1. Introduction and purpose
The Company strives to achieve policyholder satisfaction and customer confidence in its insurance products. Accordingly, the Company adopts this Policy in order to address all forms of policyholder dissatisfaction.
The Company recognises a complaint as an expression of dissatisfaction by any customer, or potential customer of the Company, who has a direct interest in an insurance policy with the Company, and such dissatisfaction relates to an alleged unfair treatment of the customer, failure by the Company to adhere to the agreement or any legal or contractual obligation or maladministration, wilful or negligent action by the Company.
2. Implementation date
This Policy shall take effect on adoption by the Board of Directors.
It is the Company’s policy to achieve policyholder satisfaction, and accordingly to properly consider and respond to any complaint received from a policyholder, prospective policyholder, customer or from the Ombudsman. The Company envisages a fair and accessible complaints process, and endeavours to respond to all complaints promptly and within a reasonable time of having received them.
3.1 Complaints Management Process
The Company shall adopt a Complaints Management Process which shall ensure the following:
- - Appropriately trained staff shall receive and respond to complaints;
- - A transparent and clear complaints process, where complainants are regularly updated on the status of their complaint, should the complaint not be finalised within fourteen (14) days;
- - Communications to complainants shall be in clear and understandable language;
- - Proper investigation of complaints shall be conducted before a complaint is responded to;
- - Complaints shall be dealt with promptly, within the shortest possible time;
- - Receipt of complaints shall be acknowledged in writing to the complainant, and internally recorded;
- - Complaints shall be given proper consideration;
- - Complainants are informed of the results of consideration with full, written reasons and within a reasonable time frame;
- - Complaints shall be recorded and arranged by category of complaint;
- - All records of complaints are kept for five years;
- - Complaints shall be reported on a regular basis in accordance with regulatory requirements;
- - A fair resolution to both the complainant and the Company is sought.
The Complaint Management Process shall be monitored and checked by regular audit, to ensure effective compliance. The Complaint Management Process shall also be subject to risk and control processes.
The Complaint Management process shall be displayed in all retail stores and on the House and Home and OK Furniture websites. This process shall be in plain and clear language so that it is easily understandable.
The Company shall review and monitor records of complaints in order to ensure fair treatment of policyholders, to reduce further occurrence of similar future complaints and to ensure customer satisfaction.
The company shall ensure that records comply with the following:
- - Records shall be kept for a period of five (5) years;
- - Records shall be accurate and efficiently and securely recorded in line with the Company’s IT Governance Policy and Record Retention Policy;
- - Records shall contain all relevant details of the complainant and the subject matter of the complaint with copies of all relevant evidence, correspondence and decisions;
- - All personal information of the complainant shall be recorded according to the Protection of Personal Information Act, 2014, and the Company’s Data and Protection of Personal Information Policy;
- - Records shall include categories of complaints, and all relevant complaints statistics.
The Company shall keep and analyse the following statistical records:
- - Number of complaints received;
- - Number of rejected complaints;
- - Number of complaints resolved in favour of the complainant;
- - Number of escalated complaints;
- - Number of compensation payments made: “Compensation payment” means a payment by a firm to a complainant to compensate the complainant for a proven or estimated financial loss incurred as a result of the matter complained about, where the firm accepts responsibility for having caused the loss concerned;
- - Number of goodwill payments made;
- - Number of complaints received from the ombudsman.
3.3 Categories of Complaints
The Company shall place complaints in the following categories:
- - Complaints relating to the design of the policy;
- - Complaints relating to information provided about the policy;
- - Complaints relating to advice given;
- - Complaints relating to customer service;
- - Complaints relating to product accessibility by the policyholder, and changes to policies;
- - Complaints relating to complaints handling;
- - Complaints relating to the claims process.
3.4 Complaints Analysis
The Company shall use complaints information to manage conduct risks and improve customer satisfaction. Complaints information shall be analysed on a regular basis in order to achieve this.
The Company’s complaints analysis shall be used to achieve the following:
- - Identify root causes of common categories of complaints;
- - Identify weaknesses in control systems;
- - Detect poor performance, lack of skills or misconduct;
- - Track the Company’s “Treating Customers Fairly” progress or delivery, and
- - Effect meaningful improvements for policyholders and the Company business.
3.5 Internal Review
Due to the insignificant number of complaints received, the Company shall not have an internal escalation process. Each complaint shall be reviewed at the highest level, by a Company director, and receive specific individual attention. This process is proportionate to the business and to the average number of complaints received per quarter.
3.6 Engagement with Ombud Schemes
The Company shall disclose and display the details of the relevant ombud services to policyholders, however, complaints shall only be escalated to the ombud once internal remedies have been exhausted. The Company shall ensure open and honest communications and co-operation with the ombud at all times.
Complaints received by staff at OK Furniture or House and Home stores, shall be recorded in writing and shall be forwarded to email@example.com, where they will be reviewed by a director of the Company, and with extensive experience in dealing with customer complaints. Complaints shall be recorded and placed into the relevant categories.
This Policy was adopted by the Board of Directors on 17 May 2016.