one business day of receiving notice from the shareholder. 11 PLC will provide a response within a reasonable period, and not later than five business days. If 11 PLC is not in a position to respond within five business days, then 11 PLC will contact the shareholder to acknowledge receipt of the enquiry or complaint and confirm that the matter is being investigated. Delays may be experienced in some situations, including where documents need to be retrieved from storage. 11 PLC will respond using the same or similar medium that was used for the initial enquiry, whether by email, phone, post or fax, unless otherwise notified to or agreed with the shareholder.
VIII. 11 PLC will record enquiries and complaints: 11 PLC will record details about an enquiry or complaint to assist in the thorough investigation of the matter, which may include recording all or some of the following information:
A. The date that the enquiry or complaint was received;
B. Name of the shareholder;
C. Shareholder Reference Number (SRN) or Holder Identification Number (HIN);
D. Telephone number or other contact details;
E. Nature of enquiry or complaint;
F. What the shareholder is seeking;
G. Whether there is any cost associated; Action taken; and
H. Copy of all correspondence sent to the shareholder.
IX. 11 PLC will liaise with the Registrar: During the course of investigating a shareholder’s enquiry, complaint or feedback, 11 PLC may liaise with the company’s share registry. If necessary, 11 PLC ’s engagement with the share registry will include:
A. Determining the facts;
B. Determining what action has been undertaken by the Registrar (if any); and
C. Coordinating a response with the assistance of the Registrar.
X. Escalating an enquiry or complaint: If the circumstances require, a shareholder enquiry or complaint that is received by 11 PLC may be escalated to 11 PLC’s Executive Management.
XI. Resolving an enquiry or complaint: Once 11 PLC has received an enquiry or complaint, 11 PLC will then:
– Commence an investigation;
– Determine whether the enquiry or complaint relates to a breach of legislative or regulatory requirements and if so, determine what notification to the regulatory body is appropriate (if any);
– Determine the course of action; and
– Communicate the response to the shareholder.
XII. Registrar Contact Details: 11 PLC’s Registrar may be contacted using the following details: GTL Registrars Ltd, No. 274, Murtala Muhammad Way – Yaba, Lagos. Telephone: 01- 2793160-2 E-mail: info@gtlregistrars.com Website: www.gtlregistrars.com
XIII. 11 PLC’s Shareholder Secretariat: Shareholders seeking more information about the company are invited to contact the office of Company Secretary at: 11 PLC Nigeria PLC Head Office, No. 1, Mobil Road, Apapa, Lagos. Website: www.11plc.com
XIV. General 11 PLC Enquiries: All general enquiries regarding 11 PLC should be directed to the company’s head office at: 11 PLC, No. 1, Mobil Road, Apapa, Lagos. Website: www.11plc.com
XV. Nigeria Stock Exchange (NSE): 11 PLC’s shares are traded at the market floor of Nigerian Stock Exchange in Lagos, Nigeria. The Exchange as a self-regulatory body has 11 PLC under its radar as regard issues relating to shares management. The Exchange will therefore be notified of issues relating to shareholders complaint that proof difficult to be resolved either by the Company or its Registrar.
XVI. Publication: This policy is available on 11 PLC’s website at www.11plc.com A copy of the policy may be requested by contacting The Company Secretariat (see section 14 of this policy for contact details).
XVII. Resources: 11 PLC will make available sufficient resources so that shareholders’ enquiries and complaints may be dealt with adequately, and in an efficient and timely manner. Where changes to systems, policies and procedures are required, 11 PLC will investigate potential solutions and apportion resources where necessary.
XVIII. Charges and Fees Wherever possible, and subject to statutory requirements, 11 PLC will not charge shareholders for making enquiries, giving feedback, providing a response or for any aspect in the course of resolving a shareholder matter. Shareholders are regularly informed that in some circumstances the share registry may charge shareholders, including resending old dividend statements upon request by shareholders.
XIX. Review: 11 PLC will regularly review this policy and the procedures concerning shareholder enquiries, complaints and feedback. As part of the review, 11 PLC will identify and analyze systemic and recurring problems and put in place remedial actions to prevent recurrence of similar problems. Any changes or subsequent versions of this policy will be published on 11 PLC’s website (refer to section 17 of this policy).