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Grievance Redressal Policy Kotak Mahindra Old Mutual Life Insurance Ltd. 9'h Floor, Godrej Coliseum, Behind Everard Nagar, Sion East, Mumbai 400022 Page 1 of 22

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Page 1: Life Insurance Ltd

Grievance Redressal Policy

Kotak Mahindra Old Mutual Life Insurance Ltd.

9'h Floor, Godrej Coliseum, Behind Everard Nagar, Sion East, Mumbai 400022

Page 1 of 22

Page 2: Life Insurance Ltd

1 POLICY STATEMENT ...........................................................................................................................................3

2 APPLICABILITY ...................................................................................................................................................... 3

3 CONTEXT ................................................................................................................................................................ 3

4 OBJECTIVES & BENEFITS ..................................................................................................................................4

5 BACKGROUND, PURPOSE & SCOPE ................................................................................................................4

6 DEFINITIONS .........................................................................................................................................................5

7 PROCESS ..................................................................................................................................................................7

7.1 CO\II'I. \IN'I RI:(:I(II'"1'R RI':GIs I'R \'I'ION ..................................................................................................................7

1.1 Receipt of (.omp/aiuts ......................................................................................................................................... 7

.1.2 R girlenlrg Complends ........................................................................................................................................ 7

7.2 COMPI..\IN'I'.\N.\IXSIS ............................................................................................................................................ 87.2./ (.ate'go,itiniion ................................................................................................................................................... 8

'.2.2 Priorititiution .................................................................................................................................................... 9

-.2.3 ss gniug IZeupon ihilil. ..................................................................................................................................... /07.3 COMIPI..\IN'1' Rls( )I.I''I'IO^ ..................................................................................................................................... 10

7.3.1 Follone np ^' F.s a/a/eon Process ......................................................................................................................... 11

7.3.2 (.ouiplninti. Ia,,agement (.ommlltee c Review of CoFup/ainis .................................................................................. I I

7.4 C \IN'I CL( )s('ItF ........................................................................................................................................... 12

8 GLOSSARY ..............................................................................................................................................................13

9 ANNEXURE ...........................................................................................................................................................14

9.1 CO\IPI..\IN'I' IZI((.IS'I I;K 1'OR\L\'I ............................................................................................................................. 149.2 '1':\'I' & F SC \I..VI ION :\L\TR1\ ................................................................................................................................ 16

9.3 RI(I'OR'I'IN( IN'I'I?RN.11.R F.S'fISRN 1I .................................................................................................................. 17

10 DESIRED GRIEVANCE REDRESSAL MECHANISM -TO ADOPT IN FUTURE ................................... 18

11 APPROACH FOLLOWED IN RESOLUTION OF GRIEVANCES UNDER CONSUMER PROTECTIONACT. 20

12 STEPS TAKEN/TO BE TAKEN BY THE COMPANY FOR CONSUMER EDUCATION ........................ 21

13 OUR GRIEVANCE REDRESSAL OFFICERS AT THE FOLLOWING LOCATIONS ................................ 22

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Grievance Redressal Policv

Policcy StatementI •:ffective complaints management is good business practice. k I .I H listens and positively- receive

customer complaints. We ensure all complaints are dealt with fairly and employees have the

necessary skills to manage these expressions of dissatisfaction confidently and competently to their

resolution.The following principles underpin KLII F complaints management:

• fair deal to all customers

• responsiveness towards customer complaints

• complainants are not to suffer reprisal for making a complaint• ensure all complaints are dealt as per the regulations prescribed by the regulatory authorities

• complaints are addressed fairly, reasonably and in a timely manner

• easy access to information and advice for all stakeholders

• application of natural justice and provision of avenues for review

• protection of confidentiality and complainants respectfully treated

• complaints data is integrated into business improvement processes

• the complaint management policy and its application is reviewed regularly to ensure it

remains an effective and appropriate mechanism to business improvement.

2 Applicability

This policy applies to all employees (including contractors and consultants engaged by the

department). The policy applies to internal and external complaints about KI.IFE policies, products

and services and/or its employees . However , it does not include complaints under unusual events

reporting and employee harassment policy.

The following are not classified as complaints:

• enquiries and requests for information

• input and feedback provided as a result of consultation processes.

3 Context

A key element toward achieving excellence is to engage with our customer and have high regard fortheir input. Effective complaints management is one avenue from which we can collect information

to inform continuous business improvement.The policy advocates accessible, transparent and accountable complaints management that:

• promotes and supports competent complaint handling

• is receptive to customer complaints• develops a culture that respects people's right to complain about any aspect of the

department's operations• provides an efficient and fair mechanism to resolve complaints and communicate outcomes

• uses the information from complaints to identify and rectify recurring and systemic

problems to improve planning and future service delivery.

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Grievance Redressal Policy

4 Objectives & Benefits

The objective of the RI] I' 1: complaints management policy is to:

• encourage the expression of customer dissatisfaction in a positive environment

• have fair, consistent and prompt investigation, decision making, and redress whichshould be embedded in well documented procedures

• provide a uniform process across KI,II1L for effective and prompt resolution ofcomplaints

• provide meaningful and useful information highlighting trends and systemic issuesassociated KI,IFIi processes, products or services enabling improvements in business

• have effective and prompt analysis of the root causes of complaints, and a commitment

to remedying such causes, to ensure fairer treatment to current and future customers

• promote customer confidence in KI,IFI by ensuring openness and transparency inhandling complaints.

This policy expresses principles to inform decision making across the department enablingconsistent and effective com plaints management.

5 Background , Purpose & Scope

KLIFI is in the life insurance business with centralized operations and decentralized business

sourcing PAN India through different channels namely Tied channel ( business sourced byindividual life advisors ), alternate channels ( other Kotak group companies, corporate partners etc),business associate and telesales teams. Life Insurance businesses are mostly sourced by partners andnon Kotak employees. "Plus often gives rise to varied level of service, commitments which are not

always as per the company standards. This often leads to customer dissatisfaction which results incomplaints from customers through various modes and through different departments. The mainidea of this document is to ensure that all complaints get recorded in KLIFI : books irrespective ofthe department where it was received and to provide a uniform process all across for effective andprompt complaint resolution

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Grievance Redressal Policy

6 Definitions

ComplaintA complaint is an expression of dissatisfaction verbally or in writing,

f' F or o anabout policies, products and services provided by 1,J A I

action of an KI.IFE employee. E.g:

• An error committed by anyone associated with KU (1:rroneous

documents/wrong information)

• Compensation transactions (resulting due to incorrect

conversions /s\N itches etc.)

• I\liss-selling by the Sales team

• Forgery

• Overwriting in proposal form

• Deficiency in service• Any servicing issue which causes inconvenience to the client etc.

Complainant This is a person who expresses dissatisfaction with KI.II^E policies,

products or service or action of an employee.

Internal Kotak Life Employees

Customer/Complainant

Internal Partners Life Advisors, Channel Partners, Doctors, Medical Centers, MediaPartners, Kotak Group companies for whom Kotak Life is

accountable

External Policy I lolders

Customers /Complainant

Standard Complaints 'I'bis is a failure of a product, service, system, policy or procedurewhich causes or contributes to a complaint, as opposed to anemployee's error of judgement. Eg: Non receipt of UL statements,

delay in receipt of policy document etc

Special Complaints Non standard complaints which are a result of a willful act ofmiscotnmum'cation, cheating, suppression of facts, misbehaviour etc.Eg: i\lisselling, Forgery, Misappropriation of funds etc.

Miss-selling Miss-selling would imply cases wherein:

• The charges have not been communicated to the client correctly

• The client was explained a different product but sold a different

product• Promising/projecting a benefit/ return to customer which is not

ex licitly promised in Product features.

Fraud I\Gsappropriation of Funds (putting money to some other use other

that pnrlx),( for which it was collected), unauthorized use of funds

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Grievance Redressal Policy1

I orl;er-, Document tamprrinl;, scribbling on document on customer behalf,

signing on document on customer's behalf, certifying customer

details (address, profession, details in \11 IR, ctc) without proper

verification

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Grievance Redressal Policy]

7 Process

7.1 Complaint Receipt & Registration

7.1.1 Receipt of Complaints

Complaints can be received from internal or external customers of KLIFE.

• KLIF1F, customers can register a complaint by way of :

n F.niails

n Snail Mails

n Phone Calls

n E-Complaints - Kotak Life Insurance -\vebsitc as well as the complaint section

on the Online Policy Manager

n Legal notices

• KLIFE customers can register a complaint with

n KLIFE Customer Care ( Client Service Desk & Contact Center)

n KLIFF Branches

n KLIFF Processing departments ( New Business, Policy Servicing, Channel

Support, Claims, RCU etc)

n KLIFE Legal & compliance department

n \Vebsite

n Chairman's office/MD's office/Ell's office/COO's office

n IRDA

n Ombudsmen

n Other statutory and regulatory bodies

7.1.2 Registering Complaints

• KI1IFF Customer Care( Complaints Management team) will be the central repository of all

complaints across the company.

• Complaints received through any mode and by any department across the company should

be forwarded to Customer Care Within 24 hours of receipt from the customer

• Complaint management team at customer care will update the complaint in the complaint

register maintained by them ( refer annexure) and provide a complaint number

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Grievance Redressal Policy

• It is the responsibility of the complaints management team to ensure completeness and

maintenance of the complaints register. '['hey have the right to reject re lucsts for registering

complaints which do not follow the defined process.

• All written complaints received would be in warded with date, time stamp as well asreceiver's signature.

• Complaints on phone need to be recorded in III :;V1' ( Internal CRM for K11I) for record

• A photocopy of the complaint would be made and sent for scanning and indexing in content

manager ( Document Management/Imaging System) under the concerned policy number

• The complaint management team((,-NI'I') appointed by the customer service head wouldensure that a I IL:A'I' call ( Internal CRM for KLI) is logged for the particular complaint onthe same day

• The complaint management team would also ensure that the complaint is updated in thecomplaint register ( refer annexure) with all the necessary details on the same day and acomplaint number is generated against for the same

7.2 Complaint Analysis

It is the responsibility of the complaints management team to analyze the complaint, establishmerits/demerits of the complaint based on initial investigation, categorize the complaint, prioritize onthe basis of facts of the case, identify and assign responsibility for resolution.

7.2.1 Categorization

As a first step of analysis , each complaint needs to be assigned a category based on the nature of thecomplaint . The nature of the complaint can be deciphered from the complaint description. Below isinitial list of categories . More categories can be added after discussion with customer care head fromtime to time.

Category Nature of Complaint

Sales Related • Instances of mis-selling, nus-representation of facts,

suppression of facts, mis-leading, over commitments, falsepromises etc

• Non-responsiveness and inappropriate behavior from agents,channel partners, KLIFF. sales managers etc

Product Features Related Complaints related to dissatisfaction over product features and policyTerms & conditions

• Alteration requests which cannot be processed on account of

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Grievance Redressal Policy

Category Nature of Complaint

product specs eg: Reducing premium Without reducing sum

assured

• I ugh deductions from premiums towards administrative/sales

charges

• Request for premium reduction not approved as per product

specs

• Non ability to surrender before 3 years etc

Forgery/Fraud Related Complaints related

• forged signature on documents

• tampering details on customer's documents done bydocument recipient (agent, employees at branches, I-IO, etc.)

• ;Misappropriation of customers funds

• Frauds etc

Customer Servicing Related Complaints related to non responsiveness, inadequate service,

i.e. deficiency in service inappropriate service and inappropriate behavior from branch, CPC &1-IO, pending payment, inadequate payment and incorrect payment tochannel partners, agents, media partners, service providers

Process & Controls /Others Complaints related to unreasonable, unjustifiable process steps andprocess controls and other miscellaneous complaints

7.2.2 Prioritization

• \X'hile the maximum TAT for resolution of all complaints is frozen at 10 workingdays ( 15 days for misselling and forgery cases), certain complaints need to beprioritized for resolution on an ASAP mode. Standard servicing complaints asdefined earlier will be closed as per the "I'XI defined in SL.\ matrix (Refer annexure)Once the merit of the complaint is established, customercare/departments/branches should immediately prioritize them on the basic of the

facts ascertained during initial investigation.

Complaints once prioritized needs to be treated in special ways. Customer care to follow up withconcerned teams for end to end resolution teams and resort to escalation to highest level( refer

escalation matrix) for speedy closure

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7.2.3 Assigning Responsibility

Grievance Redressal Policy

• On the basis of the initial investigation done by the complaints management team, the team

would assign responsibility for various actions that need to be executed for resolving the

complaint. I:.g : Sales team to get approval from their channel head/ NID/F .D/COO for

processing a cancellation for misselling, Ops to actually affect the cancellation in system once

the approvals are received etc

• The complaints management team would also intimate the concerned teams/ members therequirements in terms of documents /approvals/actions to resolve the case

• 111 cases of forgery and fraud will be rnandatorily reported to RCU ( Risk Control Unit) for

investigation and their final feedback/ recommendation will have to be updated in thecomplaints register.

7.3 Complaint Resolution

Resolution of the complaints is responsibility of customer care - complaint management team.

Complaint resolution may be possible by customer care alone or with the help of actions taken byother departments.

• For all cases received by customer care, complaints management team would respond to thecustomer (via letter/email/phone ) within 1 working day from date of receipt of complaint.

• The complaint management team would need to confirm the receipt of complaint and theexpected time frame to revert back to the customer.

• For all complaints , initial investigation will he done on the same day based on the complaintreceived , past documents in content manager ( document management/imaging system), policydetails in Life Asia( core system), discussion with relevant parties and a case sheet would beprepared

• Incase the complaint does not have any merit ; the complaints management team would close thesame in the complaint register and also close the corresponding I IFAT (internal CRNI) call.

• The complaints management team would also send a formal letter ( incase of snail mail/walk-ins)or an email (incase of emails /web /phone calls ) to the customer citing clear reasons for rejectionof hi s complaint

• Complaints management would ensure that the reason mentioned for rejection and the language

used in the letter is appropriate from customer service and compliance point of view. Allrejection letters to be sifnied /approved by complaints management head( customer service -

non voice head) or customer care head before being released to the customer

• The letter/email should assure the customer of best service from Kotak Life and must he

assured that he may get in touch with Kotak Life incase he is not happy With the resolution.

• Incase, customer care believes that the complaint received holds merit, customer care would

follow the subsequent steps within 24 hours to ensure resolution:

1

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Grie%ance Redressal Policy

n Identify the concerned teams to whom responsibility needs to be assigned

n Forward emails with the facts of the case and reasons for finding merit in the

complaint to the concerned teams/metnbcrs eg: sales/operations/ RCi-/legal

etc

n Clearly define in the email as to what is expected out of the concerned teams -

collection of documents/approvals from respective heads/issue of warning

letters/ termination of agents etc

n Complaint management team to also define in the email the timeframe within

which a revert is expected from the teams/members

r7.3.1 Follow up & Escalation Process

The complaint management team bears the responsibility of resolving the complaint for

customers within a maximum TAT of 10 days (15 days for miss-selling and forgery cases). The

complaint management team would ensure follow ups with the concerned teams/metnbcrs for

prompt and timely resolution.

• The complaint register ( currently maintained in excel) is updated with formulae which throwup cases which have crossed the various threshold of escalation within the TX! of 10 days

• Complaints management team would also escalate cases based on the escalation matrix( refer

annexurc)

• Complaints management team would publish fortnightly MIS of number of open cases -

Branchwise/ Channel wise/Ageing wise/SM wise

• Complaint management team would also highlight these cases in the review committee( refer

8.3.3 )

• For IRDA /Ombudsmen/legal complaints, incase no positive revert is received for closurefrom the concerned teams/members, follow ups and escalations will be taken over by ChiefManager - Compliance from the Level 2 escalation ( 7 days from date of receipt of

complaint)

7.3.2 Governance Structure - Complaints Management Committee

• The Complaints Management Committee would consist of MJFE MI), K!.1H ED &

KLIFF. COO.

• Complaints management team would organize periodic review meetings with the Complaints

Management Committee to get conclusion on open cases pending beyond "1':x"1'

• The review meetings to be held with the committee with special invitation to Sales I leads

and Operations Head. Complaint management team would present all open cases with

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Grievance Redressal Policy

relevant details in a presentation format to the management and decision given on each casesby M1l)/I-D/COO would be minuted and implemented.

• Periodic review should evaluate following aspects:

n l'urnarounds for complaint resolution

n Review of pending and open cases with reasonsn Directions and trends arising from complaints & complaint resolutionn Impact of complaints and resolution on 1<1] F l (Brand , Financial,

compliance, etc)

n formulation of plans and policies based on the trends & impact analysisn Corrective and pre-emptive actions for futuren Any other matter or policy in relation to complaints and grievances that the

Complaints Management Committee deems fit.

7.4 Complaint Closure

• Complaints would be eligible for closure

n when the merit in the complaint is accepted by all concerned teams /membersand written acceptance is forwarded to customer care along with necessary actionfor resolution - e.g.: necessary approvals /issue of warning letters etc and thecomplaints management team agrees that the resolution is adequate and fair tothe customer

n when the case is escalated to higher authorities - Level 1:

Sales/Ops/Compliance heads and Level 2: MMD/ED/COO and necessary

approvals are received from them and the complaints management team agreesthat the resolution is adequate and fair to the customer

n when the cases are discussed in the fortnightly review meeting and approvals arereceived from MD/ED /COO directly and the complaints management teamagrees that the resolution is adequate and fair to the customer

• Letter/limail to be sent to the customer informing him that his complaint has been resolved,

apologizing about the aberration in service and informing him that we would love to beassociated with him in future.

• Once a favourable closure is chalked out for the customer and closure letter forwarded to

the customer, the complaint management register would have to be updated as closed by the

complaints management team.

• The complaints management team to go through the checklist ( all or combination may beapplicable for case on case ) before closing the complaint in the complaint register;

n Necessary approvalsn Warning letters/Termination lettersn Complaint withdrawal letter

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Grievance Redressal Policy

n Necessary details are updated in complaint register ( e.g. ch(-yuc details for

refund cases/POD details for closure letters sent to customer etc)

n Necessary documctit, /conununications /approvals are scanned in content

manager

n Closure of I I I Vl calls

8 Glossary

Sr. Num Abbreviation Description

1 CPC Central Processing Center

2 Ctii1' Complaints Management Team

3 COO Chief Operating Officer

4 CS Channel Support

5 CSO Customer Service Officer

6 ED Executive Director

7 HNI I ugh Networth Individual

8 IRDA Insurance Regulatory Development Authority of India

9 KLIFE Kotak Nlahindra Old Mutual Life Insurance Limited

10 MD Managing Director

11 NB New Business

12 PS Policy Servicing

13 RCU Risk Control Unit

14 SCI Sales Manager

15 `1'A'1' Turn Around lime

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(: rieva n cc Iced ressa l Policy

9 Annexure

9.1 Complaint Register Format

SR. Field To be filled ExplanationNum in by

1 Sr. Num Auto Generated Auto generated serial number for the register

2 Master Complaint ID CSD • To be given only by CSD team for all thedepartments.

• All departments to take the complaint number

from (:SD on receipt of the complaint at their end.

• No approvals to be given by higher authority

without the mention of complaint number

3 1 teat 11) Concerned • All complaints to be also logged in I IEATDepartment

resolving the • No approvals to be given by higher authority

complaint without the mention of HEAT 11)

4 Proposal/ Policy Concerned

Department

5 Clients Name Concerned

Department

6 Branch Concerned • The branch to which the policy is attachedDepartment

7 Channel Concerned • The channel through which the business wasDepartment sourced

• Drop Down Available - TA (Tied), CA

Alternate), BA ( Business Associates), DM ( Direct

Nlarketing),'I'S (TeleSales)

8 Received By - Concerned Department I Iandling the complaintDepartment Department

9 Received By - Name Concerned Person working on the complaint from thatDepartment department

10 Source Concerned • Drop Down Available - Direct C ustomer/DirectDepartment I.,A/IRDA/Ombudsmen/I.ife

Counsel/Legal/Udays Office/Mgnu Desk/PoliceFIR/Others

11 Mode Concerned • Drop Down Available - Letter/ I-:mai1/Call/portalDepartment

12 Received Date Concerned Date on which the complaint was received by customerDepartment care/branch/ CPC dcpartnurnts.

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Grievance Redressal Policy

13 Complaint - Description Concerned Brief gist of the complaint

Department

14 Complaint - Category Concerned • Drop Down Available - \Iisselling/Service

Department Related/ Product Related/Forgery/Others

15 Action - In progess Concerned The action being taken for resolution

Department

16 Final Revert Rccvd Date Concerned • Date on which final resolution has been received.

Department • Interim dates should not be tilled in

17 Prompt for Escalation Auto Generated • This is a formula driven field

• Will prompt if a complaint is pending for

resolution beyond TAT

• Will also prompt the level of escalation

• To be used to track open cases

18 Due for Closure - Date Auto Generated • This is a formula driven field

• Will prompt the date by which the complaint

should surely be closed (Maximum closure time)

• To be used to track open cases

19 Complaint Status Concerned • Drop Down Available - Open/Closed - Rejected/

Department Closed - Resolved

20 Complaint Closed - Concerned Date on which the complaint was finally/completely

Date Department closed

21 Ageing Auto Generated • This is a formula driven field

• Will prompt the TAT for closure

• To be used for MIS reporting

22 Closure Description Concerned Brief description

Department

23 Action taken/Warnings Concerned • Drop Down Available - Yes/No

Given Department • Action letter/Warning letter issued by Sales Flead,

Shekhar Bhandari/Suresh Agarval) or Ops I lead

I litesh Veera) needs to be collected and scanned

in CM

24 Closed by Concerned Name of the person closing the complaint

Department

25 Whether forwarded to Concerned • Drop Down Available - Yes/No

RC I' Department

26 RCU Comments Concerned Brief Description of comments given by RCU

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Grievance Redressal Policy

Dcparnnent

27 I"inal Resolution Concerned final recommendation given by RCt'Department

28 Case Reopened:' Concerned To be tilled it customer conic back with additionDepartment proofs/documents on an already closed complaint

29 Reason Concerned Brief description as to why the case is being reopenedDepartment

30 Reopen Date Concerned l)ate of which the case is reopened - Date of receipt ofDepartment complaint

31 Reopen - Complaint Ill Concerned New complaint ID in the register for reopening theDepartment case

9.2 TAT & Escalation Matrix

TAT in Days Escalation Matrix.

:- Nfail with case History sent to

• I or Sales : To SM with copy to BSI and RI\l,

• For Sales ( Kotak Group Companies) -To RMls with copy to Thakur Bhaskar

• For Branch: To BOEs & ROC with copy to 1-lead of Branch Ops

• For CPC : To department heads with copy to CPC Head

• For RCU : To concerned team member with copy to RCU I lead

U • For Underwriting : To concerned team member with cop), to Underwriting I lead

Escalate to Sales Heads (Tied I-lead/Alternate I Iead/Kotak Direct I lead),

5 Operations Head , RCU I lead, Underwriting Head

7 Escalate to MD/Ell for Sales and COO for Ops/RCU/Underwriting

10 Final closure to customer

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Grievance Redressal Police

9.3 Reporting - Internal & External

Internal Reporting

Report Frequency Recipients

Pending Report - Channelwise/Branch wise Weekly - Wednesday Sales/Ops/RCU/Claims

Pending Heads, CPC DepartmentHeads. KL.I BMs

Pending Report - Functionwise/Channelwise/ Weekly - Wednesday Sales/Ops/RCU/Claiins

Branchwise Pending Heads. CPC DepartmentHeads, KL.I BMs

Pending Report - Sales Pending ( Channel/ Weekly - Wednesday Sales/Ops/RCU/Claims

Ageing) I leads, CPC DepartmentHeads, KLI BMs

Pending Report - Dcpartmentwise Ageing Weekly - Wednesday Sales/Ops/RCU/ClaimsHeads, CPC DepartmentHeads, KLI BMs

External Reporting

IRDA requires every life insurance company to publish in their websitc statistics pertaining to

complaints received from customers against the agents.

External Reporting to be done as per process " Process Note on Complaints relating to

ATIs/Agents"

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Grievance Redressal Policy

10 Desired Grievance Redressal Mechanism - To Adopt in Future

Complaints Management Process is a reactive measure taken by most of the companies to addresscustomer issues faced by them on account of service aberrations, unethical business acquisition -whichlacks suitability and affordability. Our focus in the coming years should be to reduce complaints insteadof reacting to complaints. Our business model of sourcing business through extended partners in theform of agents and brokers snake it extremely critical for us to believe and drive the. importance ofethical & honest practices. Ilowvever, the high attrition in advisors, sales force and their movement

within different insurance companies make it very difficult to control instances of rnisselling /forgery fo rshort term gains. The times ahead demand quality on the kind of business sourced so that we do notlose out on our customers to optional cancellations, future lapsations and disputes. It requires us to behighly compliant in all aspects and practice conformity in letter and spirit and not just on paper.

Some of the proactive steps that we would like to take as a company in future along with the help ofIRD;1 and other insurance companies in the industry:

• Establishing a credit bureau similar to CIBIL, comprising of a comprehensive repository of datapertaining to all Sourcing agents from all insurance providers regulated by IRDA. This will enable usto track the movements of all advisors and maintain a tight leash around them, so as to prevent/rnimn-aze occurrence of any unethical selling practices and subsequent customer dissatisfaction.

• More transparency & convenience in the grievance redressal procedure, Involve usage of technologyto integrate the existing systems available and ensure increased level of automation

a. Automating the complaints management system

h. Customer is to be provided the functionality to lodge a complaint using the online

customer portal, from where the same will be picked up and be dealt with.

c. Customer will be able to check on the status/ progress of the complaint by logging in tothe portal and track the progress of the complaint by date and the stage it has reached.

d. Customer should also he able to receive a Short summary on the status of the complaintby sending us an SMS (Keyword + Complaint Ref no).

c. A similar function can be enabled on the IVR as well, subject to feasibility of the same.

• Ethical acquisition of business - Guideline of best practices to be followed by sourcing agents, sothat any new business acquired is not done through any untoward/ nefarious means, failing whichthey would be eligible for punitive action as the situation may warrant.

• F xtreme caution needs to be exercised, both at the acquisition stage as well as during the complaint

handling stage that no unrealistic commitments whatsoever are made to the customer at any time

and in any form, -which we may not be able to deliver later.

• Benefit of doubt to be provided to the customer, in case a situation reaches a deadlock/ stalemate.

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Grievance Redressal Police

• Clearer guidelines in terms whether a complaint demands merit or not ; in terms of timescales within

which a customer can revert, legitimacy of the facts presented.

• 1 lowever, as each and every complaint is unique in itself, we must adopt a more pragmatic approach

and ensure that every complaint received is treated with apt jurisprudence.

• Greater involvement is also needed in terms of providing consumer education initiatives ( informing

customer about their rights, etc .). This can be attained by issuance of newsletters / news bulletins

and putting relevant content on the websitc.

• Greater levels of clarity in all our communication / terminology listed on the Policy document needsto be made more lucid, such that any layman may he able to interpret the same.

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Grievance Redressal J'olicv

11 Approach followed in resolution of grievances under Consumer ProtectionAct.

• On receipt of complaint/summon/notice from Consumer Courts for cases filed under the

Consumer Protection Act, our Legal team first studies the case & investigates into the merits.

• The Legal team will contest only those cases tiled against K1A which holds merit. Legal team will

not contest all cases filed against K1.I just for the sake of contesting cases.

• Our Legal team will collate necessary facts & information on the issue based on which, strengths

& weaknesses are ascertained.

• Once the merit of the case is ascertained , our Legal team entrusts the matter to the advocate torepresent.

• Drafting, pleading, filing of replies , affidavit , written arguments are in-house activities of theLegal team.

• Based on the facts & info gathered, if it is not a fit case or customer's grievance / allegations aregenuine, Legal team would take up the matter with competent authority to settle the caseamicably out of court.

• Necessary approval /s will be taken & legal team will take it up for logical conclusion.

Compliance with Court orders / judgements:

• On receipt of the final verdict/order, Legal team will study the order & provide its views on

gravity /criticality of the issue.

• Legal team will look into the merits. Based on the possibility/probability of winning as well ason the legal aspects, Legal team will provide its views and opinion for logical conclusion whetherto prefer an appeal or not.

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Page 21: Life Insurance Ltd

IGrievance Redressal Policy

12 Steps taken to be taken by the company for consumer education.

• At the very outset, language used in all customer correspondence, particularly the Policy document

needs to be made simpler, such that am' layman may be able to interpret the same. A dedicated l-:\(

booklet explaining all terms and conditions arc to be enclosed with every Policy documents.

• Consumer education initiatives can be fulfilled in a major way by way of Newsletters/ leaflets/

mailers, which can be sent to the customers through snail mail & e-mail, educating them about their

rights and creating awareness.

• Relevant content also needs to be uploaded on the website from time to tithe; updates on the sane

can be flashed on the customer portal in the form of a ticker.

• Consumer education through every customer touch points

• Inbound Contact Center -Through IVRs and agents

• Outbound Contact Center -Through agents

• SKIS Alerts

r

• All insurance providers, at the behest of the 1RDA would require to set-up a dedicated consortiumsuch as a Consumer forum/ helpline, wvhich would review and adjudicate the complaints received.

A dedicated resource to be posted at all branches who can be approached by the customer to seek clarity

about the product or about any procedure that may he need to be followed in the event of any servicing

need/ complaint/ discrepancy

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Page 22: Life Insurance Ltd

Grievance Redressal Policy

13 Our Grievance Redressal Officers at the following locations

Complaints1'\N IndiManagement Cell a

Chief Grit ranee \IalieshkumarO b r P \\ I diee Radhak ri hnan

- n a

Senior Vice

President -3 '( )perations & I litesh \ ecra PAN IndiaService I lead

Customer Service

I lead Kalparupa Datta PAN India

5 Regional ( )pcrations West Bengal , Bihar,

Controller Rajiv Bagaria Jharkhand, ( ) rissa,Assam

Regional ( ) pcraiionsController Rajneesh Nangia Maharashtra & Goa

Regional ( ) pcrationsController Digvijav Karki Delhi, NCR &

Rajasthan

Regional ( )perationsController Rahul Arora Punjab & I lan'ana

Regional ( )perations9 Controller Priti Punjabi Gujarat

Regional ( ) pcrations South 1 - Andhra10 Controller \lithun Shanbhag Pradesh &

KarnatakaRegional ( )pcrarion,

II Conrrollc-r Seshadri R South 2 -TamilNadu & Kerala

Regional ( )pcrations12 Controller

Shashank Uttar Pradesh &Srivastava \ladhva Pradesh

clientservicedesk (I kotakcom

n-lahesh .kumar(a;kort k.com

hitcsh ._̂ _eera.9 kotlk.com

I:alpan) .datta a kota^.com

ra bagaria(a k-wak`com

raincesh ran is kotak.com

diaiiaiia y. kart i.(t k-ptokc;om

rah I arora(2kot k.cQm

rr unjabi(aLkclabsczrrr

rni. th un. s h a n [email protected]. corn

seshadri.r p%kotakcom

sriv-astava.shashank(t kotak.com

1800 209 8800

022 66215865

022-66215103

022-66215195

09836112212

09920606088

09999200391

09216911681

09825260336

09845579777

09282345450

09935557561

For an grievances, we suggest you wclicnts rite in to our dedicated complaints management cell at

en-icedesk(citkotak,com, Our officers will revert to \•ou with resolution within 2 business days. 11o^^ever, iy ifYOU are not satisfied with the resolution provided, you can highlight your complaint to the Grievance RedressalOfficers of your region or to the Grievance Officers at our I lead Office.

Page 22 of 22