Avoid Disputes, Not Complaints Presented by: Stuart Ayres and Derek Pullen Stuart Ayres, Scheme Manager Derek Pullen, Scheme Adjudicator

Avoid Disputes, Not Complaints “Customers can not only talk back, they can look into the very workings of your business and decide if you conduct yourself in a way they approve of. In this world, your reputation will be the sum total of all your conduct and interactions, which will now be so much more measurable by outsiders” Tom Friedman, “The World is Flat”

Never Had One, Never Will  Be prepared, be pro-active  Must have an internal complaints system  Consumer awareness  Benefit to consumers and to financial service providers  From bottom drawer to business tool  Reputation and referrals  Environment of trust and open exchange  New business

What is a Complaint? Any indication that a service or product does not meet a customer’s expectations

What is a Complaint? Feedback

Overview  Developing a good Internal Complaints Process (ICP)  The FDR Dispute Resolution Process  Complaint Handling  Complaints are Gifts  Root Cause Analysis  Q and A

Developing a good ICP  Guiding Principles (ISO 10002)  Visibility  Accessibility  Responsiveness  Objectivity  Free  Confidentiality  Customer focused approach  Accountability  Continual improvement

Developing a good ICP – Alternative Dispute Resolution

Developing a good ICP – The Framework  Commitment of top management and personnel  Policy  Customer focused – obtain input from customers, personnel and interested parties  Known by all personnel  Available to customers and interested parties  Consider regulatory and operational requirements  Align quality and complaints policy

Developing a good ICP – The Framework Responsibility and Authority  Top Management  Complaints Handling Representative  Managers  Personnel in contact with customers and complainants  Communication

Developing a good ICP – The Framework  Responsibility and Authority – Top Management  Ensuring establishment, planning, designing, implementation  Maintenance and continuous improvement of I C P and its objectives  Identifying and allocating management resources and representatives  Ensure promotion of I C P and customer focus  Periodically review I C P to ensure effective, efficient and continuously improved  Make information about the I C P is easily accessible to all  Develop a process for escalating significant complaints to senior management

Developing a good ICP – The Framework Responsibility and Authority – Complaints Representative Complaints Handling Representative (senior person, marketing?) Establish the process for performance monitoring, evaluation and reporting Reporting to top management on I C P, with recommendations for improvement Maintaining effective and efficient operation of I C P, including personnel I T, documentation, deadlines and process reviews

Developing a good ICP – The Framework Responsibility and Authority – Managers Implementation Liaising with ICP representative Promotion of awareness of I C P and customer focus Information on I C P is accessible Reporting on actions and decisions Ensure monitoring of I C P undertaken and recorded Ensure action taken to correct problem, prevent in future and recorded Ensure data available for review

Developing a good ICP – The Framework Responsibility and Authority – Personnel All personnel in contact with customers and complainants; Trained in complaints handling Comply with I C P requirements Treat customers courteously and promptly respond to complaints Show good interpersonal and communication skills Aware of their roles, responsibilities and authorities re. complaints Aware of procedures to follow and information to give complainants Report complaints of significance

Developing a good ICP - Operation Communication Information readily available, clear language and formats Disclosure document, brochures, website, Where and how complaints can be made Information to be provided regarding the dispute process; ­ Time periods of various stages ­ Options for remedy ­ Avenues for feedback on the complaint

Developing a good ICP - Operation  1.Receipt  2.Tracking  3.Acknowledgement  4.Initial Assessment  5.Investigation  6.Response – Decision and deadlock notices

Developing a good ICP - Operation  1.Receipt Record with supporting information and unique I D code Identify remedy sought by complainant Identify products / practices complained about Due date for response Data on people etc Immediate action taken

Developing a good ICP - Operation  2.Tracking Complaint should be tracked throughout entire process until complainant satisfied or decision made Up-to-date status made available to complainant on request and at regular intervals

Developing a good ICP - Operation  3.Acknowledgement  Receipt acknowledged immediately (post, phone or )  Certainly within 2 working days  4. Initial assessment  For severity, safety implications, complexity, impact and need for possible immediate action  5.Investigation  Reasonable effort made to investigate all relevant circumstances and information  Level commensurate with seriousness, frequency and severity

Developing a good ICP - Operation Response – Decision Notice  P I Insurer - notify  Following investigation, offer response  Decision notice (suggest within 10 working days)  If accepted, obtain acceptance in writing  Carry out decision /action and record Response – Deadlock Notice If decision not accepted by complainant  Issue Deadlock Notice (Template)  State view unlikely to resolve complaint internally  Outline clearly how to access FDR scheme (free)  Leave complaint “open”  Liaise with FDR  Monitor progress until complainant satisfied

Developing a good ICP – Maintenance and Improvements  1.Collection of Information  2.Analysis and evaluation of complaints identify systemic, recurring and single incident problems and trends  3.Satisfaction with the I C P Random surveys?  4.Monitoring of the I C P  5.Auditing of the I C P  6.Management review  7.Continuous improvement, product / service development

Developing a good ICP – Possible Responses  Refunds  Replacement  Rework  Substitutes  Technical assistance  Information  Referral  Financial assistance  Other assistance  Compensation  Apology  Goodwill gift or token  Indication of changes in products, processes, policy, procedure

Disputes Resolution Process

Suggested Website Disclosure If you have a complaint about “S M ” or one of its representatives please contact “S M ”. “S M” has a formal complaints process. If you feel your complaint has not been resolved to your satisfaction by “S M”, you can contact our independent dispute resolution provider Financial Dispute Resolution (