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Location: Central Bank of Bahrain Volume 3—Insurance > Part A > Business Standards > BC Business and Market Conduct > BC-4 Customer Complaints Procedures
  • BC-4 Customer Complaints Procedures

    • BC-4.1 General Requirements

      • BC-4.1.1

        All insurance licenseesG must have appropriate customer complaints handling procedures and systems for effective handling of complaints made by customers by 31st March 2012.

        Added: October 2011

      • BC-4.1.2

        Customer complaints procedures must be documented appropriately and their customers must be informed of their availability.

        Added: October 2011

      • BC-4.1.3

        All insurance licenseesG must appoint a customer complaints officer and publicise his/ her contact details at all departments and branches. The customer complaints officer must be of a senior level at the insurance licenseeG and must be independent of the parties to the complaint to minimize any potential conflict of interest.

        Added: October 2011

      • BC-4.1.3A

        The position of customer complaints officer may be combined with that of compliance officer.

        Added: October 2012

      • BC-4.1.4

        In the case of an overseas insurance licenseeG , a local complaints officer must be present and must report all complaints to the head office complaints unit.

        Added: October 2011

    • BC-4.2 Documenting Customer Complaints Handling Procedures

      • BC-4.2.1

        In order to make customer complaints handling procedures as transparent and accessible as possible, all insurance licenseesG must document their customer complaints handling procedures. These include setting out in writing:

        (a) The procedures and policies for:
        (i) Receiving and acknowledging complaints;
        (ii) Investigating complaints;
        (iii) Responding to complaints within appropriate time limits;
        (iv) Recording information about complaints; and
        (v) Identifying recurring system failure issues; and
        (b) The types of remedies available for resolving complaints; and
        (c) The organisational reporting structure for the complaints handling function.
        Amended: January 2012
        Added: October 2011

      • BC-4.2.2

        Insurance licenseesG must provide a copy of the procedures to all relevant staff, so that they may be able to inform customers. A simple and easy-to-use guide to the procedures must also be made available to all customers, on request, and when they want to make a complaint.

        Added: October 2011

      • BC-4.2.3

        Insurance licenseesG are required to ensure that claims forms and claim notification documents include a statement informing the customer of the availability of a simple and easy-to-use guide on customer complaints procedures in the event the customer is not satisfied with the services provided.

        Amended: January 2012
        Added: October 2011

    • BC-4.3 Principles for Effective Handling of Complaints

      • BC-4.3.1

        Adherence to the following principles is required for effective handling of complaints:

        Added: October 2011

      • Visibility

        • BC-4.3.2

          "How and where to complain" must be well publicised to customers and other interested parties, in both English and Arabic languages.

          Added: October 2011

      • Accessibility

        • BC-4.3.3

          A complaints handling process must be easily accessible to all customers and must be free of charge.

          Added: October 2011

        • BC-4.3.4

          While an insurance licensee'sG website is considered an acceptable mean for dealing with customer complaints, it should not be the only means available to customers as not all customers have access to the internet.

          Amended: January 2012
          Added: October 2011

        • BC-4.3.5

          Process information must be readily accessible and must include flexibility in the method of making complaints.

          Added: October 2011

        • BC-4.3.6

          Support for customers in interpreting the complaints procedures must be provided, upon request.

          Added: October 2011

        • BC-4.3.7

          Information and assistance must be available on details of making and resolving a complaint.

          Added: October 2011

        • BC-4.3.8

          Supporting information must be easy to understand and use.

          Added: October 2011

        • BC-4.3.9

          [This Paragraph was deleted in January 2012].

          Deleted: January 2012

        • BC-4.3.10

          Insurance licenseesG should incorporate the complaints procedure as a clause within the insurance policies provided to their customers.

          Added: October 2011

      • Responsiveness

        • BC-4.3.11

          Receipt of complaints must be acknowledged in accordance with Section BC-4.5 "Response to Complaints".

          Added: October 2011

        • BC-4.3.12

          Complaints must be addressed promptly in accordance with their urgency.

          Added: October 2011

        • BC-4.3.13

          Customers must be treated with courtesy.

          Added: October 2011

        • BC-4.3.14

          Customers must be kept informed of the progress of their complaint.

          Added: October 2011

        • BC-4.3.15

          If a customer is not satisfied with an insurance licensee'sG response, the insurance licenseeG must advise the customer on how to take the complaint further within the organisation.

          Added: October 2011

        • BC-4.3.16

          In the event that they are unable to resolve a complaint, insurance licenseesG must outline the options that are open to that customer to pursue the matter further, including, where appropriate, referring the matter to the Compliance Directorate at the CBB.

          Added: October 2011

      • Objectivity and Efficiency

        • BC-4.3.17

          Complaints must be addressed in an equitable, objective, unbiased and efficient manner.

          Amended: January 2012
          Added: October 2011

        • BC-4.3.18

          General principles for objectivity in the complaints handling process include:

          (a) Openness:
          The process must be clear and well publicised so that both staff and customers can understand.
          (b) Impartiality:
          (i) Measures must be taken to protect the person the complaint is made against from bias;
          (ii) Emphasis must be placed on resolution of the complaint not blame; and
          (iii) The investigation must be carried out by a person independent of the person complained about.
          (c) Accessibility:
          (i) The insurance licenseeG must allow customer access to the process at any reasonable point in time; and
          (ii) A joint response must be made when the complaint affects different participants.
          (d) Completeness:
          The complaints officer must find the relevant facts, talk to both sides, establish common ground and verify explanations wherever possible;
          (e) Equitability:
          Give equal treatment to all parties.
          (f) Sensitivity:
          Each complaint must be treated on its merits and paying due care to individual circumstances.
          (g) Objectivity for personnel — complaints handling procedures must ensure those complained about are treated fairly which implies:
          (i) Informing them immediately and completely on complaints about performance;
          (ii) Giving them an opportunity to explain and providing appropriate support;
          (iii) Keeping them informed of the progress and result of the complaint investigation;
          (iv) Full details of the complaint are given to those the complaint is made against prior to interview; and
          (v) Personnel must be assured they are supported by the process and should be encouraged to learn from the experience and develop a better understanding of the complaints process;
          (h) Confidentiality:
          (i) In addition to customer confidentiality, the process must ensure confidentiality for staff who have a complaint made against them and the details must only be known to those directly concerned;
          (ii) Customer information must be protected and not disclosed, unless the customer consents otherwise; and
          (iii) Protect the customer and customer's identity as far as is reasonable to avoid deterring complaints due to fear of inconvenience or discrimination.
          (i) Objectivity monitoring:
          insurance licenseesG must monitor responses to customers to ensure objectivity which could include random monitoring of resolved complaints.
          (j) Charges:
          The process must be free of charge to customers;
          (k) Customer Focused Approach:
          (i) Insurance licenseesG must have a customer focused approach;
          (ii) Insurance licenseesG must be open to feedback; and
          (iii) Insurance licenseesG must show commitment to resolving problems.
          (l) Accountability:
          Insurance licenseesG must ensure accountability for reporting actions and decisions with respect to complaints handling; and
          (m) Continual improvement:
          Continual improvement of the complaints handling process and the quality of products and services must be a permanent objective of the insurance licenseesG .
          Amended: January 2012
          Added: October 2011

    • BC-4.4 Internal Complaint Handling Procedures

      • BC-4.4.1

        An insurance licensee'sG internal complaint handling procedures must provide for:

        (a) The receipt of written complaints;
        (b) The appropriate investigation of complaints;
        (c) An appropriate decision-making process in relation to the response to a customer complaint;
        (d) Notification of the decision to the customer;
        (e) The recording of complaints; and
        (f) How to deal with complaints when a business continuity plan (BCP) is operative.
        Added: October 2011

      • BC-4.4.2

        An insurance licensee'sG internal complaint handling procedures must be designed to ensure that:

        (a) All complaints are handled fairly, effectively and promptly;
        (b) Recurring systems failures are identified, investigated and remedied;
        (c) The number of unresolved complaints referred to the CBB is minimized;
        (d) The employee responsible for the resolution of complaints has the necessary authority to resolve complaints or has ready access to an employee who has the necessary authority; and
        (e) Relevant employees are aware of the insurance licensee'sG internal complaint handling procedures and comply with them and receive training periodically to be kept abreast of changes in procedures.
        Added: October 2011

    • BC-4.5 Response to Complaints

      • BC-4.5.1

        An insurance licenseeG must acknowledge in writing within the same day of receipt of customer written complaints for non-life insurance policies and within 5 business days of receipt of customer written complaints for life insurance policies.

        Added: October 2011

      • BC-4.5.2

        An insurance licenseeG must respond in writing to a customer's complaint within one week of receiving non-life insurance policies complaint and within 2 weeks of receiving life insurance policies complaint, explaining their position and how they propose to deal with the complaint.

        Added: October 2011

      • Redress

        • BC-4.5.3

          An insurance licenseeG should decide and communicate how it proposes (if at all) to provide the customer with redress. Where appropriate, the insurance licenseeG must explain the options open to the customer and the procedures necessary to obtain the redress.

          Added: October 2011

        • BC-4.5.4

          Where an insurance licenseeG decides that redress in the form of compensation is appropriate, the insurance licenseeG must provide the complainant with fair compensation and must comply with any offer of compensation made by it which the complainant accepts.

          Added: October 2011

        • BC-4.5.5

          Where an insurance licenseeG decides that redress in a form other than compensation is appropriate, it must provide the redress as soon as practicable.

          Added: October 2011

        • BC-4.5.6

          Should the customer that filed a complaint not be satisfied with the response received as per Paragraph BC-4.5.2, he can forward the complaint to the Compliance Directorate at the CBB within 30 calendar days from the date of receiving the letter from the insurance licenseeG .

          Added: October 2011

    • BC-4.6 Records of Complaints

      • BC-4.6.1

        An insurance licenseeG must maintain a record of all customers' complaints. The record of each complaint must include:

        (a) The identity of the complainant;
        (b) The substance of the complaint;
        (c) The status of the complaint, including whether resolved or not, and whether redress was provided; and
        (d) All correspondence in relation to the complaint. Such records must be retained by the insurance licenseeG for a period of 5 years from the date of receipt of the complaint.
        Added: October 2011

    • BC-4.7 Reporting of Complaints

      • BC-4.7.1

        An insurance licenseeG must submit to the CBB's Compliance Directorate a quarterly report summarising the following:

        (a) The number of complaints received;
        (b) The substance of the complaints;
        (c) The number of days it took the insurance licenseeG to acknowledge and to respond to the complaints; and
        (d) The status of the complaint, including whether resolved or not, and whether redress was provided.
        Added: October 2011

      • BC-4.7.2

        The report referred to in Paragraph BC-4.7.1 must be sent electronically to compliance@cbb.gov.bh.

        Added: July 2013

      • BC-4.7.3

        Where no complaints have been received by the licensee within the quarter, a 'nil' report should be submitted to the CBB's Compliance Directorate.

        Added: July 2013

    • BC-4.8 Monitoring and Enforcement

      • BC-4.8.1

        Compliance with these requirements is subject to the ongoing supervision of the CBB as well as being part of any CBB inspection of a licenseeG . Failure to comply with these requirements is subject to enforcement measures as outlined in Module EN (Enforcement).

        Added: October 2011

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