Investec Life

Complaints Policy

Investec Life Limited is a member of the Investec Group. It is a registered Long-Term Insurer and an authorised Financial Service Provider (No. 47702).

The aim of this policy is to give clear and concise rules when receiving complaints and the successful resolution thereof in terms of the Policyholder Protection Rules ensuring the fair treatment of all Policyholders and Beneficiaries.

Investec Life’s complaint processes and procedures are transparent, visible and accessible. The process to lodge a complaint is communicated to our clients in their policy documents and is available on our website www.investec.co.za/life.

A Complaints Officer has been appointed by Investec Life. The Complaints Officer is responsible for the approval and implementation of this policy.

Investec Life strives to provide fair service to its client and avoid complaints. Where a complaint arises, Investec Life views such complaints as an opportunity to engage with our clients, repair relationships and improve our process and service to clients.

Clients will not be charged for lodging complaints with Investec Life.

2. Definitions

“complainant”

means a person who submits a complaint and includes a:

(a) policyholder or policyholder’s successor in title’

(b) beneficiary of the beneficiary’s successor in title, or

(c) person whose life is insured under a policy;

(d) person that pays a premium in respect of a policy;

(e) member ; or

(f) potential policyholder 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 (a), to (f)

[1] “member” means a member of a fund or a member of a
group scheme;
“complaint”

means an expression of dissatisfaction 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 policyholder query, that:

(a) 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

(b) the insurer or its service provider’s maladministration or wilful or negligent action or failure to act, has caused the person harm, prejudice, distress or substantial inconvenience; or

(c) the insurer or its service provider has treated the person unfairly;
“compensation payment”

means a payment by 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 the loss concerned, but excludes any:

(a) goodwill payment;

(b) payment contractually due to the complainant in terms of a policy; or

(c) refund of an amount paid by or 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 in (b) or (c);
“goodwill payment”

means a payment by an insurer to a complainant as an expression of goodwill aimed at resolving a complaint, where the insurer does not accept liability for any financial loss to the complainant as a result of the matter complained about;
“policyholder query”

means a request to the insurer or the insurer’s service provider by or on behalf of a 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;
“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 includes 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 complaint other than a complaint that has been:

(a) upheld immediately by the person who initially received the complaint;

(b) 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 to complete from the date the complaint is received; or

(c) submitted to or brought to the attention of the insurer in such a manner that the insurer does not have a reasonable opportunity to record such details of the complaint as may be prescribed in relation to reportable complaints; and
“upheld”

means that a complaint has been finalised in that:

(a) the complainant has explicitly accepted that the matter is fully resolved; or

(b) it is reasonable for the insurer to assume that the complainant has so accepted; and

(c) all undertakings made by the insurer to resolve the complaint have been met

3. Commitment

Investec Life values the support of our clients and place strong emphasis on maintaining a long-term relationship that is open, transparent and based on trust. In view of this, we have established an internal complaints’ resolution procedure for the handling of complaints, and we encourage clients to provide us with feedback.

4. Record keeping monitoring, and analysis of complaints

The Complaints Officer will keep a register and record of all complaints.

The register will record at least the following information on the complaint:

Details of the complaint;
Categorisation of the complaint;
Progress made;
Escalation and appeal of the complaint;
Responsible person to deal with the complaint;
Escalation to the Long-Term Insurance or FAIS ombudsman;
Outcome (including compensation, where applicable);
Date when a complaint has been resolved; and
Whether the complaint is a reportable complaint in terms of legislation.

The record held will have all the relevant information of the complaint including all documentation related to the complaint

This information will be analysed to improve customer experience and to report to management and the relevant regulators.

5. Categorisation of complaints

Complaints will be categorised accordance with Treating Customers Fairly outcomes and will at least include the following:

design of a policy or service (TCF outcome 2);
information provided to policyholders (TCF outcome 3);
advice (TCF outcome 4);
policy performance (TCF outcome 5);
service to policyholders (TCF outcome 5);
policy accessibility, changes or switches (TCF outcome 6);
complaints handling (TCF outcome 6);
insurance risk claims, including non-payment of claims (TCF outcome 6);
other complaints.

6. Communication with complainant

Investec Life provides policyholders with multiple ways to submit complaints, as follows:

logging a complaint with the Complaints Officer or call centre on (011 291 3934);
sending an email to the complaint mailbox at Lifecomplaints@investec.co.za;
logging a complaint with an adviser; or
third parties .

If logged through the first, third and fourth options, the call centre or adviser is required to notify the Complaints Officer immediately via the complaints email.

Further, if a complaint is logged via call centre or adviser, Investec Life may request the client to submit the complaint in writing.

All communications with a complainant will be in plain and simple language.

²Third parties mean intermediaries and service providers;

The complainant is requested to provide the following information when lodging a complaint to enable Investec Life to assist with the complaint and reduce turnaround time:

Name, surname and contact details;
A complete description of the complaint;
The name of the person who provided the financial service, if relevant;
The date on which the event occurred;
All documentation relating to the complaint; and
Method of preferred communication.

Process followed upon receiving the complaint

- Acknowledge of the complaint within 2 business days which will include the following:

Informing the client of the process including escalation process;
Any additional information required;
The person dealing with the complaint; and
The expected timelines.

- During the investigation

The claimant will regularly be informed of the complaints progress; and
Any additional information required.

- Outcome of the investigation

The claimant will be informed of the determination within 2 business days after a determination is made;
Reasons for the decline, if applicable;
Options to appeal the outcome internally or to take the complaint to the relevant ombudsman; and
The payment process, if relevant.

7. Escalation

Where a client wishes to escalate a complaint, such a complaint will be assigned to the relevant manager for resolution. An escalation of a complaint relates to complaints about the complaints process.

8. Appeal

Client can internally appeal a determination decision made. The appeal will be heard by the Complaint Appeal committee. The committee is constituted by representation from the complaints and compliance areas, management and other key persons.

9. Engagement with the ombud

Any complaint received from the ombudsman will be treated with the same respect and care as any other complaint.

Clients may refer a complaint at any time to the relevant Ombudsman.

The client may also refer a complaint not resolved to their satisfaction to the Ombudsman for the Long-term Insurance. The details are as follows:

National Financial Ombud Scheme

National Financial Ombud Scheme

Physical Address: Claremont Central Building, 6th Floor, 6 Vineyard Road, Claremont, 7708

Telephone: 0860800900

Email: info@nfosa.co.za

Website; www.nfosa.co.za

If a complaint is related to financial advice, the matter to the Financial Advisory and Intermediary Services (FAIS) Ombudsman within 6 months of receiving a final response from Investec Life. The details are as follows:

Financial Advisory and Intermediary Services (FAIS) Ombudsman

Postal address:	PO Box 74751, Lynnwood Ridge, 0040
Residential address:	473 Lynnwood Road, Cnr Lynnwood Road and Sussex Avenue, Lynnwood, Pretoria
Email:	info@faisombud.co.za
Telephone:	012 470 9080 / 0860 324 766
Fax:	012 348 3447