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      Complaint Policy at SAPP Academy (for ACCA Students)

      Introduction to the Complaint Policy at SAPP

      SAPP Academy is committed to providing a transparent, high-quality, and accessible service to ensure the best learning experience for our students and stakeholders. We are always ready to listen and promptly address any feedback when issues arise, aiming to provide maximum support to our students throughout their learning journey.

      All complaints are received, carefully reviewed, and swiftly handled—not only to resolve issues but also to continuously improve our service quality. 

      1. What is a complaint?

      A complaint is an expression of dissatisfaction, whether justified or not.

      Our policy covers complaints about:

      •  The standard of service you should expect from us
      • The behaviour of our staff in delivering that service
      • Any action, or lack of action, by our staff or others engaged on Commission business We refer to these complaints as "service complaints".

      Our complaints policy does not cover:

      •  Comments about our policies or policy decisions
      • Dissatisfaction or complaints expressed with our policies or decisions about individual cases, funding, or requests for legal advice and assistance
      • Matters that have already been fully investigated through this complaints procedure
      • Anonymous complaints

      We refer to these types of comments or complaints as ’non-service complaints’. These are handled differently, as set out in the ‘Comments and Non-service complaints’ section on page 12.).

      2. Standards for Handling Complaints

      • We can receive complaints by Hotline, feedback forms, Chat, letters, emails, or any other appropriate means if required by virtue of reasonable adjustments. All complaints are taken seriously and thoroughly reviewed.
      • You can expect to be treated with courtesy, respect and fairness at all times. We expect that you will also treat our staff dealing with your complaint with the same courtesy, respect and fairness.
      • We will treat your complaint in confidence within the Commission.
      • We will deal with your service complaint promptly. We will acknowledge receipt of a written complaint within four working hours where we have a return address and you can expect to have a full reply within 20 working days. In a few cases we will not be able to send a full reply within 20 working days of receipt, for example if your complaint is very complex. If this happens, we will tell you the reason why and let you know when we will be able to reply in full, keeping you fully informed of progress.
      •  We will not treat you less favourably than anyone else because of your:
      • Sex or legal marital or same-sex partnership status: this includes family status, responsibility for dependants, and gender (including gender reassignment, whether proposed, commenced or completed)
      • Sexual orientation
      • Colour or race: this includes ethnic or national origin or nationality of disability
      • Religious or political beliefs, or trade union affiliation
      • Any other unjustifiable factors, for example language difficulties, age, pregnancy and maternity.

      Third Party Reporting

      Complainants may wish to have a third party act on their behalf. A third party is any person or organisation acting on behalf of or making enquiries for the complainant. For example, third parties may include:

      •  Advice organisations 
      • Professionals such as social workers, community psychiatric nurses, doctors or solicitors
      • Family members or friends

      Where a third party is helping a complainant with a particular complaint, we need written consent to that effect. Where we have this authority, we will endeavour to take all possible steps to keep the third party informed of progress on the complaint.

      We do not need written consent if a MP or elected Councillor is helping a constituent with a complaint, and we can disclose information to them in response to their enquiries.

      Also, some lawyers and attorneys are legally empowered in certain circumstances to act on behalf of a complainant, and consent to disclose information is not required.

      3. Confidentiality

      All complaints received will be dealt with confidentially and in accordance with the requirements of the Data Protection Act 1998, subject to the need to disclose information as required by statutory authorities, and/or as a result of statutory, legal or parliamentary obligations placed on the Commission.

      4. How to Submit a Complaint to Us

      If you wish to submit a complaint, you may do so via our Hotline, feedback forms, chat, letters, emails, or any other appropriate means.

      • By post: SAPP Academy, Add: 6 th floor, no. 54 Le Thanh Nghi Str., Hai Ba Trung Dist., Hanoi

      Our contact details can be found in the Contacting Us section below. If you require any additional adjustments, please let us know, and we will make every effort to accommodate your needs where possible.

      How we will respond to your complaint

       

      5. Service complaints procedure

      We have a three-stage service complaints handling procedure, explained above. At each stage it will help us to resolve your complaint quickly if you can give us as much clarity and detail as possible, including providing any documents and correspondence and stating that you are making a complaint. If we do not have all the details required to deal with the complaint, we may contact you and ask you for further information.

      Our Correspondence Unit is responsible for managing the handling of service complaints including notifying you of the outcome.

      Stage 1

      This is the first opportunity for us to resolve your dissatisfaction. We expect the majority of complaints to be resolved at this stage. On receipt of your complaint we will contact the Customer Experience Department and they are going to respond to your complaint. This includes any service complaints about our former services where we still retain relevant information.

      Stage 2

      If you are dissatisfied with the response at stage 1, you may request a review. This will be carried out by a responsible Supervisor. Your request together with all subsequent correspondence relating to it should be sent to our Correspondence Unit, who will forward your request to the relevant Supervisor to be reviewed.

      Stage 3

      If you remain dissatisfied with the outcome at Stage 2, your complaint will be escalated to the BUH, the highest responsible authority for the ACCA training program at SAPP. At this stage, the BUH will conduct a thorough review of your case to ensure that an appropriate resolution is reached. Your request, along with all related correspondence, will be forwarded by our Correspondence Unit to the BUH for final review and resolution.

      After our Director reviews and responses, if the student has exhausted our complaints process and is dissatisfied with our handling of their complaint, they can complain directly to ACCA at complaints@accaglobal.com.

       

      Finally, if the student is dissatisfied with our handling of their complaint and with ACCA’s handling of their complaint, they can complain to the regulators, details of which can be found at https://www.accaglobal.com/uk/en/footer-toolbar/contact-us/unhappy.htm

      6. Timescales

      Our timescales for handling a complaint comply with guidance issued by the Public and Health Services Ombudsman.

      Stage 1

      We will acknowledge receipt of your complaint within 4 working hours from the time it is received.

      A full response will be provided within 14 working days from the date of receipt.

      If you submit a complaint directly to our staff (at an event or meeting), we will document the complaint in writing. Additionally, our complaints handling team will contact you to confirm receipt within 4 working hours. The complaint will then be processed in accordance with our policy for written complaints.

      Stage 2

      If your complaint has not been fully resolved at Stage 1 and you remain dissatisfied, we will escalate the complaint to a higher authority for further review. At Stage 2, we will work to address the issue and provide a full response within 3 working days.

      Stage 3

      If your complaint remains unresolved after Stage 2, we will escalate it to the BUH, the highest authority responsible for the ACCA training program at SAPP. At Stage 3, we will acknowledge receipt of your complaint and provide a full response within 3 working days to ensure a comprehensive resolution.

      Extending time limits

      We aim to complete our investigation into all complaints received about our service within the timescales set out above. However, in a limited number of cases - for example, if a complaint is very complex or requires further breakdown, it may be necessary to extend the time limit to ensure we have all the information necessary to

      deal with it. If this is the case we will keep you informed of progress with the investigation, the reasons for the delay, and inform you of next steps.

      7. Remedies

      When we get things wrong we will act to:

      7.1. Our Commitment to Addressing Service Errors

      In the event of a service error, we are committed to implementing the following corrective measures:

      • Taking responsibility and issuing a sincere apology.
      • Providing a clear explanation of the issue and its underlying cause.
      • Resolving the issue by making the necessary adjustments.
      • Learning from mistakes and making appropriate, reasonable policy or procedural changes to prevent recurrence.

      The corrective actions (i.e., redress) we apply to resolve service complaints may include one or more of the remedies listed below. Our fundamental principle is to restore the complainant to the position they would have been in had the issue not occurred.

      Any remedy must be proportionate to the severity of the service failure and take into account the complainant’s expectations. While a formal apology is often the most appropriate response, additional actions may be necessary in certain cases.

      7.2. Corrective Measures

      • A full apology, explaining what occurred and/or identifying the service failure. (Note: An apology does not constitute an admission of legal liability under Section 2 of the Compensation Act 2006).
      • Remedial action, which may include reviewing or amending a decision related to the service provided.
      • Providing the originally requested service as soon as possible, where applicable.
      • Implementing corrective actions (e.g., modifying procedures to prevent similar issues from occurring in the future, either for the complainant or others).
      • Enhancing staff training, supervision, or a combination of both to improve service quality.
      • Financial compensation, where deemed appropriate.

      8. Compensation

      In the majority of cases, remedies other than financial compensation will sufficiently address the complainant’s concerns. Financial compensation is considered a last resort and will only be granted in cases where the loss or hardship is deemed significant enough to warrant such a payment, specifically in instances of actual direct or indirect financial loss.

      Where it is determined that our actions or omissions have resulted in maladministration, and the complainant has suffered a direct or indirect financial loss, compensation may be considered. In making this determination, we adhere to the “Principles for Remedy” as set out by the Parliamentary and Health Service Ombudsman (PHSO).

      Following a thorough investigation, if it is concluded that the complainant has experienced injustice or hardship resulting in financial loss due to maladministration, we will carefully assess whether financial compensation is an appropriate remedy. This evaluation will take into account all available evidence, including the extent of the complainant’s demonstrated financial loss or any additional costs incurred as a direct consequence of our maladministration.

      The rationale for our decision will be documented by the decision-maker and included in our formal response to the complainant.

      9. Vexatious and repetitive complaints, and unreasonable or abusive behaviour

      All complaints will be handled in accordance with this policy. However, there are instances where unreasonable, abusive, or vexatious complaint behavior arises. Repetitive or deliberately disruptive complaints present an increasing challenge for service-based organizations, placing undue strain on resources, staff time, and operational efficiency. Managing these cases appropriately is essential to maintaining a fair and effective complaint resolution process.

      The Parliamentary and Health Service Ombudsman defines unreasonably persistent complainants as:
      “Individuals who, due to the frequency or nature of their contact with an authority, hinder the authority’s ability to consider their own or others’ complaints.”

      We have established a structured policy outlining how we will address such situations while ensuring that all complaints are managed fairly and transparently. This approach helps safeguard our staff and resources while upholding the integrity of our complaint-handling process.

      10. Recording complaints

      Complaint details, resolutions, and corrective actions are systematically recorded and utilized for service improvement. We document all complaints received and aggregate data to identify recurring issues and assess the effectiveness of our resolution efforts.

      We highly value your feedback and are committed to using it to:

      • Prevent similar issues from occurring in the future;
      • Enhance our customer-centric approach;
      • Improve transparency and accountability;
      • Ensure fairness and proportionality in complaint resolution;
      • Continuously refine and enhance our services.

      Your information will be processed and retained appropriately and lawfully in accordance with data protection regulations.

      11. Contacting us

      All complaints and requests for review under our complaints procedure should be sent as follows:

      • By post: SAPP Academy, Add: 6 th floor, no. 54 Le Thanh Nghi Str., Hai Ba Trung Dist., Hanoi

      12. Reasonable adjustments and alternative formats

      The Commission is committed to equal opportunities and our aim is to make our corporate complaints policy easy to use and accessible to all of our customers. We will take reasonable steps to accommodate any reasonable adjustments you may have to enable you to access this policy or receive responses to complaints in other formats, and provide such assistance as you may reasonably require.

      This policy is also available in Welsh.

      If you would like the policy or a response to a complaint in another format (such as Braille, audio CD, BSL video, large print or Easy Read) please contact support@sapp.edu.vn.

      13. Comments and non-service complaints

      Service quality is one of the key metrics by which we measure our operational effectiveness. At SAPP Academy, we recognize that learning from complaints, including non-service-related complaints (i.e., complaints that fall outside the scope of this policy), is an essential means of continuous improvement. This approach enables us to enhance our operations and better uphold the values and standards we are committed to.

      All non-service-related complaints will be reviewed by a responsible manager from the relevant department. Where necessary, we will provide a direct response within 14 working days from the date of receipt, provided this is feasible. Non-service-related complaints should be submitted to the Correspondence Unit for appropriate handling.

      In addition to addressing complaints, we also welcome any suggestions you may have on how we can enhance our services. Likewise, we appreciate receiving positive feedback when our service meets or exceeds your expectations.

      All feedback will be directed to the appropriate department and used to improve our service delivery and operational processes. You may share your comments by reaching out to any member of SAPP Academy’s staff.

      Addendum

      Policy on Vexatious Complaints, Unreasonable and Abusive Behaviour

      This policy is integrated with other existing policies of SAPP Academy. It does not directly address health and safety matters, as these are governed by separate regulations.

      This policy applies to service-related complaints that SAPP Academy staff consider to be vexatious or unduly repetitive, as well as behavior that is deemed unreasonable. It has been developed in accordance with the Information Commissioner’s Office (ICO) guidance under the Freedom of Information Act 2000.

      Certain complaints may relate to final decisions made by SAPP Academy on matters such as:

      • Scholarship applications
      • Requests for legal assistance
      • Requests for enforcement actions
      • Requests for policy changes

      These matters are addressed through separate procedures. Once those procedures have been fully exhausted, any subsequent complaints that are deemed vexatious or repetitive will be handled under this policy.

      Vexatious or Repetitive Complaints

      At times, we receive complaints that may be considered "vexatious" or "repetitive." Some of these complaints can be costly to process, and responding to them may place a disproportionate burden on staff time and resources.

      Determining whether a complaint is vexatious requires a case-by-case assessment of its context and history. We will evaluate whether the complaint is likely to cause undue distress, disruption, or annoyance. Specifically, we will consider the following factors:

      • Can the complaint reasonably be considered obsessive?
      • Does the complaint harass or cause distress to staff?
      • Does the complaint appear to be intended to cause disruption or nuisance?
      • Does the complaint lack a legitimate purpose or practical value?

      Our assessment focuses on the effect of the complaint on SAPP Academy rather than the personal motivations of the complainant. By its ordinary meaning, "vexatious" refers to activity that “is likely to cause distress or irritation, literally to vex the person to whom it is directed.”

      To determine whether a complaint is vexatious, we will consider whether there is a legitimate reason for it. We will not only examine the complaint itself but also its broader context and history. This includes the complainant’s past interactions with SAPP Academy, the number and subject matter of previous complaints, and the nature of prior communications. The impact of a complaint is often influenced as much, if not more, by its context than by its content alone.

      The following (non-exhaustive) factors will be taken into account when determining whether a complaint is vexatious:

      • The complaint requests information that has already been provided
      • The volume and nature of the complainant’s correspondence suggest an obsessive approach to information disclosure
      • The complainant’s tone in correspondence is confrontational or aggressive, indicating that the intent is to argue rather than to obtain information
      • The complaint is likely to have a negative impact on the health and well-being of our staff
      • The complaint appears to be an attempt to reopen matters that have already been reviewed and disputed multiple times, effectively using complaints as an alternative means to persist with an issue
      • Responding to the complaint would impose a substantial and disproportionate financial and administrative burden on SAPP Academy
      • The complaint is not a one-off instance but part of a pattern of repeated complaints, often varying in detail in a way that makes it difficult to determine the complainant’s exact request and makes resolution unlikely

      No single factor listed above would, on its own, determine that a complaint is vexatious. However, a complaint may be deemed vexatious by SAPP Academy based on the overall weight of multiple factors, combined with its history and context.

      It is important to note that not all complaints from the same individual will be classified as vexatious simply because some previous complaints were deemed so. This is particularly true if a new complaint appears specific, standalone, and straightforward. However, when evaluating whether a complaint is vexatious, we must consider its broader context—such as whether it is part of an ongoing grievance against SAPP Academy or an attempt to hold the institution accountable for perceived shortcomings.

      At times, complaints may be used as a mechanism to revisit previously addressed concerns. While we recognize that not all individuals will be satisfied with the responses they receive, the complaints process should not be used as a means to continue disputes that have already been resolved through formal channels. Persisting with complaints after the core issue has been addressed goes beyond the reasonable pursuit of resolution.

      The Commission understands that individuals may behave differently under stress or frustration. We do not consider a complainant's behaviour to be unreasonable simply because they are assertive or persistent. Our staff make reasonable allowances for such circumstances.

      However, in some instances, interactions between a complainant and Commission staff may escalate, leading to behaviour that is deemed unacceptable, such as abusive, aggressive, or threatening conduct. Although such cases are rare, there are times when we must restrict or terminate communication and access to our premises or staff.

      Our staff have the right to perform their duties free from abuse, threats, harassment, or vexatious and repetitive complaints. We expect our staff to be treated with courtesy and respect. The Commission has a responsibility to ensure the welfare and safety of its staff and considers any form of violence, threats, or abuse towards them to be unacceptable. Similarly, our staff are expected to treat complainants with courtesy, respect, and fairness.

      Complainants who engage in harassment or exhibit abusive, aggressive, or threatening behaviour—either directly or indirectly—towards our staff, their families, or associates on one or more occasions will be considered as engaging in unreasonable behaviour.

      Unreasonable Behaviour

      Any threats or acts of violence will result in the immediate termination of direct contact with the complainant. Violence includes any behaviour or language (whether written, spoken, tonal, or otherwise) that causes staff to feel intimidated, threatened, or abused. Examples of unacceptable behaviour include, but are not limited to:

      • Threats, verbal abuse, derogatory remarks, rudeness
      • Racist, sexist, homophobic, transphobic, ableist, or other forms of harassment based on personal characteristics
      • Making obscene or offensive comments
      • Persistently demanding disciplinary action against staff without valid grounds
      • Secretly recording meetings or phone conversations without consent
      • Making inflammatory statements or unsubstantiated allegations, which may be considered abusive behaviour

      Furthermore, Commission staff are instructed to end phone calls if the caller is aggressive, abusive, or threatening. Before doing so, the complainant will be informed that their language or behaviour is considered offensive or unacceptable and will be asked to stop.

      If an officer determines that a complainant’s behaviour is unreasonable, they are advised to escalate the matter to their manager, who may seek guidance before deciding on future communication, whether by phone, in person, or electronically.

      If a complaint is deemed vexatious, the complainant will be notified in writing that no further correspondence will be entertained regarding the matter. However, the Commission will maintain at least one channel of communication to ensure there is no blanket ban on contact with any individual.

      If a complainant's behaviour is deemed unreasonable or abusive, they will be notified in writing that all further contact with the Commission will be terminated. This restriction will apply across all Commission contact points. A copy of this policy will be provided, and if applicable, a specific no-contact period will be outlined. If further communication is necessary, the complainant will be informed that it must take place through a Director or an appointed representative. A decision to restrict contact may be reconsidered if the complainant subsequently demonstrates more reasonable behaviour.

      If a complainant disagrees with the Commission’s decision to classify their behaviour as unreasonable, they may challenge it by referring to our Complaints Policy.

      All instances of harassment or aggression will be documented and reported to senior staff. Where appropriate, these matters may be referred to law enforcement, and the Commission reserves the right to take legal action against the complainant without prior notice if necessary.

      Please refer to the attached complaint form here.

      SAPP Academy