Complaints Management Policy

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1. INTRODUCTION

1.1 Purpose and Objectives

The purpose of this Complaints Policy is to provide a clear and transparent process for handling complaints from policyholders, potential policyholders, and other stakeholders. This policy aims to ensure that all complaints are managed effectively, in compliance with Bermuda Monetary Authority (BMA) regulations, and with a focus on resolving issues to maintain trust and satisfaction.

1.2 Scope / Field / Application

This policy applies to all employees, agents, and representatives of Global GOP Involved in the handling of complaints. It covers complaints related to the conduct of the Company, including services provided, policy terms, claims handling, and other interactions with stakeholders.

1.3 Availability

The document is readily available to all employees and managers and all these stakeholders shall be appropriately and informed of its provisions. Access to internal procedures, documentation and policies is available to external stakeholders on request.

1.4 Responsibility and Authority

The responsibility of the implementation of this policy lies with the Complaints Manager, Complaints Department as well as the Management of the Company.

2. POLICY

2.1 Categorisation of Complaints Complaints are differentiated to ensure that the appropriate attention is given to complaints depending on their nature. Complaints are categorised in accordance with the following minimum categories:

Complaints relating to the design of the policy or related service, including the premiums or other fees or charges related to that policy or service;
Complaints relating to information provided to policyholders;
Complaints relating to advice;
Complaints relating to policy performance;
Complaints relating to service of policyholders, including complaints relating to premium collection or lapsing of policies;
Complaints relating to policy accessibility, changes, or switches;
Complaints relating to complaints handling;
Complaints relating to insurance risk claims, including non-payment of claims; and
Other complaints.

2.2 What Constitutes a Complaint?

The Company views any expression of dissatisfaction with its services, products, or conduct, as a complaint.

A complaint is defined as an expression of dissatisfaction regarding the conduct of the company including but not limited to issues related to:

Services provided
Terms of the insurance policy
Handling of a claim
Any other aspect of the Company’s operations that is believed to breach its obligations or regulatory requirements.

The Bermuda Monetary Authority (BMA) defines a complaint within the context of insurance regulation as:

“An expression of dissatisfaction by a policyholder or a potential policyholder concerning the conduct of an insurer, including the services provided, the terms of the insurance policy, or the handling of a claim, which is believed to be in breach of the insurer’s obligations or regulatory requirements.”

2.3 Tracking and Recording of Complaints As an authorised financial services provider, the FSP is committed to rendering services honestly, fairly, with due skill and it is for this reason that other complaints by members are recorded and tracked for quality control purposes. In addition to valid member complaints, the following is also recorded and tracked:

unjustified or invalid complaints;
non-member complaints;
service provider complaints.

2.4 Lodging Complaints

Any member, or prospective member, which has experienced any of the categories of complaints mentioned above in 2.1, may lodge a complaint in writing or verbally.

2.5 Submitting a Complaint

Complaints may be submitted as follows:

by email;
by fax;
via the website;
via social media (Facebook, Google reviews, Hello Peter); or
telephonically.

Any complaints received by company employees should be forwarded to the Complaints Department without delay. This can either be done electronically or telephonically. Any complaints received from legal entities representing dissatisfied members, the Regulator, or the Bermuda Monetary Authority (BMA) should be relayed to the Complaints Department without delay.

A central email address (complaints@globalgop.co.za) is used to communicate with all members that have lodged a complaint.

2.6 Basic Principles of the Complaints Resolution System The Company is committed to maintain an internal complaint resolution system and procedures based on the following:

Maintenance of a comprehensive complaints policy that outlines the Company’s commitment to, and system and procedures for, internal resolution of complaints;
Transparency and visibility: ensuring that members have full knowledge of the procedures for resolution of their complaints;
Accessibility of facilities: ensuring the existence of easy access to such procedures at any office or branch of the provider is open to members, or through ancillary postal, fax, telephone, or electronic helpdesk support; and
Fairness: ensuring that a resolution of a complaint can during and by means of the resolution process be affected which is fair to both members and the company and its employees.

2.7 Standards for Record Keeping

To ensure effective complaints monitoring and analysis, complaints need to be accurately, efficiently, and securely recorded. Complaints recorded include:

all relevant details of a complainant and the subject matter of the complaint;
copies of all relevant evidence, correspondence, and decisions;
the complaint categorisation as set out in 2.1;
progress and status of complaints, including whether such progress is within or outside the prescribed timeline.

The following data in relation to complaints needs to be recorded on an ongoing basis:

number of complaints received, upheld, rejected and the reason for rejection;
number of complaints escalated by complainants using the internal complaints escalation process;
number of complaints referred to the Bermuda Monetary Authority (BMA) and their outcome;
compensation and goodwill payments;
total number of complaints outstanding.

Records of complaints shall be appropriately maintained for a period of five years and regular reporting to senior management will be conducted.

2.8 Escalation Process

The complaints escalation and review process should:

follow a balanced approach, bearing in mind the legitimate interests of all parties involved including the fair treatment of the complainants;
provide for escalation of complex or unusual complaints at the instance of the initial complaint handler;
provide for complainants to escalate complaints not resolved to their satisfaction;
be allocated to an impartial, senior functionary within the insurer or appointed by the insurer for managing the escalation and review process.

2.9 Appeals

A complainant that is aggrieved at the outcome of a complaint is entitled to appeal the decision of the Company. Complainants will be advised of this right when the outcome of a complaint is communicated.

Internal appeals against a decision may be lodged, in writing and will be assessed by the Complaints Manager who will provide an outcome to the complainant, within two weeks of receipt of the appeal. The complainant will also be advised of further steps, such as the right to refer the dispute to the to the Bermuda Monetary Authority, for further review.

2.10 Upheld and Rejected Complaints

Where a complaint is upheld, any commitment to make a compensation, goodwill payment or to take any other action must be conducted without undue delay and within any agreed timeframes.

Where a complaint is rejected, the complainant must be provided with clear and adequate reasons for the decision and must be informed of any applicable escalation or review processes, including how to use them and any relevant time limits. The member may, within the required timeframes outlined in legislation, pursue the relevant Regulator with the complaint.

Contact Information for the Bermuda Monetary Authority (BMA)

Address:
Bermuda Monetary Authority
43 Victoria Street
Hamilton HM 12
Bermuda

Phone:
+1 (441) 295-5278

Email:
info@bma.bm

Website:
www.bma.bm

2.11 Employee Training

The Company undertakes to:

ensure that adequate training is provided to all relevant employees, ensuring full knowledge of all applicable legislation regarding resolution of complaints;
have an appropriate combination of experience, knowledge and skills in complaints handling, fair treatment of members, the subject matter of the complaints concerned and relevant legal and regulatory matters;
not be subject to conflict of interest;
be empowered to make impartial decisions or recommendations;
ensure that employees are aware of provisions for the escalation of reportable complaints; and
ensure that employees are made aware of the contents of this policy as well as its effect and purpose.

2.12 Communication to the Insurer and Regulator

When the Company has received a complaint from a complainant via the insurer the following is to be conducted:

Acknowledge receipt of complaint from Insurer;
Complaints Manager to allocate complaint to a relevant Complaints Officer;
Complaints Officer to communicate with the Complainant and resolve complaint;
Feedback of the outcome to be provided to the insurer;
The Company will ensure the following when communicating with the Regulator;
Maintain open and honest communication and cooperation between itself and the Regulator; and
Endeavour to resolve a complaint before a final determination or ruling is made by the Regulator, or through its internal escalation process, without impeding or unduly delaying a complainant’s access to the Regulator.

3. RISK IMPLICATIONS

Risk is the consequences of potentially not adhering to the outlined guidelines within this document and how it could negatively affect the business.

3.1 What Would Happen If the Process Is Not Followed?

Risk Type	Risk Description
Financial	The company may lose profits through the paying of refunds and fines.
Operational	If complaints are managed poorly, customers may withdraw their business and encourage others to do the same. Complaints that are managed well may help you retain existing customers and could result in new customers being referred to your business. Negative complaints lead to reputational damage for the company.

4. COMPLIANCE AND DEVIATIONS

It is the responsibility of all employees and representatives to comply with all statutory and regulatory requirements, as well as corporate policies. Any deviation from this or related procedure should be communicated, in writing, to the Head of Compliance for inclusion into exception reports. The communication should detail the reason for the deviation and should contain clear instructions of the alternate process to follow.

5. DEFINITIONS, ACRONYMS, ABBREVIATIONS AND TERMS

The terms in this document should be interpreted as meaning:

No.	Term/Acronym/Abbreviation	Definition
(i)	Complainant	means a person who submits a complaint and includes a: policyholder or policyholder’s successor in title; beneficiary or the beneficiary’s successor in title; person whose life is insured under a policy; person that pays a premium in respect of a policy; member, or potential policyholder or potential member whose dissatisfaction relates to the relevant application, approach, solicitation or advertising or marketing material, or who has a direct interest in the agreement, policy, or service to which the complaint relates, or a person acting on behalf of a person referred to in (a).
(ii)	Complaint	Defined in the context of 2.2
(iii)	Compensation Payment	means a payment, whether in monetary form or in the form of a benefit or service, by or on behalf of an insurer to a complainant to compensate the complainant for a proven or estimated financial loss incurred as a result of the insurer’s contravention, non-compliance, action, failure to act, or unfair treatment forming the basis of the complaint, where the insurer accepts liability for having caused the loss concerned, but excludes any: goodwill payment; payment contractually due to the complainant in terms of a policy; or refund of an amount paid by or on behalf of the complainant to the Insurer where such payments were not contractually due; and includes any interest on late payment of any amount referred to in paragraphs (b) or (c).
(iv)	Employee	means a person employed by the Company for purposes of remuneration in exchange for work done.
(v)	Goodwill payment	means a payment, whether in monetary form or in a form of a benefit or service, by or on behalf of an Insurer to a complainant as an expression of goodwill aimed at resolving a complaint, where the Insurer does not accept liability for any financial loss to the complainant as a result of the matter complained about.
(vi)	The Bermuda Monetary Authority	The Bermuda Monetary Authority is the integrated regulator of the financial services sector in Bermuda.
(vii)	Policyholder query	means a request to the insurer or the insurer’s service provider by or on behalf of a policyholder, for information regarding the insurer’s policies, services, or related processes, or to conduct a transaction or action in relation to any such policy or service.
(viii)	Rejected	means that a complaint has not been upheld and the insurer regards the complaint as finalised after advising the complainant that it does not intend to take further action to resolve the complaint and includes complaints regarded by the insurer as unjustified or invalid, or where the complainant does not accept or respond to the insurer’s proposal to resolve the complaint.
(ix)	Reportable complaint	means any complaint other than a complaint that has been: upheld immediately by the person who initially received the complaint; upheld within the insurer’s ordinary processes for handling policyholder queries in relation to the type of policy or service complained about, provided that such process does not take more than five business days from the date that the complaint is received.
(x)	Upheld	means that a complaint has been finalised wholly or partially in favour of the complainant and that: the complainant has explicitly accepted that the matter is fully resolved; or it is reasonable for the insurer to assume that the complainant has accepted; and all undertakings made by the insurer to resolve the complaint have been met or the complainant has explicitly indicated its satisfaction with any arrangements to ensure such undertakings will be met by the insurer within a time acceptable to the complainant.
(xi)	Writing or Written	includes communication by telefax or any appropriate electronic medium that is accurately and readily reducible to written or printed form.

6. REFERENCES

This Policy should be read in conjunction with the following Acts and/or Directives:

Regulatory and Compliance Framework (REG-FRW/001),
Policyholder Protection Rules Insurance Act 1978,
BMA’s Insurance Code of Conduct,
Complaints Management Framework,
Consumer Protection Act 1999,
International Association of Insurance Supervisors (IAIS), and
Bermuda Financial Services Commission (BFSC) Guidelines.

7. AMENDMENTS AND PROPOSED CHANGES

The Complaints Department is the owner of the policy and is therefore responsible for ensuring that the information in this directive is kept up to date.

Any required amendments, adjustments and proposed changes must be channelled through the Head of Compliance for review prior to approval.

8. APPROVAL AND REVIEW

This directive is approved at Executive level, by the Executive Committee of the Company.

This directive is approved at Executive level, by the Head of Compliance.
This directive is approved at Operational level, by the Complaints Manager.

It will be reviewed, at a minimum, every year, as well as in line with applicable changes to legislation or foundational documentation.

9. APPENDICES

9.1 Appendix A: Complaints Register – Content

The Company is required to have a complaint register and to record complaints within it. The below is mandatory content in a complaint register to be kept by the Company:

Name and Surname of the complainant as well as their details:
Nature of the complaint and the date the complaint was received	Advice, admin and service issues, fraud, claim related complaints etc.
Categorisation of the complaint	Reportable or Non-reportable.
What TCF Outcome the Complaint falls into	9 TCF Outcome Choices: 2; 3; 4; 5(a); 5(b); 6(a); 6(b); 6(c) and others.
Who will respond to the complaint	Complaints Department i.e., Complaints Manager or the Complaints Officer
Actions to be taken to respond to the member and how the response has been made and by whom	Complaints will be responded to electronically or telephonically by the Complaints Department.
The outcome of the process and how the complaint was dealt with/resolved and whether it was within the allocated time	Whether favourable or not, investigations conducted within the allocated 3 weeks
The associated inherent risk of the complaint. What controls have been evaluated and have been implemented to prevent such complaints from reoccurring	Whether financial or non-financial. E.g., Evaluating Employee performance, policy wording, claims procedures etc. to determine where the lack is and how to improve those to eliminate or lessen future complaints.
Reported to the manager of the employee where the complaint arose	If the complaint arose out of the misconduct of an employee in a certain department, that the employee’s manager will be notified of such.

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