COMPLAINTS POLICY

1. Introduction

1.1 Purpose
This Complaints Policy outlines the framework for handling complaints, ensuring fair treatment of customers in line with regulatory requirements within Seven Insurance Brokers L.L.C (“the Company”). The policy is designed to identify and address issues affecting customer satisfaction and service quality while documenting and analyzing complaints to drive continuous improvement. At Seven Insurance Brokers, we are committed to treating our customers fairly and ensuring that any dissatisfaction is addressed promptly, efficiently, and in compliance with regulatory requirements, including those set forth by the Central Bank of the UAE.
1.2. Scope
1.2.1 Applicability to All Employees, Representatives, and Third-Party Service
Providers:
The policy applies to all employees of the Company, regardless of their role or level within the organisation. This includes customer service representatives, sales agents, and senior management.
The policy also extends to representatives acting on behalf of the brokers, such as agents or intermediaries who interact with customers.
Third-party service providers who perform services related to the brokers’ operations are also covered by this policy. This ensures that any complaints arising from services provided by third parties are handled consistently and in line with the Company’s standards.
1.2.2 Coverage of All Services Provided
The policy covers complaints related to all services offered by the Company. This includes, but is not limited to:
• Policy Sales: Complaints related to the sale of insurance policies, such as misrepresentation of policy terms, incorrect pricing, or failure to disclose important information.
• Policy Servicing: Complaints about the ongoing management of insurance policies, such as billing issues, changes to policy terms, or errors in policy documentation.
• Other Services: This policy also covers any additional services provided by brokers, such as advisory services, risk management, or customer support.
1.2.3 Geographical and Regulatory Scope
The policy is designed to comply with the regulatory requirements of UAE, including those set forth by the Central Bank of the UAE. This means that the policy applies to all operations of the Company.
The policy also aligns with international best practices in complaint handling, ensuring that customers receive a high standard of service regardless of their location.
1.2.4 Inclusivity of All Customer Types
The policy applies to all customers, including:
• Individual Customers: Personal insurance policyholders, such as those with health, motor, or home insurance.
• Corporate Customers: Businesses that have taken out insurance policies, such as commercial property or liability insurance.
• Potential Customers: Individuals or businesses who have interacted with the Company, with the intention of purchasing a policy, but have not yet purchased a policy.

2. Definition of a Complaint

A complaint is any oral or written expression of dissatisfaction from a customer or potential customer regarding the services provided or failed to provide, alleging that they have suffered (or may suffer) financial loss, material distress, or material inconvenience.
Complaints are a valuable source of intelligence, allowing the Company to identify trends or issues through root cause analysis. Effective Complaint handling enables the Company to continuously improve the products and services for the benefit of Clients and to remain competitive.
This policy also covers complaints where the customer alleges that they have suffered (or may suffer) financial loss, material distress, or material inconvenience due to the services provided by the brokers.

3. Types of Complaints Covered

The policy applies to any oral or written expression of dissatisfaction from a customer or potential customer. This means that complaints can be made in various forms, including:
• Verbal Complaints: Made in person or over the phone.
• Written Complaints: Submitted via email, postal mail, or through the online complaint form on the company’s website.

4. Complaint Handling Process

4.1 Lodging a Complaint
Customers may lodge complaints through the following channels:
• Email
• Telephone
• In person at any of our office locations
• Online via our website complaint form
• Postal mail
4.2 Complaint Recording & Acknowledgment
Upon receipt of a complaint, the Company shall immediately record it on the Complaint Log.
The client shall be contacted by the Compliance/Audit department of Seven Insurance Brokers confirming receipt and outlining the next steps.
The Company shall acknowledge all complaints in writing within 2 business days.
4.3 Investigation
i. The complaints will be assigned to the designated Complaints Officer.
ii. The Complaints Officer will conduct a thorough investigation, gathering relevant facts and speaking to involved parties.
iii. The Complainant shall be offered the opportunity to meet with one of the Directors and/or Senior Managers to discuss the nature and details of the complaint.
iv. The Complainant shall be allowed to submit any additional evidence to corroborate the complaint raised at/or after the meeting.
v. A record of the meeting and any additional information obtained shall be fully recorded as part of the complaint review.
vi. If the Complainant declines to meet with the Company’s representative, the Complainant’s decision shall be respected, and the file noted accordingly.
vii. The Company shall arrange to interview any company representative(s) referenced in the complaint.
viii. A senior manager shall conduct the interview, with a witness confirming the accuracy of the recorded notes. This record is to form part of the complaint review process.
ix. After the investigation is completed, the findings shall be reviewed by the Company’s Director(s)/ Senior Manager(s) in conjunction with the Compliance / Audit function to determine the complaint outcome. The outcome can be:
• Complaint fully upheld.
• Complaint partially upheld.
• Complaint not upheld.
4.4 Resolution
i. If the complaint is upheld in full or in part, the Broker will review and determine the necessary steps to rectify and remedy the complainant’s situation for any inconvenience and distress suffered.
ii. Where relevant, the proposed remedial action shall be discussed & agreed upon with any third party (i.e. insurance company). All documentation produced as evidence to support the complaint investigation shall be made available to the third party (if this does not constitute a breach of confidentiality of data protection); in which event, the Complainant’s specific consent shall be obtained).
iii. A final response to the Complainant will be issued within 30 calendar days in writing. If additional time is required, an interim response will be provided, explaining the delay.
iv. The Complainant’s agreement/disagreement with the proposed resolution is to be obtained in writing.
v. The Complainant will be informed of their right to escalate the matter if they are dissatisfied with the resolution.
vi. If the Complainant accepts the proposed remedy in writing, the Company shall take immediate action to fulfill the remedial action.
vii. If the Complainant rejects the proposed remedial action OR a complaint not upheld decision; the Company director(s)/Senior Manager(s), Compliance & Audit function to review the case and collect any new evidence or information if available.
viii. If the Complainant’s agreement is still not obtained, a Letter of Deadlock shall be issued, outlining the reasons supporting the decision.
4.5 Escalation Process
If the Complainant is not satisfied with the outcome of the investigation, he can appeal to:
• The Chief Executive Officer/The Compliance Officer of Seven Insurance Brokers.
• The UAE Central Bank per the CBUAE Insurance Brokers Regulations.
• An external regulatory body such as the Financial Ombudsman Service, if applicable.
4.6 Employee Sanction
Where a complaint has been received, at the Company’s discretion; the employee(s) involved is to be requested not to make direct contact with the client, pending completion of the complaint review, unless otherwise outlined in this policy.
After a decision is reached as per the Company’s complaint process, the Company Director(s) and/or Senior Manager(s) will review and determine any necessary remedial or corrective measures applicable to the employees involved.
Remedial Actions or Corrective Measures are to be considered and applied per the employee contract and any prevailing HR policies and procedures of the Company.
Remedial Actions or Corrective Measures to include (but are not restricted to): verbal warning, written warning with a fixed expiry date, written warning with unlimited expiry, 2nd written warning, final written warning, suspension pending further investigation, and immediate
dismissal.

5. Regulatory Compliance

This policy aligns with the relevant insurance regulatory guidelines and financial service laws applicable to the Company’s operations. Specifically, it adheres to:
• UAE Central Bank’s Insurance Brokers Regulations.
• Any amendments or additional regulations issued by the UAE Central Bank following its oversight of the insurance sector.

6. Record-Keeping and Reporting

i. All complaints upon receipt will be documented in the Complaint Log.
ii. The Company shall retain the records for a minimum of ten years.
iii. Periodic reports on complaints will be prepared for internal review and regulatory reporting per UAE Central Bank requirements.
iv. The Company shall, in its quarterly interim financial statements audited by an external auditor to be submitted to CBUAE, include a statement concerning the number and nature of complaints, the products involved, stated reasons for complaints, resolution rates, and/or where litigation arises from complaints.
v. All stages of the complaint review are to be documented on the client file and in the company’s complaint recording system (Annexure A) for review (and on the Employee personnel file where relevant).

7. Staff Training and Awareness

The Company shall give regular training to the employees on complaint-handling procedures.
Training will include best practices in customer service and regulatory compliance.

8. Continuous Improvement

The Company shall review the complaints regularly to identify trends and areas for improvement. Corrective actions will be promptly implemented to prevent the recurrence of systemic issues.
Compliance officers will periodically review complaints data to assess adherence to UAE regulatory standards.

9. Policy Review

This policy will be reviewed annually or as required due to regulatory updates or operational changes.

10. Contact Information for Complaints
Complaints Officer Name: Heinrich Teichert
Contact No: +971 (0) 4 436 1800
Email: Hein.t@seveninsurancebrokers.com
Mailing Address: Floor 49, Tower B, Business Central Towers, Internet City, Dubai, UAE.

11. Exclusions

While the policy is comprehensive, it may not cover complaints that fall outside the scope of the brokers’ services. For example:
• Complaints related to fraudulent activities that are being investigated by law enforcement.
• Complaints that are frivolous or vexatious, meaning they are made without serious purpose or value.
• Complaints that are outside the jurisdiction of the UAE regulatory authorities.
This Policy will be reviewed annually or more frequently if necessary. Updates or changes to the Policy will be communicated to all relevant personnel to ensure continued adherence guidelines.