Avoid Disputes, Not Complaints

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Avoid Disputes, Not Complaints

• Presented by Stuart Ayres and Derek Pullen

Stuart Ayres, Scheme Manager Derek Pullen,
Scheme Adjudicator
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Avoid Disputes, Not Complaints

• Customers can not only talk back, they can look
  into the very workings of your business and
  decide if you conduct yourself in a way they
  approve of.
• In this world, your reputation will be the
  sum total of all your conduct and interactions,
  which will now be so much more measurable by
  outsiders
• Tom Friedman, The World is Flat

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Never Had One, Never Will

• Be prepared, be pro-active
• Must have an internal complaints system
• Consumer awareness
• Benefit to consumers and to financial service
  providers
• From bottom drawer to business tool
• Reputation and referrals
• Environment of trust and open exchange
• New business

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What is a Complaint?

• Any indication that a service or product does
• not meet a customers expectations

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What is a Complaint?

• Feedback

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Overview

• Developing a good Internal Complaints Process
  (ICP)
• The FDR Dispute Resolution Process
• Complaint Handling
• Complaints are Gifts
• Root Cause Analysis
• Q and A

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Developing a good ICP

• Guiding Principles (ISO 10002)
• Visibility
• Accessibility
• Responsiveness
• Objectivity
• Free
• Confidentiality
• Customer focused approach
• Accountability
• Continual improvement

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Developing a good ICP Alternative Dispute
Resolution
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Developing a good ICP The Framework

• Commitment of top management and personnel
• Policy
• Customer focused obtain input from customers,
  personnel and interested parties
• Known by all personnel
• Available to customers and interested parties
• Consider regulatory and operational requirements
• Align quality and complaints policy

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Developing a good ICP The Framework

• Responsibility and Authority
• Top Management
• Complaints Handling Representative
• Managers
• Personnel in contact with customers and
  complainants
• Communication

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Developing a good ICP The Framework

• Responsibility and Authority Top Management
• Ensuring establishment, planning, designing,
  implementation
• Maintenance and continuous improvement of I C P
  and its objectives
• Identifying and allocating management resources
  and representatives
• Ensure promotion of I C P and customer focus
• Periodically review I C P to ensure effective,
  efficient and continuously improved
• Make information about the I C P is easily
  accessible to all
• Develop a process for escalating significant
  complaints to senior management

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Developing a good ICP The Framework

• Responsibility and Authority Complaints
  Representative
• Complaints Handling Representative (senior
  person, marketing?)
• Establish the process for performance monitoring,
  evaluation and reporting
• Reporting to top management on I C P, with
  recommendations for improvement
• Maintaining effective and efficient operation of
  I C P, including personnel
• I T, documentation, deadlines and process reviews

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Developing a good ICP The Framework

• Responsibility and Authority Managers
• Implementation
• Liaising with ICP representative
• Promotion of awareness of I C P and customer
  focus
• Information on I C P is accessible
• Reporting on actions and decisions
• Ensure monitoring of I C P undertaken and
  recorded
• Ensure action taken to correct problem, prevent
  in future and recorded
• Ensure data available for review

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Developing a good ICP The Framework

• Responsibility and Authority Personnel
• All personnel in contact with customers and
  complainants
• Trained in complaints handling
• Comply with I C P requirements
• Treat customers courteously and promptly respond
  to complaints
• Show good interpersonal and communication skills
• Aware of their roles, responsibilities and
  authorities re. complaints
• Aware of procedures to follow and information to
  give complainants
• Report complaints of significance

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Developing a good ICP - Operation

• Communication
• Information readily available, clear language and
  formats
• Disclosure document, brochures, website, email
• Where and how complaints can be made
• Information to be provided regarding the dispute
  process
• Time periods of various stages
• Options for remedy
• Avenues for feedback on the complaint

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Developing a good ICP - Operation

• 1. Receipt
• 2. Tracking
• 3. Acknowledgement
• 4. Initial Assessment
• 5. Investigation
• 6. Response Decision and deadlock notices

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Developing a good ICP - Operation

• 1. Receipt
• Record with supporting information and unique I D
  code
• Identify remedy sought by complainant
• Identify products / practices complained about
• Due date for response
• Data on people etc
• Immediate action taken

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Developing a good ICP - Operation

• 2. Tracking
• Complaint should be tracked throughout entire
  process until complainant satisfied or decision
  made
• Up-to-date status made available to complainant
  on request and at regular intervals

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Developing a good ICP - Operation

• 3. Acknowledgement
• Receipt acknowledged immediately (post, phone or
  email)
• Certainly within 2 working days
• 4. Initial assessment
• For severity, safety implications, complexity,
  impact and need for possible immediate action
• 5. Investigation
• Reasonable effort made to investigate all
  relevant circumstances and information
• Level commensurate with seriousness, frequency
  and severity

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Developing a good ICP - Operation

• Response Decision Notice
• P I Insurer - notify
• Following investigation, offer response
• Decision notice (suggest within 10 working days)
• If accepted, obtain acceptance in writing
• Carry out decision /action and record

• Response Deadlock Notice
• If decision not accepted by complainant
• Issue Deadlock Notice (Template)
• State view unlikely to resolve complaint
  internally
• Outline clearly how to access FDR scheme (free)
• Leave complaint open
• Liaise with FDR
• Monitor progress until complainant satisfied

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Developing a good ICP Maintenance and
Improvements

• 1. Collection of Information
• 2. Analysis and evaluation of complaints
• identify systemic, recurring and single incident
  problems and trends
• 3. Satisfaction with the I C P
• Random surveys?
• 4. Monitoring of the I C P
• 5. Auditing of the I C P
• 6. Management review
• 7. Continuous improvement, product / service
  development

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Developing a good ICP Possible Responses

• Refunds
• Replacement
• Rework
• Substitutes
• Technical assistance
• Information
• Referral

• Financial assistance
• Other assistance
• Compensation
• Apology
• Goodwill gift or token
• Indication of changes in products, processes,
  policy, procedure

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Disputes Resolution Process
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Suggested Website Disclosure

• If you have a complaint about S M or one
  of its representatives please contact S M . S
  M has a formal complaints process. If you feel
  your complaint has not been resolved to your
  satisfaction by S M, you can contact our
  independent dispute resolution provider Financial
  Dispute Resolution (www.fdr.org.nz)

www.fdr.org.nz 0508 337 337