Compliants Procedure
  • All complaints, whether received in writing or verbally, must be referred to the Quality Management Team and/or Compliance Officer for attention and to be entered in the Complaints Log.                      
  • Where the complaint can be concluded within 3 working days to the satisfaction of the customer, an acknowledgement letter confirming the decision should be issued within this time. The letter should include details of the customer’s right to refer the matter to the Financial Ombudsman Service in case the client does not accept the decision. A copy of the leaflet, “your complaint and the ombudsman” should be included.
  • In all other cases, complaints must be acknowledged promptly, but at least within 5 working days of receipt and the customer advised of the person who will be dealing with the matter and when they can expect to receive our response. Details of our complaint handling procedure must also be given, or re-stated, together with a copy of “your complaint and the ombudsman” where appropriate.
  • The customer must be kept informed of the progress of the investigation, but our final response must be given within eight weeks of receipt of the complaint. If the complaint is ultimately rejected, we must explain our decision in full and advise the customer if they may be able to refer the matter on to an Approved Dispute Resolution facility as available (currently the Financial Ombudsman Service in the UK and only for consumers, charities with an annual income of less than £1,000,000, trustees of trusts with a net asset value of less than £1,000,000 and commercial clients with fewer than 10 employees and a turnover of less than €2,000,000). They can be contacted by writing to The Financial Ombudsman Service, Exchange Tower, Harbour Exchange Square, London, E14 9SR, or e-mail to complaint.info@financial-ombudsman.org.uk, or by telephone on 0800 023 4567. Further information can be obtained from their web-site www.financial-ombudsman.org.uk.  
  • This letter should inform the customer that if they are unhappy with the response they may have the right to refer the matter to the Financial Ombudsman Service within 6 months of the date of the letter and that we do not provide automatic consent to the Financial Ombudsman Service to consider a complaint outside the 6 month deadline.
  • We will consider the matter closed if the customer does not respond to the final response letter within 8 weeks.
  • If the matter is sufficiently complicated to warrant a lengthier investigation, the customer must be advised and given a reasonable timescale in which we think we can advise further. We must also inform the customer that if he is unhappy with the delay, he can refer the matter to the Financial Ombudsman Service. A copy of the leaflet, “your complaint and the ombudsman” should be included.
  • For Lloyd’s business, we will endeavour to provide our response within 14 days. If you are not satisfied with our response, you may refer your complaint to Lloyd’s by: Phone:0207 327 5693 or Fax: 0207 327 5225 or in writing to: Complaints, Lloyd’s, One Lime Street, London, EC3M 7HA or by e-mail to: complaints@lloyds.com
  • If the complainant remains dissatisfied, and they have received a Summary Resolution Communication, they may request a stage 2 review by Lloyd’s or the Financial Ombudsman Service, whereas complainants that have received a formal response may request a stage 2 review by Lloyd’s. Lloyd’s will investigate the complaint (stage two) and will provide any final response by the end of eight weeks from the complaint being made. (The Code provides for circumstances where a final response cannot be provided within eight weeks).
  • In the event that the complaint relates to activities, or services, provided by another party, the complaint letter should immediately be forwarded to the party concerned, with the request that they deal with it in accordance with their own complaints procedure. The customer should be advised accordingly and the progress tracked.
  • Where the client has purchased cover on-line, The European Commission has provided an on-line dispute resolution (ODR) platform that will allow them to submit their complaint through a central site. This will forward their complaint to the right Alternative Dispute Resolution (ADR) scheme, which in the UK will be the Financial Ombudsman Service, for which contact details have been provided above. More information can be obtained from http://ec.europa.eu/odr
  • Wherever possible, a complaint should be dealt with by one of the above persons and/or a person independent of the employee who originally dealt with the customer. The investigation should include due referral to and discussion with the particular member of staff involved and the checking of internal files and system records to obtain full details and assess overall responsibility and liability.
  • All complaints must be formally recorded in the Complaints Log controlled by the Compliance Officer. Records of all complaints and full copy correspondence must be passed to and kept with the Compliance Officer for a minimum period of 3 years after acceptance of redress or date of the final response.