Introduction

As a business, ANIMOR® MEMBERSHIP SERVICES LIMITED is committed to ensuring that it has effective and transparent procedures for the reasonable and prompt handling of complaints. ANIMOR® MEMBERSHIP SERVICES LIMITED is also committed to ensuring that complaints are properly investigated and resolved appropriately. ANIMOR® MEMBERSHIP SERVICES LIMITED recognises that the proper handling of complaints will not only improve the customer’s experience but can contribute to the success of its business. Identifying complaints and understanding the underlying causes can also provide our business with valuable information to improve products and the service provided to customers.

This Procedure therefore documents ANIMOR® MEMBERSHIP SERVICES LIMITED' approach to handling complaints to ensure they are identified and handled in accordance with FCA’s rules.

The FCA Glossary defines a complaint as:

"any expression of dissatisfaction, whether oral or written, and whether justified or not, from or on behalf of an eligible complainant about that firm's provision of, or failure to provide, a financial service."

In simple terms, a complaint is where a customer or his or her representative contacts ANIMOR® MEMBERSHIP SERVICES LIMITED and is in some way unhappy with the service or insurance provided to that customer. A complaint may or may not include an allegation that the customer has suffered, or may suffer, financial loss, material distress or material inconvenience.

This Procedure is intended to ensure that ANIMOR® MEMBERSHIP SERVICES LIMITED meets its regulatory obligations. The main sources for complaints handling rules follow and should be referred to when questions arise as to how to ensure compliance with the applicable regulations:

• The FCA Handbook – DISP: https://www.handbook.fca.org.uk/handbook/DISP/.
• Financial Ombudsman Service guidance and previous decisions:
• Technical approach to insurance complaints: http://www.financial-ombudsman.org.uk/publications/technical.htm.
• Decisions database: http://www.ombudsman-decisions.org.uk/.

All staff are required to comply with this Policy and Procedures. Failure to do so could result in disciplinary action.

Eligible complainants

In short, and in accordance with DISP 2.7.3, an eligible complainant is one whose complaint involves an allegation of financial loss, material distress or material inconvenience and who is either:

• a consumer;
• a micro-enterprise which employs fewer than 10 employees and with a yearly turnover or annual balance sheet that does not exceed 2 million Euros;
• a small business which employs fewer than 50 employees and with a yearly turnover that does not exceed £6.5 million or annual balance sheet that does not exceed £5 million
• a charity with a yearly income under £6.5 million; or
• a trust with net assets under £5 million.

Whether a complainant is eligible or non-eligible will determine whether ANIMOR® MEMBERSHIP SERVICES LIMITED must handle the complaint in accordance with the FCA’s complaint handling rules and whether the complainant is entitled to refer their complaint to the Financial Ombudsman Service (FOS) in the event that they remain dissatisfied.

Non-eligible complainants

Whilst the FCA’s complaints handling requirements do not apply to complaints received from non-eligible complainants, as a matter of good practice and customer care, ANIMOR® MEMBERSHIP SERVICES LIMITED will, as far as possible, handle complaints from non-eligible complainants in the same manner as those from eligible complainants. However, complaints from non-eligible complainants cannot be escalated to the FOS. There may also be instances where it is either not possible or commercially viable to follow the same timescales for responding to and resolving complaints from eligible complainants (see below).

Filtering

Minor expressions of dissatisfaction should be handled informally and at team level, with the aim of resolving the issue as quickly as possible and without having to subject the customer to unnecessary escalation procedures. All such complaints should be recorded in the firm's Complaints Register.

Complaints which involve an allegation of financial loss, material distress or material inconvenience should be referred to the Complaints Manager (see 9 below) who will be responsible for ensuring that the complaint is recorded in the firm's Complaints Register and that the formal procedures set out below are followed.

Stages of Complaints Handling

The stages of the complaints handling process can be summarised as follows:

• establish if a complaint or enquiry has been received;

Once it has been confirmed that a complaint from an eligible complainant has been received;

• record details of the complaint;
• investigate the complaint;
• if possible, resolve the complaint informally by close of the third business day following receipt;
• issue a Summary Resolution Communication if resolved informally by close of the third business day (see 5 below).

If complaint is not resolved byclose of the third business day following receipt:

• acknowledge the complaint (normally within five working days of receipt);
• investigate the complaint;
• uphold or not uphold the complaint; and
• send a Final Response Letter to the complainant.

Where the complaint is not resolved within eight weeks from the date of receipt:

• send an eight week 'holding' letter.

Recording and Reporting

Whilst all complaints should be recorded in the Complaints Register (to provide management information), not all of them have to be reported to the FCA.

The FCA’s reporting requirements do not apply where:

• the customer is not an eligible complainant;
• the activity is not a regulated activity which is within the remit of the FOS;
• there is no allegation that the customer has suffered, or may suffer, financial loss, material distress or material inconvenience;
• where is has been established that handling the complaint is the responsibility of a third party, and the complainant has either been referred to that third party or the complaint has been referred accordingly.

It should be noted that complaints received on a Friday need not be resolved until close of business on Wednesday. Weekends and public holidays do not count.

Summary Resolution Communication

The complaint can only be considered as having been resolved informally if the complainant has indicted acceptance of the proposed resolution.

The SRC must:

• refer to the fact that the complainant has made a complaint and inform the complainant that ANIMOR® MEMBERSHIP SERVICES LIMITED considers the complaint to have been resolved;
• tell the complainant that if he/she subsequently decides that he/she is dissatisfied with the resolution of the complaint he/she may be able to refer the complaint to the FOS;
• includes the mandatory wordings regarding referral timescales and FOS:

• what you’re complaining about happened more than six years ago, and
• you’re complaining more than three years after you realised (or should have realised) that there was a problem.

If you do decide to refer your complaint to the Ombudsman you must do so within six months of the date of this letter.

If you do not refer your complaint to the Ombudsman within six months of the date of this letter, the Ombudsman will not have our permission to consider your complaint and so will only be able to do so in very limited circumstances.

The very limited circumstances referred to above include instances where the Ombudsman believes that the delay was as a result of exceptional circumstances."

Further details regarding the FOS can be obtained from their website at www.financial-ombudsman.org.uk. Alternatively, the FOS may be contacted at:

The Financial Ombudsman Service
Exchange Tower
London E14 9SR
Tel: 0800 023 4 567.

Acknowledging complaints

It is an FCA requirement that all reportable complaints are acknowledged in writing promptly. As a matter of good practice ANIMOR® MEMBERSHIP SERVICES LIMITED will ensure that acknowledgement letters are sent no later than five working days after receipt.

These must include:

• a first paragraph acknowledging receipt of the complaint;
• a paragraph outlining ANIMOR® MEMBERSHIP SERVICES LIMITED' understanding of the complaint; and
• details of who will be dealing with the complaint and why he or she is an appropriate person to do so.

Investigation

In order to appropriately investigate a complaint, all the information about the complaint should be gathered. Sufficient information may be held in existing records but, if not, the appropriate parties should be contacted to elicit the information needed to consider matters properly.

On receipt of the information needed, the complaint should be considered in an impartial way in the light of all the facts available. The complaint should not be investigated by anyone involved in the matter that is the subject of the complaint.

The consideration of all the facts and evidence available should lead to a conclusion as to whether the complaint should be upheld and, if so, whether redress is required in order to put the client back into the position that they would have been in if the act or omission that is the subject of the complaint had not occurred. Where it is decided that redress is appropriate, ANIMOR® MEMBERSHIP SERVICES LIMITED should aim to provide the complainant with fair compensation for any acts or omissions for which ANIMOR® MEMBERSHIP SERVICES LIMITED is responsible. It should be appreciated that appropriate redress will not always involve financial redress, as no monetary loss may have been suffered. It may, for example, simply involve an apology. Where financial redress is deemed appropriate, it should include a reasonable rate of interest that is in line with bank base rates. Consideration should be given to the possible need to obtain authority from a third party, such as the Underwriter or ANIMOR® MEMBERSHIP SERVICES LIMITED' professional indemnity insurers.

Final or other response within eight weeks

Within eight weeks of receiving the complaint, ANIMOR® MEMBERSHIP SERVICES LIMITED must send a complainant:

• a 'Final Response', being a written response from ANIMOR® MEMBERSHIP SERVICES LIMITED which:
1. accepts the complaint and, where appropriate, offers redress or remedial action; or
2. offers redress or remedial action without accepting the complaint, or
3. not uphold the complaint and gives reasons for doing so;
and which:
4. encloses a copy of the FOS standard explanatory leaflet; and
5. informs the complainant that if they remain dissatisfied with ANIMOR® MEMBERSHIP SERVICES LIMITED' response, they may now refer their complaint to the FOS and must do so within six months; or
• a written response which:
• explains why ANIMOR® MEMBERSHIP SERVICES LIMITED is not in a position to make a final response and indicates when it expects to be able to provide one;
• informs the complainant that they may now refer the complaint to the FOS and must do so within six months; and
• encloses a copy of the FOS standard explanatory leaflet.

Record keeping

In accordance with DISP 1.3.3B ANIMOR® MEMBERSHIP SERVICES LIMITED will ensure that processes are in place to:

1. compile management information on the causes of complaints and the products and services complaints relate to;
2. identify the root causes of complaints;
3. prioritise dealing with the root causes of complaints;
4. consider whether the root causes identified may affect other processes or products (DISP 1.3.3 R (2));
5. decide whether root causes discovered should be corrected and how this should be done;
6. regular report to the Board of Directors where information on recurring or systemic problems may be needed for them to play their part in identifying, measuring, managing and controlling risks of regulatory concern; and
7. keep records of analysis and decisions taken by Board of Directors in response to management information on the root causes of complaints.

Complaints Manager

The Complaints Manager is an ANIMOR® MEMBERSHIP SERVICES LIMITED, director. In the absence of the Complaints Manager, complaints issues which require escalation should referred to ANIMOR® GROUP LIMITED.

The Complaints Manager is responsible for ensuring that complaints are dealt with in accordance with all relevant regulatory rules and the terms of our binding authorities and that all decisions reached represent fair customer outcomes.

The Complaints Manager additionally reports to Underwriters on complaints which are received and handled on behalf of the insurer or which must be escalated to the insurer. The Complaints Manager is also responsible for overseeing the day-to-day compliance with this Policy and Procedure.

The Complaints Manager has the appropriate level of seniority within the business, is deemed to understand all relevant regulatory and contractual requirements and has the full support of the Board and senior management in carrying out their responsibilities. Specific authorities include:

• establishing, maintaining and monitoring ANIMOR® MEMBERSHIP SERVICES LIMITED' complaints procedures;
• ensuring complaints are identified and investigated fairly and promptly and that appropriate responses are provided to complainants;
• establishing, where appropriate, the correct level of redress (subject to the applicable authority limits granted by the Underwriters, where complaints are handled on their behalf);
• liaising with the Underwriters where necessary;
• establishing and maintaining training for staff;
• reporting to the Underwriters, senior management and the Board of Directors on all complaints matters;
• conducting periodic reviews of our compliance with relevant regulatory and contractual requirements and these procedures;
• ensuring that all complaints are recorded in the Complaints Register, which is available for inspection by the Underwriters.

Any member of staff who has queries or concerns regarding any complaints issue (such as whether an issue is a “complaint”) should contact the Complaints Manager immediately.