Complaints Procedure

LOPEX UNICONS LTD (trading as "UNICONS") is committed to providing high-quality international education guidance and application services to students, agents, counsellors, and partner institutions worldwide. We take all complaints seriously and regard them as an important source of feedback that helps us to improve our services.

This Complaints Procedure ("Procedure") sets out:

• Who is entitled to make a complaint;
• What matters are within the scope of this Procedure;
• The four stages of our complaint handling process;
• The timelines within which we will acknowledge and respond to complaints;
• The remedies that may be available to complainants;
• How we handle complaints data and maintain confidentiality.

We aim to resolve all complaints promptly, fairly, consistently, and proportionately. Where a complaint is upheld, we will take whatever reasonable steps are within our power to put matters right and to prevent recurrence.

This Procedure does not affect your rights under any applicable contract with UNICONS, or your statutory rights as a consumer or data subject under applicable law.

If you are unsure whether this Procedure applies to your situation, please contact us at enquiry@unicons.co.uk in the first instance, and a member of our team will be happy to advise you.

The following persons are entitled to submit a complaint under this Procedure:

2.1 Students

Any current or former student who has registered on the UNICONS Platform, submitted an application through UNICONS, or received guidance or support services from UNICONS or a UNICONS-registered counsellor or agent.

2.2 Parents and Legal Guardians

The parent or legal guardian of a student who is a minor (under 18 years of age), or the authorised representative of a student who lacks the capacity to submit a complaint independently. Where a complaint is submitted on behalf of a student, we may ask for written confirmation that you are authorised to act on their behalf.

2.3 Agents and Counsellors

Any individual or organisation registered with UNICONS as an agent or counsellor, in respect of matters arising from their working relationship with UNICONS, including commission payments, case allocations, and conduct of UNICONS staff.

2.4 Partner Institutions

Authorised representatives of colleges, universities, or other educational institutions that have entered into a formal partnership agreement with LOPEX UNICONS LTD.

2.5 Third Parties (Limited Scope)

In exceptional circumstances, and at UNICONS' discretion, we may accept a complaint from a third party who has been materially affected by the actions or decisions of UNICONS, even where that person does not have a direct contractual relationship with us (for example, a prospective employer of a student affected by a data handling incident).

2.6 Anonymous Complaints

We encourage complainants to identify themselves so that we can investigate effectively and communicate our response. Where a complaint is submitted anonymously, we will consider it and take any necessary action where possible, but we may not be able to communicate the outcome to the complainant.

This Procedure covers complaints about any of the following matters:

3.1 Quality of Guidance and Advice

The quality, accuracy, or appropriateness of educational guidance, course recommendations, or application advice provided by UNICONS staff, counsellors, or agents — including advice that was misleading, inaccurate, incomplete, or inappropriate to the complainant's circumstances.

3.2 Conduct of Staff, Counsellors, or Agents

The professional conduct, attitude, or behaviour of any UNICONS employee, contractor, registered counsellor, or agent — including complaints relating to discourtesy, unprofessional conduct, discrimination, harassment, or conflicts of interest.

3.3 Data Handling and Privacy

The way in which UNICONS has collected, used, stored, shared, or otherwise processed your personal data — including breaches of our Privacy Policy, failures to honour your data subject rights, or other breaches of UK data protection law.

Please note that formal data subject rights requests (such as subject access requests) are handled under our Privacy Policy and the UK GDPR framework, with a defined response timeline of one calendar month. You may also submit a complaint about data handling through this Procedure if you are dissatisfied with our response to a data subject rights request.

3.4 Application Processing Delays

Unreasonable delays in the processing of a student application, failure to submit an application by an agreed deadline, or poor communication about the status of an application.

3.5 Commission Disputes

Disputes between UNICONS and a registered agent or counsellor regarding the calculation, payment, or withholding of commission, referral fees, or other financial arrangements governed by a signed agreement with UNICONS.

3.6 Service Delivery and Platform Issues

Failures in the delivery of services promised under a signed agreement or the UNICONS Platform Terms, including technical failures that materially affected your ability to use the Platform and which were not resolved within a reasonable timeframe.

3.7 Matters Outside the Scope of This Procedure

The following matters are outside the scope of this Procedure and will be handled through separate processes:

• Admissions decisions made by a partner university or college — these are matters for the institution concerned and should be appealed through its own admissions appeals process;
• UK visa or immigration decisions — these are matters for UK Visas and Immigration (UKVI) and should be challenged through the appropriate immigration appeals process;
• Employment disputes between UNICONS and its employees — these are governed by UNICONS' internal HR procedures and employment law;
• Matters that are already the subject of legal proceedings — once legal proceedings have been issued, this Procedure is suspended in respect of the matters in dispute.

UNICONS operates a four-stage complaints process designed to resolve issues at the earliest possible stage. We encourage complainants to use the lowest applicable stage first.

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### Stage 1: Informal Resolution

Timeframe: Contact within 14 days of the issue arising

Purpose: To resolve straightforward complaints quickly, without the need for a formal written process.

How to Use Stage 1:

If you are dissatisfied with any aspect of our services, we encourage you to raise the matter informally in the first instance by contacting the relevant member of staff directly:

• Students: Contact your assigned UNICONS counsellor or the agent who referred you to UNICONS, by telephone, email, or through the UNICONS Platform messaging system;
• Agents and counsellors: Contact your designated UNICONS account manager;
• Partner institution representatives: Contact your designated UNICONS partnership manager.

Please raise the issue as soon as possible, and in any event within 14 days of the event or matter giving rise to your concern. Prompt raising of concerns allows us the best opportunity to resolve matters while they are still fresh.

Stage 1 Outcome:

The relevant member of staff will discuss the matter with you and attempt to resolve it informally. If the matter is resolved to your satisfaction at Stage 1, no further action is required and no formal complaint record will be created (unless you request otherwise).

If the matter is not resolved to your satisfaction within 5 working days of first raising it informally, or if you prefer to make a formal complaint, please proceed to Stage 2.

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### Stage 2: Formal Written Complaint

Timeframe: Submit within 28 days of the incident or the end of Stage 1

Purpose: To provide a formal record of your complaint and ensure a thorough, documented investigation.

How to Submit a Stage 2 Complaint:

Please submit your formal complaint in writing by:

• Email: enquiry@unicons.co.uk (please include "FORMAL COMPLAINT" in the subject line)
• Post: Complaints, LOPEX UNICONS LTD, 214 High Street, Second Floor, Hounslow, TW3 1HB, London, United Kingdom
• Platform: Via the "Submit a Complaint" function in your UNICONS account (if available)

What to Include in Your Stage 2 Complaint:

Your complaint should include the following information:

1. Your full name, contact email address, and (if applicable) your UNICONS account reference or application reference number; 2. The nature of your complaint, described as clearly and concisely as possible; 3. The date(s) on which the matter occurred or came to your attention; 4. The name(s) of any UNICONS staff members, counsellors, or agents involved; 5. Details of any informal steps already taken and the response received (Stage 1); 6. The outcome you are seeking; 7. Any supporting evidence or documentation you wish to provide (for example, emails, screenshots, or copies of letters).

Stage 2 Acknowledgement:

We will acknowledge receipt of your Stage 2 complaint in writing (by email or post, as you prefer) within 3 working days of receipt.

Stage 2 Investigation and Response:

A designated member of our management team (who was not personally involved in the matter giving rise to the complaint) will be assigned to investigate your complaint. The investigation will include:

• A review of your written complaint and all supporting evidence provided;
• A review of relevant records held by UNICONS (including account records, emails, and application history);
• Interviews with relevant staff members, counsellors, or agents as appropriate;
• Any other steps reasonably necessary to reach a fair conclusion.

We aim to provide a full written response to your Stage 2 complaint within 20 working days of the date of our acknowledgement letter. If the investigation is complex and requires additional time, we will write to you before the end of the 20-working-day period to explain the reason for the delay and provide a revised response date.

Stage 2 Response Content:

Our written response will include:

• A summary of our investigation;
• Our findings and conclusions in respect of each element of your complaint;
• Whether the complaint has been upheld, partially upheld, or not upheld;
• Where the complaint is upheld or partially upheld: details of the remedy or action we propose (see Section 7);
• Where the complaint is not upheld: a clear explanation of our reasons;
• Information about how to escalate to Stage 3 if you remain dissatisfied.

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### Stage 3: Escalation to Senior Management

Timeframe: Request escalation within 10 working days of receiving the Stage 2 response, or if Stage 2 is not resolved within 20 working days

Purpose: To provide an independent senior-level review of complaints that have not been resolved at Stage 2.

When to Use Stage 3:

You may escalate your complaint to Stage 3 if:

• You have received a Stage 2 response and remain dissatisfied with the outcome or the manner in which the investigation was conducted; or
• We have not provided a Stage 2 response within 20 working days of acknowledging your complaint, and have not provided a satisfactory explanation for the delay.

How to Escalate to Stage 3:

To escalate your complaint to Stage 3, please write to us at enquiry@unicons.co.uk (subject line: "COMPLAINT ESCALATION — STAGE 3"), clearly stating:

• Your name and complaint reference number (provided in our Stage 2 acknowledgement);
• That you wish to escalate to Stage 3;
• The reasons why you are dissatisfied with the Stage 2 response or process.

Stage 3 Process:

Stage 3 complaints will be reviewed by a member of UNICONS' senior management team (Director level or above) who was not involved in the Stage 2 investigation. The senior manager will:

• Review your original complaint, all evidence submitted, and the Stage 2 investigation file;
• Consider whether the Stage 2 investigation was thorough and fair;
• Assess whether the Stage 2 outcome was reasonable and proportionate;
• Where appropriate, speak with you directly to understand your concerns.

Stage 3 Acknowledgement and Response:

We will acknowledge receipt of your Stage 3 escalation within 3 working days and aim to provide a final response within 15 working days of acknowledgement. The Stage 3 response will constitute UNICONS' final internal decision on your complaint.

If you remain dissatisfied after Stage 3, you may request independent review under Stage 4.

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### Stage 4: Independent Review and Mediation

Timeframe: As agreed between the parties or through the relevant independent body

Purpose: To provide an independent, impartial review of complaints that have not been resolved internally.

When to Use Stage 4:

Stage 4 is available where:

• You have received a Stage 3 final response from UNICONS and remain dissatisfied; or
• In exceptional circumstances, where UNICONS agrees that independent review is appropriate at an earlier stage.

Stage 4 Options:

Depending on the nature of the complaint, Stage 4 options may include:

a) Independent Mediation

The parties may agree to appoint an independent, accredited mediator to facilitate a resolution. The costs of mediation will be shared equally between the parties unless otherwise agreed. We are open to mediation as a means of resolving disputes efficiently and without recourse to litigation.

b) Alternative Dispute Resolution (ADR)

For eligible consumer disputes, you may be able to refer your complaint to an approved Alternative Dispute Resolution (ADR) scheme. Where applicable, we will identify the relevant ADR scheme in our Stage 3 final response.

c) Legal Proceedings

Nothing in this Procedure prevents you from pursuing your rights through the courts of England and Wales. The courts are available to you at any stage, subject to applicable limitation periods under the Limitation Act 1980.

d) Regulatory Bodies

Where your complaint relates to specific regulated matters, you may have the right to escalate to the relevant regulatory body. For example:

• Data protection complaints: to the Information Commissioner's Office (ICO) at ico.org.uk;
• Equality Act complaints: to the Equality Advisory and Support Service (EASS) or the Equality and Human Rights Commission (EHRC);
• Immigration or visa matters: to UK Visas and Immigration (UKVI) or the Office of the Immigration Services Commissioner (OISC) where relevant.

Upon receipt of a Stage 2 or Stage 3 complaint, we will assign a unique complaint reference number. Please quote this reference number in all subsequent communications about your complaint, to enable us to locate your file quickly and ensure continuity of handling.

You may check the status of a formal complaint at any time by contacting us at enquiry@unicons.co.uk, quoting your complaint reference number.

We will maintain a complaint log that records:

• The date of receipt;
• The nature and category of the complaint;
• The name of the investigating officer;
• Key dates (acknowledgement, response, escalation);
• The outcome of the investigation;
• Any remedial action taken.

This log is reviewed regularly by senior management to identify patterns, systemic issues, and opportunities for service improvement.

6.1 Principles of Investigation

All complaints received under this Procedure will be investigated in accordance with the following principles:

• Independence: The investigating officer will not have been personally involved in the matter giving rise to the complaint;
• Impartiality: The investigation will be conducted without bias or prejudgment;
• Proportionality: The extent and depth of the investigation will be proportionate to the nature and seriousness of the complaint;
• Timeliness: Investigations will be completed within the timelines set out in Section 4;
• Confidentiality: Information gathered during the investigation will be treated confidentially and shared only with those who need it to conduct the investigation or implement any remedy.

6.2 Information Gathering

During the investigation, we may:

• Request additional information or evidence from the complainant;
• Review relevant records, including emails, application files, Platform logs, and financial records;
• Speak with any member of staff, counsellor, or agent named in the complaint;
• Seek the views of other relevant parties (for example, a partner university) where appropriate.

6.3 Right of Reply

Where a complaint is made against a named individual (such as a counsellor or member of staff), that individual will be given a fair opportunity to respond to the allegations before a conclusion is reached.

6.4 Burden of Proof

The standard of proof applied in investigating complaints is the balance of probabilities — that is, whether it is more likely than not that the events complained of occurred as described.

Where a complaint is upheld or partially upheld, we will consider and offer the most appropriate remedy given the circumstances. The following remedies may be available, individually or in combination:

7.1 Apology

A sincere written apology from the relevant member of management, acknowledging what went wrong and expressing regret for any distress, inconvenience, or loss caused.

7.2 Explanation

A full and clear explanation of what happened, why it happened, and how we have addressed the root cause to prevent recurrence.

7.3 Corrective Action

Where an error or failure has occurred, we will take all reasonable steps to correct it — for example, resubmitting an application to a university, providing additional counselling sessions at no cost, or correcting an error in a financial record.

7.4 Process Improvement

Where a complaint identifies a systemic issue or process failure, we will review and improve the relevant internal process and communicate the changes made.

7.5 Refund (Where Applicable)

Where a complainant has suffered a direct financial loss attributable to UNICONS' error or failure — for example, a service fee paid for a service that was not delivered — we may offer a full or partial refund of that fee, subject to the terms of the relevant agreement.

Any refund offered will be calculated with reference to the actual financial loss suffered as a direct consequence of the matter complained of, and will not include speculative or consequential losses except where required by applicable law.

7.6 Compensation (Goodwill Gesture)

In exceptional circumstances where significant distress or inconvenience has been caused, we may offer a goodwill gesture (for example, a reduction in future service fees or an extension of subscription period) in recognition of the impact on the complainant.

7.7 Scope of Remedies

UNICONS' liability under this Procedure is limited to matters within our direct control. We are not responsible for decisions made by partner universities or colleges, visa and immigration outcomes, or matters attributable to third parties.

Accepting a remedy under this Procedure does not constitute a waiver of any legal rights you may have, unless you enter into a separate written settlement agreement to that effect.

8.1 Retention of Complaint Records

We retain records of all formal complaints (Stage 2 and above) for a period of 6 years from the date of final resolution. This retention period reflects:

• The general limitation period of 6 years for contract claims under the Limitation Act 1980;
• Our obligation to demonstrate compliance with our complaints handling obligations;
• The potential for regulatory enquiries or legal proceedings arising from a complaint.

Records of informal complaints resolved at Stage 1 are retained for 2 years from the date of resolution.

8.2 What Records Are Kept

Complaint records may include:

• The original complaint and all supporting documentation provided by the complainant;
• Internal investigation notes, interview records, and evidence reviewed;
• All written communications with the complainant;
• The investigation outcome and any remedial action taken;
• Records of any appeals, escalations, or Stage 4 proceedings.

8.3 Use of Complaint Records

Complaint records are used for the following purposes:

• To manage and resolve the specific complaint;
• To identify patterns of complaints and systemic issues;
• To improve our services and processes;
• For regulatory compliance and audit purposes;
• For the establishment, exercise, or defence of legal claims.

Complaint records are not used for any marketing or commercial purpose.

9.1 Complainant Confidentiality

All complaints submitted under this Procedure will be treated with discretion and confidentiality. Information about your complaint will only be shared within UNICONS on a strict need-to-know basis — that is, with those individuals who need access to the information in order to investigate and resolve the complaint.

9.2 Named Individuals

Where a complaint names a specific member of staff, counsellor, or agent, that person will be informed of the complaint and given an opportunity to respond (see Section 6.3 above). We will, however, take reasonable steps to protect the complainant's privacy and will not disclose more information about the complainant to the named individual than is necessary for a fair investigation.

9.3 Confidentiality Limitations

Confidentiality cannot be guaranteed in the following circumstances:

• Where disclosure is required by law or court order;
• Where there is a risk of serious harm to any individual;
• Where disclosure is necessary to protect the interests of UNICONS in legal proceedings;
• Where the ICO or another regulatory body requires disclosure.

In any of these circumstances, we will, where possible, inform you in advance of any disclosure we are required to make.

9.4 Complaint Anonymisation

When complaint data is used for the purpose of reporting, analysis, or service improvement (for example, in internal management reports), all personal identifying information will be removed or anonymised so that individual complainants cannot be identified.

The personal data you provide when making a complaint will be processed by LOPEX UNICONS LTD in accordance with our Privacy Policy and UK Data Protection Law.

10.1 Lawful Basis for Processing Complaint Data

We process your personal data in connection with your complaint on the following lawful bases:

• Legitimate interests (Article 6(1)(f) UK GDPR): our legitimate interest in investigating and resolving complaints and in defending our legal position;
• Legal obligation (Article 6(1)(c) UK GDPR): where processing is necessary for us to comply with our legal obligations, including record-keeping requirements;
• Performance of a contract (Article 6(1)(b) UK GDPR): where your complaint relates to contractual services provided by UNICONS.

10.2 Special Category Data

If your complaint involves the processing of special category data (for example, health information relevant to an access needs complaint, or ethnic origin relevant to a discrimination complaint), we will process such data on the basis of our legitimate interests in the administration of justice and in defending or establishing legal claims (Article 9(2)(f) UK GDPR), and/or on the basis of your explicit consent where required.

10.3 Your Rights

You retain all of your rights under UK GDPR in respect of the personal data processed in connection with your complaint, including the right of access, rectification, erasure (subject to our record-keeping obligations), and the right to object to processing. Please see our Privacy Policy for full details of how to exercise your rights.

10.4 Requests for Copies of Complaint Files

You may request a copy of the personal data we hold in connection with your complaint by submitting a subject access request to enquiry@unicons.co.uk. Please note that copies of documents will be provided subject to any necessary redactions to protect the personal data of third parties and any legally privileged information.

While we are committed to treating all complainants with respect and fairness, we also have a duty to protect our staff and other service users from behaviour that is unreasonable, vexatious, or abusive.

11.1 Unreasonable Behaviour

We may treat a complainant's behaviour as unreasonable where, in our reasonable opinion, the complainant is:

• Making repeated complaints about the same matter after a final decision has been communicated;
• Engaging in persistent, aggressive, or threatening behaviour towards UNICONS staff;
• Submitting multiple complaints simultaneously as a means of harassment;
• Providing knowingly false or misleading information in support of a complaint;
• Refusing to engage constructively with the complaints process.

11.2 Action We May Take

Where we determine that a complainant's behaviour is unreasonable, we may:

• Formally notify the complainant that their behaviour is unreasonable and explain the impact it is having;
• Restrict contact to a single channel of communication (for example, email only);
• Decline to investigate further complaints about matters that have already been finally resolved under this Procedure;
• In serious cases, suspend or terminate the complainant's access to the UNICONS Platform, without prejudice to any legal rights.

Any decision to take action under this clause will be made by a senior manager and communicated to the complainant in writing.

11.3 Zero Tolerance of Abuse

UNICONS operates a zero-tolerance policy in respect of verbal or written abuse directed at our staff or agents. Any complainant who engages in abusive behaviour (including discriminatory, threatening, or offensive language) will be warned and, if the behaviour continues, may be excluded from the complaints process and from UNICONS services.

This Complaints Procedure will be reviewed at least annually by UNICONS senior management, and following any significant complaint or regulatory change that may affect its operation. The review will consider:

• The volume and nature of complaints received;
• Compliance with the timelines and processes set out in this Procedure;
• Outcomes and remedies applied;
• Feedback from complainants about their experience of the complaints process;
• Regulatory guidance or changes in applicable law.

Any material changes to this Procedure will be communicated to registered users via the Platform and by updating the version number and review date below.

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Contact for Complaints:

Email: enquiry@unicons.co.uk Post: Complaints, LOPEX UNICONS LTD, 214 High Street, Second Floor, Hounslow, TW3 1HB, London, United Kingdom Website: www.unicons.co.uk

Effective Date: 1 September 2025 Last Reviewed: 1 September 2025 Version: 1.0.0

This Complaints Procedure is governed by the law of England and Wales.