INSURANCE COMPLAINTS PROCEDURE
Shoprite Checkers (Pty) Ltd trading as OK Furniture and House & Home (“The Company”)
1. Introduction and purpose
The Company is a registered Financial Services Provider in terms of the Financial Advisory and Intermediary Services Act and has been appointed by the Insurer (Centriq Insurance Company Limited and Centriq Life Insurance Company Limited) to act as a non-mandated Intermediary.
The Company strives to achieve policyholder satisfaction and customer confidence in the insurance products offered or provided to policyholders. Accordingly, the Company adopts this Policy in order to address all forms of policyholder dissatisfaction.
The Company recognises a complaint as defined in the Policyholder Protection Rules:
“ Complaint”: means an expression of dissatisfaction by a person to an insurer or, to the knowledge of the insurer, to the insurer's service provider relating to a policy or service provided or offered by that insurer which indicates or alleges, regardless of whether such an expression of dissatisfaction is submitted together with or in relation to a policyholder query, that—
- the insurer or its service provider has contravened or failed to comply with an agreement, a law, a rule, or a code of conduct which is binding on the insurer or to which it subscribes;
- the insurer or its service provider's maladministration or wilful or negligent action or failure to act, has caused the person harm, prejudice, distress or substantial inconvenience; or
- the insurer or its service provider has treated the person unfairly;”
“Complainant”: means a person who submits a complaint and includes a:
- policyholder or the policyholder’s successor in title;
- beneficiary or the beneficiary’s successor in title; or
- person whose life is insured under a policy;
- person that pays a premium in respect of a policy;
- member of a group scheme; or
- potential/prospective policyholder or potential member of a group scheme whose dissatisfaction relates to the relevant application, approach, solicitation or advertising or marketing material, 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 above.
“Insurer”: means Centriq Insurance Company Limited, a licensed Non-Life insurer and FSP 3417 and Centriq Life Insurance Company Limited, a licensed Life insurer and FSP 7370
“TCF”: means Principles of Treating Customers Fairly as reflected in the Policyholder Protection Rules.
“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 so accepted; and
- all undertakings made by the Company to resolve the complaint have been met or the complainant has explicitly indicated its satisfaction with any arrangements to ensure that such undertakings will be met by the Insurer or its service provider within a time acceptable to the complainant.
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 or prospective policyholder 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 (see Complaints Procedure) which:
- is proportionate to the nature, scale and complexity of the insurer's business and risks;
- is appropriate for the business model, policies, services, policyholders, and beneficiaries of the insurer;
- enables complaints to be considered after taking reasonable steps to gather and investigate all relevant and appropriate information and circumstances, with due regard to the fair treatment of complainants;
- does not impose unreasonable barriers to complainants; and
- must address and provide for, at least, the matters provided for Rule 18 of the Policyholder Protection Rules.
Other important considerations regarding the Company’s Complaints Management Process:
- 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.
- 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 fourteen (14) days after having sent confirmation of receiving your complaint, unless further documentation is required from you, which may cause a longer response 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 at least five years;
- Complaints shall be reported on a monthly basis to the Insurer;
- A fair resolution to both the complainant and the Company is sought.
The Complaint Management Process shall be reviewed regularly, to ensure effective compliance. The Complaint Management Process shall also be subject to risk and control processes.
The Complaint Management process shall be made available to any Customer in all retail stores and is also available on the website for OK Furniture: www.okfurniture.co.za; and House & Home: www.houseandhome.co.za. This process shall be in plain and clear language so that it is easily understandable.
The Company shall ensure accurate, efficient and secure recording of complaints-related information. 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, 2013, 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 record the following in respect of each reportable complaint-
- all relevant details of the complainant and the subject matter of the complaint;
- copies of all relevant evidence, correspondence and decisions;
- the complaint categorisation as set out in rule 18.5; and
- progress and status of the complaint, including whether such progress is within or outside any set timelines.
The Company shall keep and analyse the following statistical records:
- Number of complaints received;
- Number of rejected complaints which will be deemed invalid insurance claims;
- Number of complaints escalated by complainants to the internal complaint’s escalation process;
- Number of complaints resolved in favour of the complainant (“complaints upheld”);
- 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 (and their respective outcomes).
- Number of complaints outstanding.
3.3 Categories of Complaints
The Company shall place complaints in the following categories:
- TCF Outcome 2 : Complaints relating to the design of the policy;
- TCF Outcome 3 : Complaints relating to information provided about the policy;
- TCF Outcome 4 : Complaints relating to advice given;
- TCF Outcome 5a : Complaints relating to product and service expectation;
- TCF Outcome 5b: Complaints relating to customer service;
- TCF Outcome 6a :Complaints relating to product accessibility by the policyholder, and changes to policies;
- TCF Outcome 6b :Complaints relating to complaints handling;
- TCF Outcome 6c :Complaints relating to the claims process.
3.4 Complaints Analysis
Complaints information recorded shall be scrutinised and analysed (root cause analysis) by the Company on a quarterly basis and utilised to manage conduct risks and effect, improved outcomes and processes for its policyholders, and to prevent recurrences of poor outcomes and errors. Complaints information shall be analysed quarterly by the Compliance Manager as well as the Market Conduct Review Committee (“MCRC”) during its quarterly Committee meetings. The MCRC’s complaint root cause analysis shall also be included in the Board Meeting pack in order to report to the Company’s Board of Directors.
3.5 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 the Complaints will be reviewed and addressed as applicable Complaints shall be recorded and placed into the relevant categories listed above.
This Policy was adopted by the Board of Directors on September 2021
1.1 Complaints Procedure
Shoprite Checkers (Pty) Ltd trading as OK Furniture and House & Home (“The Company”)
Complaints Management Process for customer business
This document explains the procedure to be followed when you lay a complaint against the Company or the Insurer (Centriq Insurance Company Limited and Centriq Life Insurance Company Limited) in respect of an insurance policy for Consumer protection (death, disability, retrenchment or all risks) or warranty protection.
The Company employs trained and experienced staff who will attend to your complaint in a fair and timely manner.
a) Submitting a complaint
If you are an individual policyholder (or possible future policyholder) and have either a consumer protection policy, or a warranty protection policy:
You may lodge a complaint either:
- In writing at any OK Furniture or House and Home store, where staff are trained to receive and process your complaint;
- via email to: firstname.lastname@example.org ; or
- escalate the complaint to the Insurer (Centriq Insurance Company Limited and Centriq Life Insurance Company Limited) via email to: email@example.com
You must provide the following information with your complaint:
- All documentation relevant to your complaint;
- Factual summary of your complaint;
- Policy number;
- Contact details, including your physical and postal address and cell phone number.
Once your complaint has been submitted in writing, you will be notified within two working days that your complaint has been received.
The Company will document your complaint. Your policy number will be your reference number.
The Company will investigate your complaint and will respond within fourteen (14) days after having sent confirmation of receiving your complaint, unless further documentation is required from you, which may cause a longer response time.
The Company will properly consider your complaint and will inform you in writing regarding the outcome and will give you clear reasons for the decision.
If you are not satisfied with the decision of the Company, you may escalate your complaint to the Insurer (Centriq Insurance Company Limited and Centriq Life Insurance Company Limited) via email to: firstname.lastname@example.org
If you are not satisfied with the decision given to you, you may approach the Ombudsman for Short Term Insurance, the Ombudsman for Long Term Insurance or the FAIS Ombudsman within 6 (six) months.
The details for the Short Term Insurance Ombudsman are:
1 Sturdee Avenue,
1st Floor, Block A,
P.O. Box 32334,
Telephone: 011 726 8900 / 0860 726 890
Fax: 0 11 726 5501
The details for the Long Term Insurance Ombudsman are:
3rd Floor, Sunclare Building,
21 Dreyer Street,
Private Bag X45,
Cape Town, 7735
Telephone: 021 657 5000 / 0860 103 236
Fax: 021 674 0951
The details for the FAIS Ombudsman are:
125 Dallas Avenue Menlyn
P O Box 74571,
Telephone: 012 762 5000 / 012 470 9080
Fax: 012 348 3447 / 012 470 9097 / 086 764 1422
There is no charge for this complaints service.