Complaints Policy

ShareGuard Complaints Policy

Version: 1.0
Effective date: 18 October 2026
Last updated: 18 October 2026
Complaints Owner: James Walsh

1. Our commitment

ShareGuard is committed to providing a professional, fair and reliable service to brokers, lenders, platform users, business contacts and other people affected by our activities.

We take complaints seriously and use them to:

• Resolve problems;
• Correct inaccurate information;
• Improve our services;
• Identify recurring issues;
• Strengthen our controls;
• Support fair business outcomes; and
• Maintain confidence in ShareGuard.

We will handle complaints fairly, objectively and without charging anyone for making a complaint.

A person or organisation making a complaint in good faith will not be disadvantaged because they have raised a concern.

2. About ShareGuard

ShareGuard is a trading name and product of:

Apexsync Limited
Company number: 17513909

M60 Office Park
Oak Court
Wynne Avenue
Manchester
United Kingdom
M27 8FF

Email: sales@shareguard.uk

In this policy, “ShareGuard”, “Apexsync”, “we”, “us” and “our” refer to Apexsync Limited.

3. Complaints Owner

ShareGuard’s appointed Complaints Owner is:

Name: James Walsh
Role: ShareGuard Complaints Owner
Email: sales@shareguard.uk

The Complaints Owner is responsible for:

• Overseeing the complaints process;
• Ensuring complaints are recorded;
• Monitoring acknowledgement and response deadlines;
• Assigning complaints for investigation;
• Identifying conflicts of interest;
• Reviewing significant or recurring complaints;
• Ensuring appropriate remedial actions are completed;
• Escalating legal, security or data-protection concerns;
• Reviewing complaint-management information; and
• Reporting material concerns to the directors of Apexsync Limited.

The Complaints Owner may assign an investigator or case owner while retaining oversight of the complaint.

4. Purpose of this policy

This policy explains:

• What ShareGuard treats as a complaint;
• Who can make a complaint;
• How to submit a complaint;
• How complaints are recorded;
• How we investigate and respond;
• Our acknowledgement and response targets;
• How complaints are escalated;
• How dealer-information challenges are managed;
• How regulated finance complaints are routed;
• How data-protection complaints are handled; and
• How complaint information is monitored and retained.

5. Scope

This policy applies to complaints concerning:

• The ShareGuard public website;
• Demonstration requests;
• Access applications;
• Organisation onboarding;
• User accounts and permissions;
• The dealer-intelligence platform;
• Dealer profiles;
• ShareGuard Ratings;
• Risk indicators;
• Dealer comparisons;
• Watchlists and alerts;
• Evidence records;
• Broker or lender outcome information;
• The Aftersales CRM;
• Reports and exports;
• Platform availability;
• Integrations;
• Customer support;
• Billing and subscriptions;
• Information security;
• Staff conduct;
• Communications from ShareGuard; and
• The way Apexsync Limited operates ShareGuard.

6. What is a complaint?

A complaint is an expression of dissatisfaction about ShareGuard, Apexsync Limited, our service, our conduct or information for which we are responsible, where a response or resolution is expected.

A person does not have to use the word “complaint” for us to treat their concern as one.

A complaint may concern:

• Something we have done;
• Something we have failed to do;
• The quality or availability of a service;
• A delay;
• An account or permission decision;
• The accuracy of information;
• The presentation of a risk indicator;
• A billing concern;
• How a person was treated;
• A security concern;
• An alleged breach of policy; or
• How a previous complaint was handled.

7. Matters outside this policy

This policy does not make ShareGuard responsible for resolving every underlying complaint recorded within the Aftersales CRM.

It does not replace:

• A broker’s complaint-handling procedure;
• A lender’s complaint-handling procedure;
• A dealer’s customer-service process;
• A regulated firm’s FCA complaint obligations;
• A customer organisation’s legal or regulatory responsibilities;
• A data controller’s responsibility for its own personal information; or
• The contractual dispute process agreed with a customer.

Where a complaint concerns a finance agreement, broker, lender, dealer, vehicle or regulated financial service, it will normally need to be directed to the organisation responsible.

ShareGuard may provide the software used to record and manage a complaint without being responsible for deciding its outcome.

8. Who can make a complaint?

A complaint may be made by:

• A ShareGuard customer;
• An authorised platform user;
• A broker;
• A lender;
• A dealer;
• A dealer’s authorised representative;
• A supplier or business contact;
• A person identified within dealer information;
• A consumer whose information is processed through ShareGuard;
• A representative acting with appropriate authority; or
• Another person directly affected by our activities.

We may request evidence that a representative is authorised to act for another person or organisation.

9. How to make a complaint

Complaints can be submitted by email or post.

Email

sales@shareguard.uk

Please include “Formal Complaint” in the subject line.

Post

ShareGuard Complaints
Apexsync Limited
M60 Office Park
Oak Court
Wynne Avenue
Manchester
United Kingdom
M27 8FF

A complaint is treated as received when it enters our designated email system or is delivered to our registered office.

10. Information to include

To help us investigate efficiently, please provide:

• Your full name;
• Your organisation, where applicable;
• Your role or relationship to the matter;
• Your preferred contact details;
• A clear description of the complaint;
• Relevant dates;
• The relevant dealer, organisation, account, case or report reference;
• Copies of relevant communications or evidence;
• The effect the issue has had; and
• The outcome you are seeking.

Please do not send:

• Passwords;
• One-time authentication codes;
• Complete payment-card information;
• Unnecessary identity documents;
• Unnecessary medical information;
• Unnecessary consumer financial information; or
• Personal information about unrelated individuals.

Where sensitive evidence is required, ShareGuard will provide an approved secure method for supplying it.

11. Accessibility and additional support

We will make reasonable efforts to assist anyone who needs support to submit or progress a complaint.

A person may ask us to:

• Use plain language;
• Communicate through an authorised representative;
• Provide information in an alternative format;
• Allow additional time to provide evidence; or
• Make another reasonable communication adjustment.

Requests for support can be sent to sales@shareguard.uk.

12. Our complaint-handling principles

We aim to:

• Treat complainants fairly and respectfully;
• Investigate complaints objectively;
• Avoid conflicts of interest;
• Consider all relevant evidence;
• Keep complainants appropriately informed;
• Protect confidential and personal information;
• Provide clear reasons for decisions;
• Correct errors where appropriate;
• Record agreed actions;
• Monitor deadlines; and
• Learn from complaints.

13. Complaint registration

Every complaint must be recorded in the ShareGuard complaint-management system.

The complaint record should contain:

• A unique complaint reference;
• Date and time received;
• Complainant’s name;
• Organisation;
• Contact details;
• Complaint category;
• Relevant service;
• Summary of the complaint;
• Desired outcome;
• Complaints Owner;
• Assigned investigator;
• Risk and priority level;
• Acknowledgement deadline;
• Target resolution date;
• Target final-response date;
• Current status;
• Evidence received;
• Communications;
• Investigation findings;
• Decision;
• Remedial action;
• Internal-review information; and
• Closure date.

The original date and time received must not be changed.

14. Stage 1 — Receipt and acknowledgement

When ShareGuard receives a complaint, we will:

• Create a complaint record;
• Generate a unique complaint reference;
• Record the exact date and time received;
• Assign James Walsh as the Complaints Owner;
• Categorise the complaint;
• Assess urgency and potential impact;
• Identify whether another organisation should be involved;
• Set the acknowledgement deadline;
• Set the target response date; and
• Send an acknowledgement within 72 hours of receipt.

The acknowledgement will normally include:

• The complaint reference;
• Confirmation that the complaint has been recorded;
• The Complaints Owner’s name;
• A summary of our understanding of the complaint;
• Any additional information required;
• The target response date; and
• An explanation of what will happen next.

The 72-hour acknowledgement deadline runs from the recorded date and time of receipt. It includes weekends, bank holidays and days when the office is closed.

Where possible, we will acknowledge complaints sooner during normal operating hours.

15. Stage 2 — Initial assessment

Following acknowledgement, we will assess:

• Whether the complaint is within ShareGuard’s responsibility;
• Whether another organisation is the correct recipient;
• Whether personal information is involved;
• Whether the complaint concerns regulated financial activity;
• Whether information should be temporarily restricted;
• Whether there is a security or fraud concern;
• Whether immediate corrective action is required;
• Whether there is a conflict of interest;
• Whether specialist or legal advice is needed; and
• Whether the complaint presents a significant business or reputational risk.

Where another organisation is responsible, we will explain this and provide relevant contact information where reasonably available.

We will not disclose confidential information about another organisation merely because a complaint has been made.

16. Stage 3 — Investigation

The investigator may:

• Review account records;
• Review audit history;
• Review relevant communications;
• Check source information;
• Review submitted documents and evidence;
• Speak to relevant employees;
• Contact the Customer organisation;
• Contact a data or integration provider;
• Review applicable agreements and policies;
• Review technical logs;
• Check whether similar issues have occurred; and
• Request further information from the complainant.

The investigator should not be the person whose actions are the main subject of the complaint where this can reasonably be avoided.

Where James Walsh is personally the subject of the complaint, it must be reassigned to another director or an appropriately independent senior person.

17. Stage 4 — Complaint outcome

The complaint response should explain:

• What we understood the complaint to be;
• What evidence we considered;
• What we found;
• Whether the complaint is upheld, partially upheld or not upheld;
• The reasons for the decision;
• Any correction or remedial action;
• Any action expected from the complainant;
• Whether another organisation must respond;
• How to request an internal review; and
• Any relevant external escalation route.

The outcome will be recorded within the complaint history.

18. Response times

ShareGuard will use automated date tracking for every complaint.

Our service targets are:

• Acknowledgement: within 72 hours of receipt;
• Straightforward complaint resolution: within 10 business days;
• Target final response: within 20 business days;
• Internal-review response: within 15 business days of receiving the review request.

The complaint record must display:

• Date and time received;
• Acknowledgement deadline;
• Date and time acknowledged;
• Number of hours remaining to acknowledge;
• Target resolution date;
• Target final-response date;
• Number of business days remaining;
• Current status;
• Complaints Owner;
• Assigned investigator;
• Whether the complaint is on target;
• Whether a deadline is approaching;
• Whether the complaint is overdue;
• Reason for any delay; and
• Date of the next promised update.

If we cannot provide a final response within 20 business days, we will provide an update explaining:

• Why the investigation is taking longer;
• What remains outstanding;
• Whether further information is required;
• The revised expected response date; and
• When the complainant will next receive an update.

These are ShareGuard service targets. They do not replace any shorter legal, regulatory or contractual deadline that applies.

19. Deadline alerts

The ShareGuard complaint-management system should notify the Complaints Owner:

• When a complaint is received;
• When 48 hours remain before acknowledgement is due;
• When 24 hours remain;
• When six hours remain;
• When the acknowledgement becomes overdue;
• Five business days before the final-response target;
• Two business days before the final-response target; and
• When the final-response target becomes overdue.

Reassigning a complaint must not reset or extend an existing deadline.

20. Complaint statuses

Complaints may use the following statuses:

• New;
• Awaiting acknowledgement;
• Acknowledged;
• Triage;
• Investigation in progress;
• Awaiting information;
• Awaiting third party;
• Decision review;
• Final response due;
• Final response issued;
• Internal review;
• Closed; or
• Reopened.

Placing a complaint into “Awaiting information” does not automatically stop a legal or regulatory deadline.

Any paused internal target must be supported by a recorded reason and appropriate authority.

21. Priority and risk levels

Complaints may be assigned the following risk levels:

Standard

A routine complaint with limited impact and no immediate risk.

Priority

A complaint involving:

• Multiple affected users;
• Material service disruption;
• Significant data accuracy concerns;
• Repeated service failure;
• An important customer relationship; or
• Potential financial loss.

Urgent

A complaint involving:

• Suspected personal-data breach;
• Unauthorised account access;
• Cross-organisation information exposure;
• Fraud;
• Serious security risk;
• Immediate risk of harm;
• Potential unlawful publication;
• Regulatory intervention; or
• Significant reputational risk.

Urgent complaints must be escalated to the Complaints Owner immediately.

22. Possible outcomes

Depending on the complaint, we may:

• Provide an explanation;
• Apologise;
• Correct information;
• Add a clarification;
• Add a dispute marker;
• Restrict information while it is reviewed;
• Restore authorised access;
• Correct a permission;
• Correct a billing record;
• Reissue a report;
• Fix a technical issue;
• Provide training or guidance;
• Review a supplier or integration;
• Update a process or policy;
• Take appropriate internal action;
• Refer the matter to another organisation;
• Offer a contractual remedy where appropriate; or
• Decide that no further action is required.

An apology or correction does not automatically amount to an admission of legal liability.

23. Dealer-information challenges

A dealer, director or authorised representative may challenge information displayed within a dealer profile.

The challenge should identify:

• The dealer;
• The disputed information;
• Why it is believed to be inaccurate;
• The correct information;
• The evidence supporting the challenge; and
• The person’s authority to act for the dealer.

We may:

• Verify the person’s identity and authority;
• Review the original information source;
• Contact the organisation that supplied the information;
• Request supporting documents;
• Temporarily restrict disputed information;
• Add a dispute marker;
• Correct factual information;
• Record an alternative position;
• Recalculate an affected indicator;
• Notify authorised recipients where required; and
• Retain a record of the challenge and outcome.

A disagreement with a ShareGuard Rating or commercial assessment does not automatically mean that the underlying information is inaccurate.

We will distinguish between:

• A factual inaccuracy;
• A source dispute;
• An opinion;
• A risk interpretation;
• A customer-configured policy outcome; and
• A difference in commercial judgement.

We will not remove or amend accurate information solely because it is unfavourable.

24. Broker and lender outcome disputes

Where a complaint concerns information supplied by a participating broker, lender or other customer, ShareGuard may need to consult that organisation.

We may:

• Ask the submitting organisation for evidence;
• Restrict the disputed item during review;
• Mark the information as disputed;
• Remove information that cannot be supported;
• Correct inaccurate information;
• Retain information where it remains accurate and lawful; and
• Record the challenge and final outcome.

We will not share identifiable consumer complaint information with an unrelated organisation unless an appropriate lawful basis exists.

25. Aftersales CRM complaints

ShareGuard provides software that Customers may use to manage their own consumer complaints and aftersales cases.

Where the underlying complaint concerns:

• A finance application;
• A finance agreement;
• A broker’s conduct;
• A lender’s conduct;
• A dealer;
• A vehicle;
• Commission;
• Affordability;
• A warranty;
• Redress; or
• A regulated financial service,

the complaint should normally be made to the broker, lender, dealer or organisation responsible.

ShareGuard must not issue a final response on behalf of a regulated firm unless a written agreement and lawful authority specifically permit it.

A broker or lender using the Aftersales CRM remains responsible for:

• Recognising its own complaints;
• Investigating them;
• Applying relevant FCA requirements;
• Monitoring regulatory deadlines;
• Determining redress;
• Issuing its final responses; and
• Providing Financial Ombudsman Service rights where applicable.

26. FCA and Financial Ombudsman matters

Apexsync Limited provides ShareGuard as a business software and dealer-intelligence service.

Unless expressly confirmed otherwise, Apexsync Limited is not acting as the regulated broker or lender responsible for a consumer’s financial product.

If a complaint concerns a regulated financial service, it should be directed to the relevant broker or lender.

That regulated organisation is responsible for determining:

• Whether the matter is an eligible complaint;
• Which FCA requirements apply;
• When its final response is due;
• Whether the complainant is eligible to use the Financial Ombudsman Service; and
• What referral rights must be provided.

ShareGuard will not state that someone has Financial Ombudsman Service rights against Apexsync Limited unless those rights genuinely apply.

27. Data-protection complaints

If a complaint concerns how Apexsync Limited uses personal information as data controller, it will also be handled under our Privacy Notice and data-rights procedure.

This may include concerns about:

• Access to personal information;
• Accuracy;
• Erasure;
• Restriction;
• Retention;
• Unauthorised disclosure;
• Security;
• Marketing;
• Publicly sourced personal information; or
• Exercise of a data-protection right.

Contact:

ShareGuard Data Protection
Email: sales@shareguard.uk

Please include “Data Protection Complaint” in the subject line.

Where ShareGuard processes information solely for a broker, lender or other Customer, that Customer will normally be the data controller. We may refer the matter to that organisation and assist with its response.

A person also has the right to raise a concern with:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Website: https://ico.org.uk
Telephone: 0303 123 1113

28. Security complaints

Potential security vulnerabilities should not be submitted through a general complaint form with detailed exploitation instructions.

Suspected security issues should be sent to:

sales@shareguard.uk

Please use “Confidential Security Report” in the subject line.

A person reporting a suspected vulnerability must not:

• Exploit it;
• Access another organisation’s information;
• Download information without permission;
• Disrupt the service;
• Attempt social engineering; or
• Publish sensitive details before they have been assessed.

Credible reports that may affect customer information or platform security will be prioritised.

29. Fraud and unlawful conduct

Where a complaint suggests fraud, criminal conduct, serious misuse or an immediate risk, we may:

• Restrict access;
• Preserve evidence;
• Escalate the matter internally;
• Contact an affected customer;
• Seek legal advice;
• Notify insurers;
• Notify relevant regulators; or
• Report the matter to law enforcement where appropriate.

We may be unable to disclose all investigative steps to the complainant.

30. Internal review

If the complainant remains dissatisfied with the outcome, they may request an internal review.

The request should:

• Be made within 20 business days of the outcome;
• Identify the complaint reference;
• Explain why the outcome is disputed;
• Identify any relevant evidence not previously considered; and
• Explain the resolution being requested.

Where reasonably possible, the review will be completed by a senior person who was not responsible for the original decision.

The review will consider:

• Whether the complaint was understood correctly;
• Whether relevant evidence was considered;
• Whether this policy was followed;
• Whether the decision was reasonable;
• Whether additional action is required; and
• Whether the explanation was sufficiently clear.

We aim to provide the internal-review outcome within 15 business days.

The outcome of the internal review will normally complete ShareGuard’s internal complaint procedure.

31. Complaints about the Complaints Owner

If a complaint concerns James Walsh or his handling of a complaint, it must be referred to another director of Apexsync Limited.

James Walsh must not:

• Investigate a complaint about himself;
• Approve his own complaint outcome;
• Close a complaint about his own conduct; or
• Conduct the internal review of his own decision.

The reassignment and reason must be recorded in the audit history.

32. Unreasonable or abusive behaviour

We understand that people may be frustrated when making a complaint.

However, we may restrict the method or frequency of communication where behaviour becomes:

• Threatening;
• Abusive;
• Discriminatory;
• Persistently harassing;
• Deliberately obstructive;
• Excessively repetitive without new information; or
• Disproportionately demanding.

Any restriction should be:

• Necessary;
• Proportionate;
• Approved by an appropriate senior person;
• Explained to the complainant; and
• Reviewed periodically where it continues.

A complaint will not be rejected merely because the complainant is persistent or expresses dissatisfaction strongly.

33. Confidentiality

Complaint information will only be shared with people who reasonably need it to:

• Investigate the complaint;
• Provide a response;
• Correct information;
• Protect the platform;
• Obtain professional advice;
• Meet legal obligations; or
• Complete agreed actions.

We may be unable to disclose:

• Another Customer’s confidential information;
• Internal security information;
• Personal information about another person;
• Legally privileged information;
• Details of staff-management action; or
• Information restricted by law or contract.

34. Complaint records and retention

We will retain complaint information only for as long as reasonably necessary to:

• Investigate and resolve the complaint;
• Complete remedial action;
• Monitor recurring issues;
• Establish, exercise or defend legal claims;
• Comply with contractual obligations; and
• Meet applicable legal or regulatory requirements.

Complaint records will normally be retained for up to six years after closure unless:

• A shorter period is appropriate;
• A longer period is legally required;
• Legal proceedings are ongoing;
• A security investigation remains open; or
• The relevant Customer, acting as controller, instructs us otherwise for information processed on its behalf.

Access to complaint records will be restricted to authorised users.

35. Monitoring and reporting

We may analyse complaint information to identify:

• Recurring technical problems;
• Data-quality issues;
• Supplier failures;
• Training requirements;
• Permission errors;
• Security concerns;
• Delayed responses;
• Common user difficulties;
• Dealer-information disputes;
• Complaint trends; and
• Opportunities for service improvement.

Management information should be proportionate and should not expose unnecessary personal information.

36. Audit history

The ShareGuard complaints system must maintain an audit history containing:

• Complaint creation;
• Initial assignment;
• Reassignment;
• Acknowledgement deadline;
• Acknowledgement sent;
• Status changes;
• Evidence received;
• Internal notes;
• Communications;
• Investigation findings;
• Decision approval;
• Final response;
• Internal-review request;
• Review outcome;
• Remedial actions; and
• Closure or reopening.

Audit records must identify:

• The user;
• The action;
• The previous value;
• The new value;
• Date and time;
• Reason where required; and
• Relevant complaint reference.

Ordinary users must not be able to delete or overwrite complaint audit history.

37. Policy review

This policy will be reviewed:

• At least annually;
• Following a significant complaint;
• Following a material legal or regulatory change;
• When ShareGuard’s services materially change;
• When a new complaint route is introduced;
• When response targets change; or
• When monitoring identifies a weakness.

Material changes will be recorded in the version history.

38. Contact us

Complaints and questions about this policy should be directed to:

James Walsh
ShareGuard Complaints Owner
Apexsync Limited
Company number: 17513909

M60 Office Park
Oak Court
Wynne Avenue
Manchester
United Kingdom
M27 8FF

Email: sales@shareguard.uk

Please include “Formal Complaint” in the subject line.

39. Document information

Document title: ShareGuard Complaints Policy
Document owner: James Walsh
Role: ShareGuard Complaints Owner
Legal entity: Apexsync Limited
Classification: Public
Version: 1.0
Effective date: 18 October 2026
Next review date: 18 October 2027