COMPLAINTS PROCEDURE

1.Overview

This procedure is operated by CMutual in relation to its financial services provided under the Consumer Protection Code 2025.

 

2.Our Objectives

1. To respond to complaints in a courteous, timely and fair manner.

2. Take all reasonable steps to resolve any complaint with the consumer making the complaint.

3. To endeavour to address the specific issues raised by our customers and, where appropriate, update our procedures to avoid re-occurrence of problems.

4. To endeavour to achieve a situation where our customer feels we have addressed the complaint, but if he/she remains dissatisfied with the outcome of our efforts, to ensure that he/she is notified of the right to refer the matter to the Financial Services and Pensions Ombudsman (FSPO).

 

3.Who does this procedure apply to

This procedure applies to all directors and employees of CMutual who receive a complaint in relation to a regulated activity.

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4.Procedure

1. CMutual will establish and maintain a complaints file and all complaint records will be kept for six years.
    

2. Where we receive an oral complaint, we will offer the consumer the opportunity to have the complaint to have the complaint handled in accordance with the firms’ complaints process. We will investigate the complaint based on our understanding of the issue.

3. The firm shall permit and facilitate submission of complaints in writing by post and by electronic means.

4. The firm will implement and maintain systems and controls to effectively track and manage the progress and resolution of complaints.
    

5. We will acknowledge in writing each complaint within 5 business days of receipt.  This acknowledgement will contain a copy of these procedures and notification that the complainant can refer the matter to the Financial Services Ombudsman or the Pensions Ombudsman if he/she is not happy with the outcome of our investigation, or if the matter has not been resolved within 40 business days, the anticipated timeframe within which We hopes to resolve the complaint. Contact details of the Financial Services Ombudsman and Pensions Ombudsman will also be provided.

6. The firm shall provide the consumer making the complaint, or the person making the complaint on the consumer’s behalf, with a point or points of contact in relation to the complaint until the complaint is resolved or all steps of the firm’s complaints handling procedures have been exhausted.

7. We shall investigate the complaint as swiftly as possible and shall provide the consumer making the complaint or the person making the complaint on the consumer’s behalf, with a regular update, on paper or on another durable medium, on the progress of the investigation of the complaint at intervals no greater than 20 working days, starting from the date on which the complaint was received.

8. We will attempt to investigate and resolve the complaint within 40 business days of having received the complaint; where the 40 business days has elapsed and the complaint is not resolved, the complainant will be informed of the anticipated timeframe within which we intend to resolve the complaint and that the complainant can refer the matter to the relevant Ombudsman and the contact details of such Ombudsman will be provided.

9. Within 5 working days of the conclusion of our investigation of the complaint, we shall advise the consumer making the complaint on paper or on another durable medium of: (a) The decision at the conclusion of the investigation, including the reasons for that decision, (b) Where applicable, the terms of any offer or settlement being made to the consumer making the complaint, (c)  Where the consumer has a right to refer the matter to a relevant ombudsman, the fact that the consumer may refer the matter to the Financial Services and Pensions Ombudsman (FSPO), and (d) The contact details of the Financial Services and Pensions Ombudsman (FSPO).

10. Where it appears to CMutual that the complainant is not satisfied with the outcome of our investigation, and where we feel that we cannot progress the issue further, we will immediately write to the complainant advising them of their right to refer the dispute to Financial Services and Pensions Ombudsman.

11. A senior manager will review the file before its conclusion and attempt to identify any procedures that can be implemented to avoid a repeat of the type of complaint received.  Any new procedures will be immediately communicated to all staff and placed in the Written Procedures file.

12. With regard to Quality Assurance, all complaint investigations are conducted by the by the Head of Operations  and reviewed by the Head of Product where necessary prior to the issuance of responses. 

 

Complaints are reviewed by company management regularly and are reported to the Board. Should there be any emerging theme, the company would address potential product changes with the relevant underwriter in accordance with the prevailing Terms of Business Agreement. 

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5.Root cause corrective action

This section describes how CMutual assesses the root cause of complaints and feeds back any learnings relating to company processes, product design, or other matter.

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1 – Complaint received

A complaint may be registered by phone, email, via company website form, or in person. The complaint will be acknowledged by the complaint handler, logged on the complaint log, and noted in the CRM system. At the time of recording the complaint, the narrative may point to an underlying issue (policy coverage, claim part-payment, claim denial, service delay).

Each complaint will attract a prioritisation, depending on the issue severity, and at all times within the context of regulatory compliance requirements.

 

2 – Resolve complaint

This phase involves the gathering of relevant information (Policy document, policy coverage, claim limits, claim files). In the case of claims related issues, the complaint handler may conduct an interview with the claims assessor.

The complaint handler will update the complainant in a timely way with either a full, or interim update. The complaint handler will ensure responses are issued well within the compliance guidelines set by the FSPO.

 

3 – Root cause analysis – RCA

The company is keen to understand why complaints arise, and to learn from the issue so as to either improve company processes, or product as appropriate. Various Six-Sigma approaches may be employed, (Fishbone diagram, Pareto, the 5 Whys).

The company is data driven and will ensure cross-functional team involvement (product, Finance, Operations, Compliance). This approach helps drive organisational learning and accountability.

The output expected here is a succinct description of what has gone wrong, whether this is people, systems, or process related.

 

4 – Corrective action

The corrective action will typically include one of insurance product, or process change. Any such change will be supported by focused staff training and coaching.

The implementation of changes will be completed to an agreed plan, with clear responsibility, timelines and metrics reported. Where a recommended action has a compliance related impact, such impact will be assessed prior to implementation.

Changes to process will be advised to staff via team meetings with supporting documentation.

 

5 – Evaluate effectiveness

Complaint metrics will be reviewed to check for recurrence of the identified issue, completion of actions will be reported to the company executive at ExCo meetings.

The relevant department manager will feed results of the actions taken into staff training, company systems and processes. Should this evaluation identify any additional process or product weakness, these will be fed back to the top of the process creating a closed-loop-corrective action flow.

 

6.Contact

For further information in relation to these procedures, please refer to Head of Operations.