Our commitment
Claybarn Fronteira Limited (“Claybarn”, “we”, “us” or “our”) is committed to treating customers fairly and handling complaints promptly, objectively and respectfully. We regard complaints as an important part of our consumer-protection and service-improvement framework.
This Policy explains how a customer may complain about our money-lending services, how we will handle the complaint, the information that may be required, and the options available if the customer remains dissatisfied.
Scope
This Policy applies to complaints relating to Claybarn’s lending services and customer interactions, including loan applications, loan terms and disclosures, interest or charges, repayments, account or payment issues, customer service, privacy concerns, credit-related issues, debt collection or recovery conduct, and other aspects of our service.
A complaint may be made by a customer or, where properly authorised, by a representative acting for the customer.
What is a complaint?
A complaint is an expression of dissatisfaction about a product, service, action, omission or conduct of Claybarn where the customer expects an explanation, correction, remedy or other response.
A customer does not need to use the word “complaint” for us to treat a matter as one. General enquiries or requests for information may, however, be handled through our ordinary customer-service channels.
How to make a complaint
Complaints may be submitted free of charge through Claybarn’s designated complaints channel.
- Email: compliance@claybarn.ng
- Telephone: 070 8468 0000
- Online complaint form:
- By post or in person: 8 Lake Chad Crescent, Maitama, Abuja
To help us investigate efficiently, please provide your full name, contact details, loan or application reference where available, a clear description of the issue, the outcome you are seeking, and copies of relevant documents, messages, receipts or transaction records.
Please do not send passwords, PINs, one-time passwords or other authentication credentials.
Acknowledgement and resolution times
We will acknowledge a complaint promptly and begin reviewing it as soon as practicable.
Where the complaint concerns consumer lending within the scope of applicable FCCPC digital, electronic, online or non-traditional consumer-lending requirements, Claybarn will take reasonable steps to resolve the complaint within forty-eight (48) hours of receipt.
If the complaint cannot reasonably be resolved within forty-eight (48) hours because the factual or other issues require further investigation, we will notify the customer in writing, explain the nature of the issues requiring additional time, and aim to fully resolve the complaint within fourteen (14) days of receipt, subject to applicable regulatory requirements.
For complaints outside that specific framework, Claybarn will nevertheless seek to resolve complaints promptly and within any timeframe required by applicable law or a competent authority.
How we investigate
We will assess each complaint on its facts. Depending on the issue, we may review the loan application and agreement, disclosures, payment records, communications, system records, collection activity, customer information and other relevant material.
We may contact the customer for clarification or additional documents. Where a complaint concerns a service provider acting for Claybarn, we may obtain information from that provider while remaining responsible for handling the complaint as required by applicable law.
Complaints will be handled as objectively as practicable. Where appropriate, a complaint may be escalated internally to personnel who were not directly responsible for the matter complained about.
Our response
Once our review is complete, we will communicate the outcome to the customer in clear language. Our response will, as appropriate, explain what we reviewed, our findings, any corrective action or remedy, and any further step available to the customer.
Depending on the circumstances and applicable law, a remedy may include correcting records or information, reversing or correcting an erroneous charge, addressing a service failure, providing an explanation, changing an inappropriate recovery action, or taking another proportionate corrective step.
The availability of a particular remedy depends on the facts, the customer’s contract and applicable law.
Complaints about debt collection or recovery
Claybarn does not authorise harassment, intimidation, threats, public shaming, defamatory communications or improper disclosure of a customer’s debt to unrelated third parties.
A complaint about debt collection or recovery conduct will be reviewed promptly. Where collection activity is carried out by an agent or service provider, Claybarn may investigate the conduct of that party and take appropriate corrective or contractual action where necessary.
Making a complaint does not automatically suspend a valid repayment obligation. However, where the amount due or the basis of a recovery action is genuinely disputed, Claybarn will consider what interim measures are appropriate while the complaint is investigated.
Privacy and confidentiality
We will handle personal information provided in connection with a complaint in accordance with applicable Nigerian data-protection law and our Privacy Notice.
Complaint information will be shared internally or with service providers only where reasonably necessary to investigate, resolve, record or report the complaint, or where disclosure is required or permitted by law.
A privacy complaint may also be handled under Claybarn’s privacy-rights or data-protection procedure where appropriate.
No retaliation
Claybarn will not penalise a customer merely because the customer has made a complaint in good faith or exercised a lawful consumer right. This does not prevent Claybarn from enforcing a valid loan obligation or taking lawful action in response to fraud, abuse or misconduct.
Escalation to the FCCPC or another authority
We encourage customers to raise complaints with Claybarn first so that we have an opportunity to investigate and resolve the issue.
Where the complaint falls within the FCCPC’s jurisdiction and the customer remains dissatisfied after using Claybarn’s complaints process, the customer may refer the matter to the Federal Competition and Consumer Protection Commission (“FCCPC”) through the Commission’s official complaint-resolution channels.
For consumer lending covered by the applicable FCCPC digital, electronic, online or non-traditional lending framework, an unresolved complaint may be escalated to the FCCPC after the applicable internal resolution period. Claybarn will cooperate with lawful requests made by the FCCPC or another competent authority.
Nothing in this Policy removes any right a customer may have to seek redress from a competent regulator, alternative dispute-resolution body or court.
Complaint records and regulatory reporting
Claybarn will maintain appropriate records of complaints received, the issues raised, actions taken, communications with the customer, the outcome and the time taken to resolve the matter.
Where applicable to Claybarn’s lending model, we will provide complaint reports, summaries or records to the FCCPC or another competent authority in the form and at the intervals required by law or regulatory direction.
Complaint records will be retained for the period required by applicable law, regulatory requirements and Claybarn’s record-retention framework.
Monitoring and service improvement
We may analyse complaints to identify recurring issues, control weaknesses, product or disclosure problems, service-provider concerns and opportunities to improve customer outcomes.
Material or recurring issues may be escalated to management and may result in changes to processes, training, customer communications, product design or controls.
Accessibility and assistance
We aim to make our complaints process reasonably accessible. A customer who requires assistance in making a complaint should contact us through our customer-service or complaints channel.
We will not charge a customer a fee simply for making or pursuing a complaint through Claybarn’s internal complaints process.
Review of this Policy
Claybarn will review this Policy periodically and may update it to reflect changes in law, regulatory requirements, our services or our complaints-handling arrangements. The current website version will state its effective or last-updated date.
Contact
Complaints should be sent to:
Complaints Team
Claybarn Fronteira Limited
Email: compliance@claybarn.ng
Telephone: 070 8468 0000
Address: 8 Lake Chad Crescent, Maitama, Abuja
Website complaint form:
For privacy-related complaints: dpo@claybarn.ng
For compliance enquiries: compliance@claybarn.ng