Executive officers responsible for the handling of complaints:
Vincent VALENTIN, Chief Executive Officer
Alternate executive: Geoffroy GUISSARD, Executive Account Manager & Compliance Officer
Process objectives and expected results
Achieve compliance with CAA Memorandum no. 19/03 of 26 February 2019 on out-of-court dispute resolution.
Detailed description of Media Assurances S.A.’s customer complaint handling process
Relationships with our customer base must be handled in a suitable, transparent and objective way when our customers lodge complaints.
Our duty to provide an appropriate response is not only due to our fundamental ethics but also forms a key component of our brand’s image in the insurance broker sector.
Customer complaints can be symptoms indicative of system failures both for the Media Assurances S.A. management team and the CAA (Commissariat aux Assurances).
Media Assurances S.A. is aware of the brand image it displays and therefore implements and maintains an efficient, transparent process for quickly and reasonably handling complaints lodged by our customers.
Information about this process is provided free of charge to customers.
1. Receiving a complaint lodged with Media Assurances S.A.
1.1 Written complaint When a letter from a complainant is received, the original is stored in an ad hoc file after:
- a copy has been sent to the person responsible for handling that complaint
- a copy has been sent to the executive officer responsible for the handling of complaints
- a copy has been scanned into the customer’s virtual file
- and the complaint has been recorded on the centralised electronic register (‘Réclamations Clients’ - customer complaints)
1.2 Verbal complaint If it is of a serious nature, a verbal complaint from a customer or third party is summarised and put in writing. The written summary is then handled as a written complaint.
2. Processing a complaint
A written confirmation of receipt is provided to the complainant within a maximum of ten (10) working days from the date the complaint is received, unless a response is provided to the complainant within that time frame.
The complainant is given the name and contact details of the person in charge of their file, in order to ensure transparency regarding the handling of their complaint.
An executive officer within the company’s internal hierarchy is appointed to be in charge of complaints from the customer base (responses to complainants will be issued under that officer’s authority and responsibility).
The executive officer responsible for the handling of complaints contacts the department concerned by the customer’s complaint in order to obtain the necessary information. Guided by a focus on objectivity and a search for the truth, the executive officer delivers an opinion and, where appropriate, proposes an amicable solution to the customer. Media Assurances S.A. will under no circumstances seek to conceal or cover up any fault on its part or on the part of its employees. The positive or negative response given to the customer must state the reasons behind it.
When it is firm and final, the response is sent to the customer after a copy has been placed in the customer file and the complaints register.
All complaints are handled in a diligent manner.
Media Assurances S.A. will:
- gather and investigate all evidence and relevant information collected about each complaint
- express itself in simple, easily understandable language
- provide a response without undue delay and send that response to the complainant within a maximum of one (1) month from the date of receiving the complaint. If a response cannot be provided within that time frame, Media Assurances S.A. will inform the complainant of the reason for the delay and will state the date on which it expects its investigation to be completed.
When the complaint’s handling by the executive officer has not resulted in a response that is satisfactory to the complainant, Media Assurances S.A. will supply a full explanation of its position on the subject of the complaint and will inform the complainant in writing of the CAA’s (Commissariat aux Assurances) out-of-court dispute resolution process. In that situation, Media Assurances S.A. will send a copy of the CAA Memorandum 19/03 or link to the CAA website, as well as information about the various ways to contact the CAA to lodge a complaint.
If a complaint is lodged fraudulently, Media Assurances S.A. will terminate the relationship in an orderly, definitive manner, as it is no longer based on trust.
Tracking complaints
The executive officer responsible for the handling of complaints will:
- ensure that each complaint, and the measure(s) taken to handle that complaint, are recorded in an appropriate manner (secure digital records)
- consult the customer complaint file and check that this procedure has been followed
The executive officer will also propose to the Coordinating Committee any necessary improvements to the internal processes and procedures to ensure the error that lead to the complaints does not reoccur.
The executive officer responsible for the handling of complaints will continually analyse the data on complaint handling in order to identify and handle any recurring or systemic issues as well as any potential operational or legal risks:
- by analysing the individual complaint causes in order to identify any shared root causes of certain complaint types
- by investigating whether those root causes could also affect other processes or products, including those not directly affected by the complaints
- and by correcting those root causes, when feasible
The executive officer responsible for the handling of complaints will immediately notify the Media Assurances S.A. Coordinating Committee if the complaint has resulted from a serious shortcoming that must be remedied quickly.
The complaint file is also available for the internal auditor to view.
Communicating information to CAA
The executive officer responsible for the handling of complaints will send the CAA a table with the number of complaints recorded by the company, categorised by type of complaint, along with a summary report of complaints and measures taken to handle them (Article 15 of the CAA Regulations no. 19/03 of 26 February 2019). These must be sent on an annual basis.
Complaints lodged with CAA
“The CAA is authorised to receive complaints from the customers of those persons subject to its supervision and to work with those customers to find an amicable solution to their complaint.”The CAA’s role is to find an amicable solution to the complaints it receives. It does not act as a judge or mediator issuing a mandatory sentence, nor as an ombudsman who, by definition, is a person tasked with defending the rights of citizens against public authorities.
Article 15 of the CAA Regulations no. 19/03 of 26 February 2019 on out-of-court dispute resolution states that the executive officer responsible must send the CAA a table with the number of complaints recorded by the company, categorised by type of complaint, along with a summary report of complaints and measures taken to handle them. These must be sent on an annual basis.
When the CAA receives a complaint from a Media Assurances S.A. customer, it will first ask the customer to exhaust all possible avenues with the aforementioned company. If this has been done, the CAA will ask Media Assurances S.A. to state its position.
The executive officer responsible for the handling of complaints will supply the CAA with the required information under the supervision of the accountable manager. In general, Media Assurances S.A. must ensure its response and cooperation are as comprehensive as possible. The CAA may also organise a meeting with the parties if it deems that to be necessary.
Lastly, the CAA will issue its opinion, with explanations, and send it to both parties. However, if one of the parties starts legal proceedings, the CAA will cease its involvement.
References: CAA Regulations no. 19/03 of 26 February 2019 on out-of-court dispute resolution
Drawn up in Luxembourg on 13 November 2019
