Complaints Policy

Document control

Document title	Complaints Policy
Document owner	Compliance & Operations Lead (delegated by the Board of Directors)
Version	1.0
Effective from	1st January 2026
Next scheduled review	1st January 2027 (or sooner on material change)
Approved by	Board of Directors, APF SPV1 Limited, Angel Property Finance Limited
Audience	Internal — staff and contractors of APF SPV1 Limited; an extract is made available to borrowers, guarantors and introducers on request.

1. Introduction

APF SPV1 Limited & Angel Property Finance ("we", "us", "the Company") is a specialist lender providing unregulated commercial bridging and refurbishment finance to UK property professionals. We are committed to dealing with our borrowers, guarantors, introducers and other stakeholders fairly, openly and with respect. We recognise that, despite our best efforts, sometimes things may go wrong, and when they do we want to know so that we can put them right and learn from them.

This Complaints Policy explains how to raise a concern with us, what we will do when we receive it, how long it will take, and what options are available to you if you remain unhappy with our final response.

2. Scope

This Policy applies to:

any expression of dissatisfaction — whether oral or written, and whether justified or not — from a borrower, guarantor, introducer, broker, investor or other person about the products or services provided by APF SPV1 Limited, or about our conduct;
all members of staff, contractors and agents of APF SPV1 Limited handling such expressions of dissatisfaction; and
any complaint made via any of the contact channels listed in Section 4.

Our lending business is commercial in nature and is unregulated. As a result, complaints in respect of our lending products are not eligible for referral to the Financial Ombudsman Service. This is explained further in Section 9.

3. Definitions

Complaint: any expression of dissatisfaction, whether oral or written and whether justified or not, from or on behalf of a person about the provision of, or failure to provide, a product or service by APF SPV1 Limited, which alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience.
Complainant: the person making the complaint, including a third party making the complaint with the complainant's written authority.
Complaints Officer: the member of staff designated by the Compliance & Operations Lead to investigate and respond to a complaint.
Final Response: our substantive written response setting out the outcome of our investigation and any redress offered.
Senior Review: an independent review conducted by a member of senior management or a Director who has not previously handled the complaint.

4. How to make a complaint

A complaint can be made through any of the following channels and will be treated equally and confidentially. We do not require you to use a specific channel — please use whichever is easiest for you.

WhatsApp	+44 7822 035 589
Telephone	0161 470 5780
Email	[email protected] (marking the subject line "COMPLAINT")
Post	FAO: Complaints Officer, APF SPV1 Limited, South@CheadleRoyal, Royal Crescent, Cheadle, SK8 3FS

Although a complaint can be made orally, we would encourage you to put your concerns in writing or to confirm them in writing once you have raised them. This helps us to understand and address the issues correctly. Where a complaint is made orally we will, if appropriate, prepare a written summary and send it to you to confirm we have understood it.

If you are using an intermediary, broker, solicitor or other representative to act on your behalf, please ensure they enclose your written authority for them to act in respect of the complaint.

5. Our principles for handling complaints

We will deal with all complaints fairly, consistently and promptly.

We will take all complaints seriously, irrespective of the channel through which they are received or the value of the underlying matter.

We will investigate impartially, considering all relevant evidence and the legal and contractual context.

We will keep the complainant informed of progress and provide clear written responses.

Where we have made a mistake we will say so, put it right where we can, and explain what we have done to prevent recurrence.

We will treat complaints information as confidential and will only share it on a need-to-know basis or as required by law (see Section 11).

6. Our complaint handling process

Our process has four stages. Most complaints are resolved at Stages 1 or 2 without needing to escalate.

Stage 1 — Receipt and acknowledgement. On receipt we will log the complaint in our complaints register, assign it a unique reference number and allocate it to a Complaints Officer who has not been directly involved in the matter being complained about. Where this is not possible (for example in a very small team) we will appoint a Complaints Officer with appropriate oversight from senior management.

Stage 2 — Investigation and resolution. The Complaints Officer will review the file, the loan documentation, any correspondence and any other relevant evidence. The Complaints Officer may contact you to clarify points or request further information. We aim to resolve the complaint in this stage by providing a Final Response within 8 weeks of receipt.

Stage 3 — Senior Review (escalation). If you remain dissatisfied with our Final Response, you may request that the complaint be escalated for Senior Review. The Senior Review is conducted by a member of senior management or a Director who has not previously handled the complaint. The Senior Review reaches an independent and final internal decision.

Stage 4 — External recourse. After Senior Review, if you remain dissatisfied you may pursue external options as set out in Section 9.

7. Timescales

We work to the following timescales. Where the complexity of a complaint requires us to take longer than these targets allow, we will tell you in writing, explain why and give you a revised timetable.

Stage	Our target	What you receive
Acknowledgement	Within 3 business days of receipt	Written confirmation of receipt, the case reference number, the name of the Complaints Officer handling it, and a summary of next steps.
Holding update	Within 4 weeks if the complaint cannot be fully resolved earlier	A written update explaining progress, what we are still investigating and when you can expect our substantive reply.
Final response	Within 8 weeks of receipt	Our written final response setting out our findings, the resolution we are offering and your options for escalation.
Internal escalation review	Within 4 weeks of escalation request	Independent senior-management review and a final internal decision letter.

8. Outcomes and redress

Following our investigation we may:

uphold the complaint in full or in part, and where appropriate offer an apology and / or an explanation of what went wrong;
offer a financial gesture of goodwill, a fee waiver, a refund or other monetary redress to put you back in the position you would have been in had the issue not occurred;
agree to take corrective action, for example to amend records, update systems, retrain staff, or revise a procedure;
not uphold the complaint, in which case we will explain our reasoning clearly and refer to the relevant terms of the loan documentation; or
refer the matter elsewhere if it relates to the conduct of an introducer, broker or third party rather than to us, while still acknowledging your concerns.

Any monetary redress offered is intended as full and final settlement of the matters set out in the complaint and will be paid promptly once the offer has been accepted in writing.

9. External recourse

Loans made by APF SPV1 Limited are commercial and unregulated. As a result, a complaint in respect of one of our lending products is not eligible for referral to the Financial Ombudsman Service (FOS), and the borrower does not benefit from the protections that would apply to a regulated consumer credit agreement.

If you remain dissatisfied after our Senior Review, you may consider the following options. None of these forms part of our internal complaints procedure and we are not responsible for the outcome of any of them. You may wish to take independent legal advice.

Pursuing the matter through the courts of England and Wales, which have exclusive jurisdiction in respect of disputes arising under our facility documentation.
Referring the matter to any trade association of which we are a member at the relevant time. We will confirm in our Final Response whether any such body has a complaints procedure applicable to your matter, for example the Bridging & Development Lenders Association (BDLA) or the National Association of Commercial Finance Brokers (NACFB).
Referring a data protection concern to the Information Commissioner's Office (ICO) at ico.org.uk. The ICO handles complaints about how organisations handle personal data, irrespective of whether the underlying business is regulated.
Referring a financial crime concern to the relevant regulator or to Action Fraud, if applicable.

10. Record keeping and management information

We maintain a Complaints Register recording, for each complaint, the date received, the complainant, the nature of the complaint, the products or services involved, the Complaints Officer assigned, the dates of each material step in the investigation, the date of the Final Response, the outcome and any redress paid.

Records are retained for a minimum of six years from the date of the Final Response, in line with our wider record retention obligations.

A monthly Complaints MI report is presented to the Board summarising volumes, root causes, age profile, redress paid and any thematic concerns. The Board uses this information to identify systemic issues and to drive continuous improvement.

11. Confidentiality and data protection

We handle personal data received during a complaint investigation in accordance with the UK GDPR, the Data Protection Act 2018 and our Privacy Notice. Information about a complaint is shared only with those staff and advisers who need it for the investigation, and with any third party where required by law or with the complainant's consent.

The complainant has rights under data protection law in respect of the personal data we hold, including the right of access, correction and erasure. These rights are explained in our Privacy Notice and can be exercised by writing to the Data Protection contact in Section 4.

12. Vulnerable circumstances

Although our customers are typically corporate borrowers, we recognise that personal guarantors, directors and sole-trader borrowers may from time to time experience circumstances that affect their ability to engage with the complaints process (for example, ill health, bereavement, financial difficulty, or where English is not a first language).

Where we become aware of a vulnerable circumstance we will, with the complainant's consent: allow additional time to respond; provide written summaries of telephone discussions; offer to communicate in plain English; consider whether a trusted third party should be involved; and adapt our process as far as is reasonable to meet the complainant's needs.

13. Roles and responsibilities

Board of Directors: overall responsibility for this Policy, oversight of the complaints handling framework and approval of policy changes.
Compliance & Operations Lead: owner of this Policy, allocation of complaints to a Complaints Officer, training of staff, maintenance of the Complaints Register, and production of Complaints MI for the Board.
Complaints Officer: day-to-day investigation of complaints, drafting of acknowledgements, holding updates and Final Responses, and offering proportionate redress.
Senior Reviewer: a Director or other member of senior management not previously involved in the matter, who conducts the Senior Review.
All staff: a duty to recognise an expression of dissatisfaction as a complaint, to refer it to the Complaints Officer promptly, and to co-operate fully with any investigation.

14. Continuous improvement

Complaints provide some of the most valuable information about how we are doing. The Board reviews complaints data on at least a quarterly basis and uses root-cause analysis to identify trends or systemic issues. Where a complaint suggests a need for change to our products, terms, communications, processes or staff training, the relevant owner is given a specific action and a deadline, and progress is tracked through to closure.

15. Policy ownership, review and approval

This Policy is owned by the Compliance & Operations Lead and approved by the Board of Directors. It will be reviewed at least annually, and additionally on any material change in the legal, regulatory or business context affecting how we handle complaints. The next scheduled review date is set out in the Document Control table at the start of this document.

Changes to this Policy require Board approval. Minor editorial changes (for example to update contact details) may be made by the Policy owner without further Board approval, provided they are reported to the Board at the next meeting.