Complaints An Overview for Staff Prepared by MSM Compliance Services Pty Ltd

Who Are MSM Compliance? MSM is a national professional services business focused on the general insurance industry. Your company has engaged MSM to assist in the management of its obligations as a holder of a Financial Services Licence. MSM helps to ensure that you and your company comply with your AFS Licence obligations with the least disruption to your core business.

Why are you reading this? To provide you with an introduction to our Complaints Policy and Procedures. It will present you with a synopsis, but not the detail. You should still take the time to read the full Complaints Policy & Procedures.

Why do we have a Complaints Policy & Procedures? IT IS THE LAW An Complaints system is a mandatory requirement for AFS Licensees who deal with Retail Clients. It is also a requirement of the Financial Ombudsmen Service and most Industry Codes of Practice and IT IS GOOD BUSINESS PRACTICE All customers have the right to have complaints handled fairly, promptly and effectively. If we do not or are seen to be not acting in this manner it can have a detrimental effect on our client base and therefore our income and profitability.

Why is it important to resolve complaints? 25% of customers are not totally satisfied with the service they receive. Only one in twenty five dissatisfied customers actually complain. This means there are 25 unhappy customers out there for each one that complains to us! An unhappy customer will tell 9 or 10 people about the incident! If a customer complains and their dispute is resolved quickly, 95% will do business with you again!

What is a Complaint? A complaint is any expression of dissatisfaction, whether oral or written, and whether justified or not, about a service or activity relating to Financial Services offered, provided or withheld by us. It applies to internal and external clients Our clients include agents, brokers, insurers and intermediaries that the we deal with.

Ask the Customer A simple way to determine if an issue is to be handled via our formal complaints process is to ask the customer- “Would you like us to treat this matter as a complaint?”

Who Is Responsible For Complaints? The Responsible Manager(s) is ultimately responsible for complaints handling. The Complaints Officer is responsible for the day to day management and monitoring of Complaints. All staff and Authorised Representatives must be familiar with and comply with this Policy and Procedure, understand its importance and are encouraged to look for ways to improve our procedures.

Who Is The Complaints Officer? The Complaints Officer and a designated replacement are indicated on our Organisation Chart by the Codes C1 and C2 under their names. Please spend a minute to identify who the Complaints Officer is.

Complaints Handling Principles Commitment – by all levels of staff Fairness – to both complainant and the business Adequate resources – to promptly handle and fix the complaint Visibility – actively promoted to all clients Coverage - Includes complaints about all our representatives. Access – available to all clients Information - Only ask/use information relevant to complaint. Assistance – all reasonable help & support will be provided Responsiveness – courteous & timely action Charges – no fees to the client for the service Data Collection – use of our Complaints Register Systemic Problems – fix the system that is causing complaints. External Dispute Facilities – membership of FOS

What Should You Do When You Receive A Complaint? Listen carefully to the client when taking the complaint. Confirm with the client the details you have taken. Empathise with the client and be courteous. Avoid laying blame or being defensive. Avoid creating false expectations. Encourage the client to provide full details of the complaint. Try to have client provide full complaint details in writing. Use our Complaints Form to record the complaint details where considered necessary. Advise client of when complaint will be resolved. Confirm agreed action to client in writing within 24 hour Advise Complaints Officer of receiving complaint..

Complaint Timelines Insurance Brokers Code of Practice Obligations Immediate or “As Soon As Practical” acknowledgement to client of receiving complaint. Explain to client how complaint is to be resolved within 21 days of receipt or later by agreement. If complaint is unresolved, client unhappy etc. Complaint becomes a dispute.

Dispute Timelines Insurance Brokers Code of Practice Obligations Refer matter to Complaints Officer to handle. Dispute to be resolved in 21 days or as agreed. Decision to be in writing. If dispute unresolved provide client with FOS details where applicable.

Avoiding Complaints It is always better to avoid the complaint in the first place. Ensure you clearly understand the client’s instructions. Document & confirm in writing instructions and commitments. Constantly raise Non-Disclosure or Misrepresentation as key issues. Tell the client what their policy covers (and what it does not). Don’t make promises or commitments we cannot keep. Honesty is the best policy. Don’t give false or overly optimistic expectations on claims outcomes. Ensure that all “bad news” decisions have been fully considered. Provide clear and unambiguous explanations for “bad news”. Present any options that may be available. Do not delay in giving the client bad news.

Review & Updates Our Complaints Policy & Procedures will be reviewed on an annual basis as part of our the Business Planning process. We also review the annual Financial Ombudsman Service (FOS) reports to identify emerging trends and causes of complaints and review our various Policies and Procedures accordingly. Any changes will be advised to you either via or at our regular Staff meetings.

In Summary You should Avoid complaints through good customer service. Handle complaints promptly. Identify our Complaints Officer.

Where To From Here? Please take the time to read our full Complaints Policy and Procedures and if you require further clarification discuss with our Complaints Officer.