Our commitment at ADM Focus (Pty) Ltd is to give excellent service to our clients. ADM Focus (Pty) Ltd takes all complaints seriously and our aim is to resolve all client complaints promptly.

OVERVIEW

The Complaint Resolution Policy serves to provide guidance around the recording and handling of complaints with a view to continuously improve our service excellence.

The Policy will be used by all our employees to ensure that every complaint will be dealt with the necessary professionalism that ADM Focus (Pty) Ltd (herein after referred to as “ADMF”) expects from them.

Purpose of this policy is to:

• Ensure fair outcomes to customers;
• Protect and enhance ADMF’s reputation,
• Allow for effective reporting, detailed analysis and identification of trends related to complaints;
• Achieve effective and timely resolution of complaints in respect of acceptable turn-around times;
• Provide guidelines for acknowledging complaints and for recording customer complaints in a centralised
• Improve organisational effectiveness through learning from client feedback and root cause analysis;
• Ensure effective management of complaints, in line with this policy;
• Restore and enhance relationships with complainants and non-complainants for the purpose of on-going business retention and growth;

The importance of a complaints resolution policy is part of service excellence:

Not only does ADMF aim to comply with legislation, it also values the delivery of service excellence in the way which complaints are handled.

DEFINITIONS:

In this policy, the definitions below are as follow: –

Arbitration process by which the parties to a dispute submit their differences to the judgment of an impartial person or group appointed by mutual consent or statutory provision.

Client means a specific person or group of persons, including the general public, who is or may become the subject to whom financial service is rendered intentionally, or is the successor in title of such person or the beneficiary of such service.

Complainant means a person who submits a complaint and includes a-

• policyholder or the policyholder’s successor in title;
• person that pays a premium in respect of a policy
• member of a group scheme; or
• potential policy holder or potential member of a group scheme whose dissatisfaction relates to the relevant application, approach, solicitation or advertising or marketing material, who has 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 above.

A complaint means any oral or written expression of dissatisfaction – whether justified or not – 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 policy holder 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 willful 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;

Complaints management means the management of the entire lifecycle of the complaint. This starts with the ease of process for the client to lodge complaints and the associated communication. It includes the way complaints are handled, recorded, resolved and quality controlled, the way people involved in complaints management processes are managed and trained; the way decisions are made; the way clients’ trust is restored; the way the reports are compiled and analysed; and ultimately the way business learns from the feedback gleaned from complaints and takes corrective and proactive action accordingly.

Complaints management head means the individual appointed by the managing director to serve as head of the complaints management function with ADMF. The role of the complaints management head and the terms of their appointment as amended is determined by the managing director.

Complaints management system (Kissflow) means the set electronic applications and related case management software used by ADMF for recording, classifying, routing, escalating and resolving individual complaints received by the business. In relation to the complaints management function as a whole, the system is used by the business to monitor, analyse and report on the ADMF performance in relation to complaints management.

Complaints handling means the process of attending to and resolving complaints including ongoing interaction with complainants. It is expected that this process meet certain minimum standards.

Primary purpose of the complaints handling committee is to:

• fairly and objectively consider the circumstances of any complaint brought before it, based on the respective submissions of all parties to the complaint, and to frame a response to that complaint, having regard to the legal merits of the complaint, general practice within ADMF or the industry, the commercial interest of ADMF and fairness in all the circumstances;
• where action is deemed appropriate to resolve an issue raised in a complaint, ensure that the required action is taken in a timely manner;
• monitor the efficiency and effectiveness of complaint handling within ADMF and
• provide a forum for the discussion

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 loss concerned, but excludes any –

• goodwill payment
• payment contractually due to the complainant in terms of the policy; or
• refund of an amount paid on behalf of the complainant to the insurer where such payment was not contractually due;

and includes any interest on late payment of any amount referred to above.

Executive Committee or board of an organization is a committee within the organization which has the authority to make decisions and ensures that these decisions are carried out.

Enquiry an enquiry could be a late claims payment, a query on an amount paid, non-receipt of premium etc. Simple queries do not necessarily constitute in a complaint.

Evidence means the information ADMF has obtained in order to review, adjudicate and resolve a complaint and shall include all information submitted by an entity as well as from the complainant and shall be stored and recorded on the complaints management system or other repositories for storing and recording information.

FAIS complaint means a specific complaint, submitted by a complainant to the FAIS Ombudsman or ADMF or its representatives to the complainant on or after the date of commencement of the FAIS act, and in which it is alleged that ADMF representative:

• has contravened or failed to comply with the FAIS Act and that as a result thereof the complainant has suffered or is likely to suffer financial prejudice or damage;
• has wilfully or negligently rendered a financial service to the complainant which has caused prejudice or damage to the complainant or which is likely to result in such prejudice or damage; or
• has treated the complainant

FAIS Ombud complainant means a client who submits a complaint directly to the FAIS Ombudsman’s

office in relation to the application of a policy and includes advice rendered.

Goodwill 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, as an expression of goodwill aimed a t resolving a complaint, where the insurer does not accept liability for any financial loss to the complainant as a result of the matter complaint about;

Implications mean something that is suggested.

Insurer means the company providing insurance.

Legal privilege means the right to refuse to divulge information obtained in a confidential relationship.

OSTI refers to the Ombudsman for Short Term Insurance.

OSTI complaint means for the purpose of this policy a complaint submitted to the Ombudsman for Short Term Insurance (“OSTI”) in relation to any other matter than the application of a policy relating to advice rendered.

Policyholder query means a request to the insurer or the insurer’s service provider by or on behalf of the policyholder, for information regarding the insurer’s policies, services or related processes, or to carry out a transaction or action in relation to any such policy or service;

Policyholder means a person who holds an insurance policy, usually the client in whose name the insurance policy is written.

Quantum means an amount of money legally payable (towards the settlement) in damages.

Rejected in relation to a complaint 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 any further action to resolve the complaint and included complaints regarded by the insurer as unjustified or invalid, or where the complainant does not accept or respond to the insurer’s proposals to resolve the complaint;

Reportable complaint means any other 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 the complaint is received; or
• submitted to or brought to the attention of the insurer in such a manner that the insurer does not have reasonable opportunity to record such details of the complaint as may be prescribed in relation to reportable complaints;

Reports (or reporting) means any periodic or ad-hoc reports (and related documents) obtained from the complaints management system and other resources in the business which shall be used for analysis, monitoring, submissions to regulatory authorities, and by the making of recommendations to the business.

Resolution means a course of actions or solution determined or decided on.

Transparent means candid, frank, open.

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 complaint has so been 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

COMPLAINTS POLICY:

ADMF has an internal complaints resolution based on the following: –

• We are transparent by ensuring that our policyholders have full knowledge of the procedures to resolve complaints whilst staying updated on progress.
• We promise fairness at all times when dealing with the
• We provide the necessary training to the relevant staff on how to handle complaints, including knowledge of the provisions of the legislation in respect of the resolution of

RESPONSIBILITIES RELATING TO THE COMPLAINTS PROCEDURE:

Both policy holders and ADMF have responsibilities as set out below: –

Policyholder responsibilities:

• Inform us of your complaint as soon as is reasonable
• You may contact us telephonically since all conversations are recorded or in
• Provide us with all information relating to your complaint to enable us to assist you
• Please note that if your complaint is FAIS related, the complaint MUST be in writing. Kindly refer to the requirements in respect of complaints as per the Financial Advisory & Intermediary Services Act.

ADMF responsibilities:

• The person dealing with your complaint will acknowledge receipt within 24 hours and may request further information, if
• Keep records relating to such complaints for a minimum of five years from when the complaint
• Unless we require information, assessment or investigation, we will agree with you in a reasonable timeframe. However we will attempt to resolve the complaint within 7 working days, failing which we will provide feedback at least every 10 working

INTERNAL DISPUTE RESOLUTION PROCESS:

Complaints relating to a rejected claim

If your complaint relates to a rejected claim we will:

• Provide reasons for the decision in
• Inform you of the external complaints procedure
• The time limit for taking legal action and the implication,
• On request, provide the policyholder with copies of all available documents and information that influenced the decision and that are not subject to legal
• Should you still object to the decision you will need to inform us, in writing, as soon as reasonably
• Should we thereafter still stand by our initial decision, we will follow the procedure to provide reasons for the decision in writing again.

If the policyholder and the person handling the complaint cannot reach agreement, the matter will be escalated further. Guidelines for the dispute resolution are set out below.

Non-rejection complaints and reviewing of complaints

If your complaint relates to any other matter (except for rejected claims) or should you wish to have a decision regarding your complaint reviewed, we will treat it as a dispute and:

• You will be advised of your right to request an internal dispute resolution
• The person dealing with your complaint will acknowledge receipt as soon as reasonable possible and provide you with contact details. They may ask additional questions if
• Our internal dispute resolution process will be the same as the complaints resolution
• When we have made a decision relating to a complaint, we will respond to you in writing to confirm:
  • Reasons for the
  • Facts on which the decision was
  • Should you not be satisfied with the resolution, we will inform you that you have the right to refer your dispute externally to the OSTI (Ombudsman for Short-term Insurance) or the FAIS Ombudsman as well as the timeframes for lodging the

COMPLAINTS HANDLING PROCESS:

Department

• Complaints lodged with a specific department or services are handled by an agent or manager of the respective

Cases for department or business unit

• Service complaints lodged from email addresses: zan@adminfocus.co.za
• Complaints from com and relevant social media e.g. Facebook etc
• Incoming calls from reception / switchboard
• Claims
• Compliance
• Value Added Products
• Assigned to applicable person to handle and investigate
• Written (formal) response required confirming outcome of matter

Arbitration

• Client is not satisfied with the response as per first two points and result in a complaint escalation to the internal arbitrator
• Adjudication takes place with a formal written response confirming a determination

Ombudsman / Regulator

• Client is not satisfied with the internal arbitrator’s decision and escalates the matter

Recording Complaints

• Regardless of where the complaint is received from, all reportable complaints must be recorded on the complaints management system and assigned appropriately
• All written and oral interaction in connection with a complaint must be recorded in the complaints management system
• One central control point means that all complaints are located in one centralized place and can be extracted easily
• The end conclusion, or determination (the “finding” or “outcome”) must be confirmed on the complaints management system
• NB: All complaints responses (written) must reflect the complaint number as issued by the complaints management system

COMPLAINTS PROCEDURE PER TYPE:

Complaints are ranked as described under the “general complaints hierarchy” with type 1 being an initial enquiry or relatively easy complaint to a type 4 complaint being an ombudsman (or regulator) complaint. The “type” will dictate the complexity of a complaint or seriousness and therefore a type 4 complaint will be the most problematic or complicated.

TYPE 1 – PROCEDURE

Complaint

• Client writes (via email or letter) or calls into ADMF complaining
  • Complaint is logged onto the complaints management system and assigned to the relevant business unit for resolution
  • Complaint reference number is allocated to the case handler
  • Complaint is acknowledged by the case handler within 24 hours and thereafter resolved or investigated further by the case handler
  • A response is send where necessary

A phone call or reply email (less formal) may be all that is required to resolve this type of matter

• The complaints management system is updated with the final outcome
• Complaint is resolved or closed on the complaints management system

Note: if the matter is merely an enquiry, then this will also be dealt with telephonically or on e- mail but not captured onto the complaints management system.

TYPE 2 – PROCEDURE

Complaints Arbitration

• Client writes to the Complaints Arbitrator regarding a previous claim or service experience encountered and is still not happy with the outcome
• All such complaints received are logged onto the complaints management system and assigned a reference number after which the complaint is assigned to the respective business unit representative for feedback or comment
• Simultaneously, a receipt of complaint confirmation is emailed to the complainant (within 24 hours)
• The respective business unit has 7 working days in which to respond
• Responses that may require additional days in order to respond will need to be communicated back to the complainant
• Once feedback is received by the respective business unit representative, a response then drafted by the Complaints Arbitrator and issued to the complainant, reasons for the decision and escalation or reference to alternative dispute resolution mechanism must be provided
• The complaints management system is updated accordingly with the outcome and thereafter resolved / closed

TYPE 3 – PROCEDURE

Internal Arbitrator

• Any comebacks from the complaints arbitration process is then referred to the internal arbitrator
• The internal arbitrator should never be the first point of the first reference. Should this, for whatever reason be the case, then the matter will be referred per the appropriate chain above
• The complaint will be loaded onto the complaints management system and referred to internal arbitrator via email
• Receipt of the complaint is acknowledged via email which is done within 24 hours
• The internal arbitrator may respond directly to a client and in the event that this is done, the complaints management system will be updated and resolved as a Type 3 matter
• In the event that the complaints handling committee need to meet to discuss the matter, owing to its complexity, the complainant is informed, a meeting will be set up, and minutes will be taken
• The committee will come to a conclusion and the response is thereafter drafted by the internal arbitrator for resolution
• Come-back from the various Ombud scheme’s may also be escalated to the internal arbitrator for review and a response
• The internal arbitrator shall have the highest authority in making a determination and has the authority to override any previous decision

TYPE 4 – PROCEDURE

Ombudsman / Regulator complaints (OSTI)

• This should be the last option available to the complainant
• By this time, we should have complete history of the client’s complaint where calls and anyprevious correspondence are readily available
• When a case is received from the Ombudsman / Regulator, it will be recorded onto the complaints management system and assigned to the relevant business unit
• Within 7 days a response must be send out
• The following are applicable for the OSTI and resolution of these complaints-
• Recommendation: The case is then settled if the company agrees with the proposed recommendation
• Should the company disagree with the recommendation a provisional ruling will then be made, this will then be escalated to a final ruling

Details at the end of letters

• Repudiation letters must specify the details of the respective Ombud scheme
• Any response from the Complaints Arbitrator must confirm the details of the internal arbitrator
• Any response from the internal arbitrator must confirm the details of the respective Ombud scheme (Short-term and FAIS)
• Any third party response must detail the internal escalation process for the third party

SUMMARY:

• Refer client to respective business unit first; if previously done the complainant must abide
• If a client wants to lodge a new / fresh complaint, this must be logged to and allocated to the correct complaint handler
• Full complaints process / hierarchy is accessible on our website adminfocus.co.za
• Should a complaint reside within more than one area, both areas will work the complaint simultaneously and compile one response
• Any complaint received must be identified per the Type (1-4)
• Any history on the complaints management system must be accessible
• Each business unit must be given first chance to resolve the matter
• Any comeback must be escalated as per the stipulated hierarchy
• Delays in responding will not be tolerated
• Timely execution of all investigations is expected
• Detailed and clear responses to every complainant is expected
• Objectivity is to be demonstrated and decisions are to be made on fact
• Fairness principles and Treating Customers Fairly to be applies at all times
• Due dates are to be adhered to all times
• Feedback to be provided to complainant during the investigative process
• If additional time is required to conclude investigation, the complainant must be informed
• For Type 2-4 complaints, a formal response should be drafted
• All responses, information, calls etc. must be captured/loaded onto the complaints management system
• Reporting of complaints is vital and will aid root cause analysis and submission of data to Regulators
• Where gaps in processes are identified, this must be brought to the attention of respective administrator by way of a feedback report.
• Issues raised by a complainant must be considered and taken into account when a response being

TURN AROUND TIMES:

Complaints logging –

• All complaints received by the divisions must be logged within 24 hours of receipt i.e. underwriting@adminfocus.co.za;

complaints@adminfocus.co.za; compliance@adminfocus.co.za claimsrejection@adminfocus.co.za finance@adminfocus.co.za

Hello Peter and relevant social media e.g. Facebook Acknowledging complaints –

• All complaints logged must be acknowledged in writing or telephonically within 24 hours of being logged

Investigating complaints –

• During the investigation phase of the complaint all correspondence or evidence received must be attached in the complaints management system. This will ensure that all documents or correspondence received or sent remains on the system for future reference

Resolving / Closing complaints –

• The current TAT on resolutions is 7 working days to resolve complaint
• Should we be unable to resolve clients complaint within the 7 working day TAT we will communicate with a 10 day holding letter to the client informing him/her on the reason for delay
• Should we not resolve the clients complaint within four weeks, there is also a four week holding letter in which we must explain the reason for the delay experienced
• Once a complaints is resolved we must communicate resolution in writing or telephonically to the client and then resolve / close the

Hello Peter / Facebook –

• Hello Peter and Facebook complaints will be dealt with by the complaints manager, who is responsible for logging the complaints on the complaints management system as well as liaising with the division involved to respond within 24 hours. Responses will be posted by the complaints manager as provided by the division

REGULATORY COMPLAINTS:

• All complaints lodged with the Ombudsman of Short Term Insurance or the FAIS Ombud and all legal proceedings in respect of the Insurer, the Policies and/or the Insurance Business must be dealt with exclusively by
• The binder holder and intermediaries / registered FSP must give all assistance and co- operation to Guardrisk in respect of any of the above and promptly furnish all documents / information and give all representations required in order to enable Guardrisk to defend any such legal proceedings, claims, potential claims, complaints or potential
• The binder holder and intermediaries / registered FSP, must at its costs, within 24 hours of receipt of complaint, a notification form the Ombud for Short Term Insurance or the FAIS Ombud; or any other legal document pertaining to Guardrisk, the Insurance Business and / or the Policies, provide a copy of such documents and any other supporting documents to

THE DETAILS ARE AS FOLLOWS:

Non-Life Ombud Complaints:                              ombudsman@guardrisk.co.za info@osti.co.za

Non-Life FAIS Complaints:                                  compliance@guardrisk.co.za info@faisombud.co.za

For any queries, feel free to contact us on zan@adminfocus.co.za