Complaints Handling Procedure

FAEU Insurance Brokers LLC recognises that there may be occasions when a complainant or insurer or third party feels that the level of service or treatment that they have received has fallen short of what might reasonably be expected.

This Complaint Handling Policy reflects FAEU’s commitment to dealing with such complaints as timely, effectively and fairly as possible. Our aim is to resolve issues of dissatisfaction as close as possible to the level at which they arise and to conduct thorough and fair investigation of complaints so that, where appropriate, we can make evidence-based decisions based on the facts of each individual case.

Objectives

The objectives of Beneple’s complaints handling procedures are:

• To allow complainants, insurers and others to report instances of non-compliance with the laws and regulations;
• Provide channels for clients, potential clients, regulators, or other business partners to raise complaints;
• Provide a clear escalation process regarding complaints received both internally and externally;
• To use complaints to enhance procedures and correct procedural or policy deficiencies.

Roles and responsibilities

Complaints cannot be handled by the person about whom the complaint is made, nor by a department which is the subject of the complaint.

Definition of a complaint

Any expression of dissatisfaction made by a client, potential client, business partner, any regulatory body or any other person to the company, either directly or indirectly, which is related to a product or service provided by the company or an employee of the company, a service provided by an intermediary or another business partner of the company.

What is not a complaint?

There are some issues that are excluded from the complaints procedure. For example, in relation to Beneple, any complaint related to a medical policy concerning denial of coverage for a consultation, treatment or procedure which is clearly not covered under the policy or where the cost of the treatment exceeds the monetary limits under the terms of the policy.

However, where the cause of the complaint relates wholly or in part to vague wording or unclear definitions in the policy wording, terms and conditions or table of benefits this will be considered a complaint, however, should be referred to the policy provider. In this instance the complainant should be informed that they need to raise the complaint directly with the policy provider and the provider should be informed that the complainant has an issue to raise. The complaint can then be closed in the broker complaint log.

Identifying a complaint

• An explicit comment or statement such as “I want to make a complaint” or “Who do I complain to about this?” indicates the existence of a complaint.
• An expression of dissatisfaction such as “I am not happy with…” or “I am not satisfied with what you are saying…” or “This policy that I was sold does not meet my need” indicates the existence of a complaint.
• A statement that expectations were not met such as “I was told that… but this has not happened” or “You promised to… but…” or “I asked for… but did not receive…” indicates the existence of a complaint.

How to file a complaint

A complainant can raise a complaint in more than one way.

• They can directly raise the complaint with a representative of the company. A representative can be the insurance broker, the advisor themselves or any such person who is directly or indirectly in contact with the complainant through our business.
• Complaints can also be received via the company website, telephone, email and mail. If a client wishes to submit a complaint they can be directed to do so using the relevant email address.
• If a complaint or potential complaint has been identified by an employee of FAEU they must report the complaint via Praktora or the relevant email address.

Praktora complaint logging

Details of how to log a complaint on the Praktora system can be found on the firm’s intranet site.

Time limit for making a complaint

This procedure sets a time limit of six months to raise a complaint with FAEU, starting from when the complainant first became aware of the problem, unless there are special circumstances for requesting consideration of a complaint beyond this time. Beyond the six-month time limit, FAEU will exercise discretion in the way that the time limit is applied.

What happens after a complaint?

Stage 1

The complaint will be reviewed and assessed by the Stage 1 complaint handler. If the complaint is deemed substantive and cannot be resolved informally, the Stage 1 complaint handler will assess the complaint and provide an initial formal response to the complainant within 5 working days. The complaint will be categorised using the following:

• Advice provided;
• Product suitability;
• Accuracy of documentation;
• Delays in the process;
• Administrative or operational process or procedures;
• Service provided by advisers, staff or department.

Stage 2

If the Stage 1 complaint handler is unable to resolve the complaint to the complainant’s satisfaction the complaint will be escalated to the Stage 2 complaint handler. They will investigate the complaint, which may involve reaching out to insurers to gain further information on the case. If the complaint is escalated to Stage 2, a response must be provided to the complainant within 15 working days of the complaint being escalated to the Stage 2 complaint handler.

Stage 3

If the Stage 2 complaint handler is unable to resolve the complaint to the complainant’s satisfaction, the complaint will be escalated to the DHA / CBUAE for independent advice, as no internal solution could be found. We will keep open channels of communication between both the complainant and the DHA / CBUAE. The complaints process is summarised in the flowchart below.

The below categories should be referred to the policy provider. The complainant should be informed that they need to raise the complaint directly with the policy provider and the provider should be informed that the complainant has an issue to raise.

• Denial of coverage;
• Rejection of claim;
• Accuracy of documentation provided (by the provider);
• Delays in process (refunds, reimbursements, approvals, issue of membership cards, additions or deletions of members where this is completed by the provider);
• Administrative or operational process or procedures (of the provider);
• Product dissatisfaction or suitability;
• Changes to policy terms (exclusions, conditions, renewal, premiums, network coverage);
• Service provided by staff or departments (efficiency, attitudinal, behavioural, knowledge, of the provider).

Systems and controls

As part of the firm’s control framework, monthly complaint reports will be sent to management. An annual review of the complaints log and complaints process will be conducted. This ensures that feedback or lessons learned from received complaints are incorporated into this policy and procedures, as well as into wider business practices.

Staff training

All new staff members will be provided with a copy of this complaint handling procedure, and all updates will be accessible to all employees.

Confidentiality

Confidentiality is an important factor in conducting complaints investigations. FAEU will always have regard to any legislative requirements. Complaints will be handled with an appropriate level of confidentiality and information released only to those who need it for the purposes of investigating or responding to the complaint. No third party will be told any more about the investigation than is strictly necessary in order to obtain the information required from them.

In making a complaint, complainants should accept that limited disclosure of all or part of their submission will be required to enable investigation of their complaint to proceed. Complainants have the right to expect that everyone who responds to or investigates a complaint will do so impartially. No individual will be permitted to act in any manner in a case in which they have a material interest or in which any actual or potential conflict of interest may arise.

Reporting of complaints

At the start of every year an annual complaints report will be submitted to the Dubai Health Authority, Health Funding Department.

KPIs contained in the complaints log include:

• Complaints actual TATs by number of days to resolution or point of referral to third-party deliberation;
• Number of complaints outstanding at end of each calendar month;
• Number of complaints unresolved after 15, 30, and 90 days at the end of each calendar month;
• Number of complaints escalated for outside deliberation or arbitration;
• Complainant satisfaction with the outcome of internal handling of the complaint (as a minimum a scoring system, with 1 = fully satisfied, 2 = largely satisfied, 3 = largely unsatisfied, 4 = completely dissatisfied);
• Number of complaints by category;
• Number of complaints fully upheld;
• Number of complaints partially upheld;
• Number of complaints denied (prior to any external escalation).

Complaints log

The following list contains the column headers that are included in the complaints register:

• Complaint ID
• Complainant
• Date received
• Received by
• Source of complaint (phone, etc.)
• Complaint owner
• Staff member against whom the complaint has been directed
• Repeat complaint
• ID of previous complaint
• Policy number
• Policy name
• Provider name
• Complaint category (incorrect advice, etc.)
• Has the complaint been made to the service provider?
• Name of person from service provider dealing with the complaint
• Date formal reply sent to service provider
• Further detail of complaint
• Resolution notes
• Date of resolution
• Date file closed