Complaints Policy

1. Who we are

This Complaints Policy applies to Prime Time Risk Management & Recruitment Pty Ltd (ABN 96 159 461 284), trading as Profact Services (ProFact, we, us).

We provide private investigation and related services to corporate clients, law firms, insurers, government agencies and private individuals across Australia. We are committed to dealing with complaints fairly, promptly and in accordance with Australian law.

2. Our commitment

We take complaints seriously. If something has gone wrong, we want to know so we can review it, respond appropriately and improve how we work where needed.

This policy explains how you can raise a concern with us, what happens when you do, and where you may seek help if you remain dissatisfied. It sits alongside our Privacy Policy and Conflicts of Interest policy.

3. Who can complain

You may use this process if you are:

• a client or former client who instructed us;
• a person authorised to act on behalf of a client;
• a person affected by our services, including where you believe we have handled personal information about you incorrectly; or
• another party with a genuine concern about our conduct, billing or communications.

If you are not sure whether this process applies to your situation, contact us and we will guide you.

4. What you can complain about

You may raise a complaint about matters including:

• the quality, timeliness or scope of our work;
• conduct or communication by our staff or contractors;
• billing, fees or engagement terms;
• confidentiality or privacy (see also section 10 below);
• access to information we hold about you; and
• any other aspect of our service that you believe is unfair, incorrect or below the standard you reasonably expected.

Complaints about criminal conduct, threats or immediate safety should be reported to the relevant police service in the first instance. We will cooperate with lawful enquiries from regulators and law enforcement.

5. How to make a complaint

Complaints should be directed to us in writing where possible so we can review the details carefully. You may contact us by:

Email: briefs@profact.com.au (subject line: Complaint)
Phone: 1300 464 810
Post: Profact Services, Complaints, Australia

Please include:

• your name and contact details;
• the matter or engagement reference, if you have one;
• a clear description of your concern;
• relevant dates and the outcome you are seeking, if any; and
• copies of supporting documents, if available.

If you need help putting a complaint in writing, call us and we will assist. Where lawful and practicable, we will accept verbal complaints and record them accurately.

6. Our complaints process

When we receive a complaint, we will:

1. Acknowledge receipt and confirm we have understood the key issues.
2. Assess whether we need further information and who within ProFact should review the matter (usually a senior investigator not directly involved in the day-to-day handling of the file, where practicable).
3. Investigate the complaint fairly, including reviewing relevant files and speaking with staff involved, subject to confidentiality and legal privilege limits.
4. Respond with our findings, any remedial action we propose, and reasons for our decision.
5. Record the complaint and outcome in line with our document retention obligations.

We handle complaints in accordance with the Australian Consumer Law and other applicable Commonwealth and state or territory laws. We do not charge you a fee to make or pursue a complaint through this process.

7. Timeframes

We aim to:

• acknowledge your complaint within 5 business days of receipt; and
• provide a substantive response within 30 calendar days, or advise you if we need more time and why.

Complex matters, matters involving multiple parties, or complaints that require information from third parties may take longer. If that happens, we will keep you informed of progress.

8. Confidentiality and conflicts

We treat complaint information confidentially and share it only with people who need it to assess and resolve the matter, including professional advisers where appropriate.

Complaints may be limited by confidentiality owed to other clients, legal professional privilege, or obligations under investigation and security licensing law. Where we cannot disclose certain information, we will explain that to you as clearly as we can without breaching those obligations.

Our Conflicts of Interest policy continues to apply. We will not accept instructions that create a direct opposing conflict in the same matter pairing.

9. Outcomes and remedies

Depending on the nature of the complaint and what the law allows, outcomes may include:

• an explanation of what occurred and why;
• an apology where appropriate;
• corrective action on the file or in our processes;
• correction of personal information we hold;
• fee adjustment or other commercial resolution, where agreed; or
• a decision that no further action is required, with reasons.

If you are not satisfied with our response, ask us to escalate the matter for further review by a senior member of our team. We will confirm who is handling the escalation and the expected timeframe.

10. Privacy complaints

If your complaint relates to how we collect, use, store or disclose personal information, we will handle it under this policy and our obligations under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

See our Privacy Policy for more detail. If you remain dissatisfied after we have responded, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

11. External avenues

If we cannot resolve your complaint to your satisfaction, you may be able to seek assistance from an external body depending on the nature of the issue:

• Privacy: Office of the Australian Information Commissioner (OAIC) — oaic.gov.au
• Consumer and fair trading matters: Australian Competition and Consumer Commission (ACCC) — accc.gov.au, or the consumer affairs or fair trading agency in your state or territory
• Licensing and conduct (private investigation and security): the police licensing or security regulator in the state or territory where the conduct occurred (for example, in New South Wales, the NSW Police Force Security Licensing & Enforcement Directorate)

External bodies may have their own eligibility rules and time limits. We will provide reasonable cooperation if a regulator contacts us about your complaint, subject to our legal obligations.

12. Changes to this policy

We may update this Complaints Policy from time to time. The current version will be published on this page with an updated effective date.

Effective date: 1 June 2026