Complaints Policy and Procedure

Updated: 1 September 2022

Our passion for the fair treatment of all our customers governs everything we do and drives our mission to provide our corporate and individual customers with world-class insurance solutions which are relevant, appropriate, and fairly priced, supported by our first-class service. There may, however, be occasions when you feel you have not received the service you expect from us and/or our insurance partners. We want to hear about these experiences so that we can continually improve our customer service.  

The complaints process that applies depends on whether your complaint is regarding: 

  • service and/or administration service of an insurance solution provided by Unisure Limited or a Unisure Group Company (“Unisure”); and/or

  • in relation to a product and/or a claims adjudication of one of our insurance partners.

    Please see the table below:

Complaint

Complaint Registration

Resolution

External Resolution

Service

Service provided by Unisure

Unisure

UK Financial Ombudsman

Product and/or claims adjudication

UK Group Life issued by Quantum Leben

Quantum Leben

Financial Markets Authority Liechtenstein (FMA)  https://www.fma-li.li/en/ 

Medical or General Insurance Policy issued by Guardrisk Insurance Company Mauritius 

Or 

A Life Assurance Policy issued by Guardrisk Life International Limited

Guardrisk Insurance Company 

Or  

Guardrisk Life International Limited 

Office of Ombudsperson for Financial Services Mauritius  

Life Assurance policy issued by Best Meridian Insurance (BMI)

Best Meridian Insurance 

Service

Complaint
Service provided by Unisure
Complaint Registration Unisure complaints@unisuregroup.com
Resolution Unisure
External Resolution
UK Financial Ombudsman

Product and/or claims adjudication

Complaint 

UK Group Life issued by Quantum Leben

Complaint Registration Unisure complaints@unisuregroup.com

Resolution Quantum Leben

External Resolution

Financial Markets Authority Liechtenstein (FMA)  https://www.fma-li.li/en/

Complaint

Medical or General Insurance Policy issued by Guardrisk Insurance Company Mauritius  Or  A Life Assurance Policy issued by Guardrisk Life International Limited

Complaint Registration Unisure complaints@unisuregroup.com

Resolution

Guardrisk Insurance Company Or  Guardrisk Life International Limited

External Resolution
Office of Ombudsperson for Financial Services Mauritius https://www.fscmauritius.org/en/consumer-protection/complaints-handling 

Complaint

Life Assurance policy issued by Best Meridian Insurance (BMI)

Complaint Registration Unisure complaints@unisuregroup.com

Resolution

Best Meridian Insurance

  1. The Unisure Complaints Process

    1. Objective

      The objective of our Complaints Policy is to resolve all complaints quickly and fairly, wherever possible without recourse to formal investigations or external bodies.  We therefore aim to ensure that: 

      1. There is a clear and fair procedure for any customers who wish to make a complaint about Unisure or its Group Companies, our activities, our insurance solutions, our customer service or about our employees and/or contractors;

      2. Making a complaint is a simple process, following a well-documented, easily understood procedure;

      3. Everyone working with or for us knows how to handle complaints made by our customers;

      4. All complaints are handled timeously, equally and fairly; and

      5. We learn from complaints to improve our service and avoid situations being repeated in the future.

    2. Unisure’s definition of a complaint

      We define a complaint as a situation or instance where either an individual or organisation considers the solution and/or service provided by Unisure Limited to have fallen short of their reasonable expectations, and wishes to express their dissatisfaction. 

      Complaints may relate to any of our activities and may include (but not be limited to):
       
      1. The quality of customer service you have received from us;

      2. The behaviour and/or professional competence of our employees and contractors;

      3. Delays or other problems associated with our administration of insurance solutions; and

      4. Delays or other problems associated with the provision of services.

        The following scenarios are not complaints and should therefore be addressed accordingly: 

      5. General queries about our administration of insurance solutions and/or services should be directed to info@unisuregroup.com;

      6. Formal requests for the disclosure of information, for example, under Data Protection legislation. For more information on data subject requests, please refer to our Data Protection Policy; and 

      7. Matters concerning contractual or other legal disputes.

    3. How Unisure handles complaints

      Our aim is to always resolve complaints to your satisfaction without further recourse to external resolution. If you are not satisfied with the resolution of your complaint, we will inform you of the next steps you should take for external resolution with the applicable regulatory authority responsible for supervision of the solution or service to which your complaint relates.

       

    4. Registering a Complaint with Unisure

      All complaints in relation to Unisure should be registered by email to complaints@unisuregroup.com  and should include the following details:

      1. Your full name, address, telephone number and email address. All formal communication related to your complaint will be via email.

      2. If you are making a complaint on behalf of someone else, please include that person’s name and contact details, as well as your own.

      3. If you are making a complaint about a particular transaction, include the Customer Reference Number (Policy Number/Quote Number/Claim Number/Other Reference).

      4. If you are making a complaint about an employee or contractor, include the name and, where appropriate, position of that employee or contractor.

      5. Full details of your complaint, including details of all applicable times, dates, events, and people involved.

      6. Any supporting documents or other evidence you feel is applicable or relevant in support of your complaint.

      7. Details of what you would like us to do to resolve your complaint.

      8. You should understand that while we will make every reasonable effort to accommodate such requests, we are not bound to take any action beyond our contractual or legal obligations.

    5. The Unisure Complaints Process Timings

      The response times below apply to registered complaints in relation to Unisure only. We will only register a complaint as received once we have sufficient information from you to conduct an effective investigation to resolve your complaint. 

      We will acknowledge the registration of your complaint within three working days of receiving it and provide you with a Complaints Reference. 

      1. We will inform you who will handle your complaint and with which entity it relates to. This may be the person to whom you directed your complaint, or we may delegate the task to an appropriate member of our team. Please contact this person if you wish to check on the progress of your complaint.

      2. If your complaint relates to a specific employee or contractor, we will inform them of your complaint and give them a fair and reasonable opportunity to respond. Until your complaint has been resolved, please do not contact that employee or contractor directly; all communication concerning your complaint should only take place through the person handling it.

      3. We may ask you for further information, clarification or evidence to assist us with our investigation. If we do, we ask that you provide this as soon as possible to avoid delays. If you are unable to provide this for any reason, we will use all reasonable efforts to proceed without it.  

      4. Once we have registered your complaint, we will fully investigate the matter you have brought to our attention.

      5. We aim to provide a resolution to complaints within 15 working days. If we are unable to complete our investigation in this period of time, we will write to you informing you of the progress we have made.

      6. We will write to you within 30 working days of receiving your complaint with the results of our investigation, our conclusions from that investigation, and any action taken as a result.

    6. Unisure Complaints Process External Resolution

      If we cannot settle your complaint within 30 working days, or you are not satisfied with our proposed resolution to your complaint, you have the right to seek external resolution.

      Financial Ombudsperson Service (United Kingdom)

      If we cannot settle your complaint within 30 working days, or you are not satisfied with our proposed resolution to your complaint and if your complaint relates to a premium transaction, claims handling or other service interaction with Unisure Limited, you may lodge a complaint to the Financial Ombudsperson Service (United Kingdom). 

      By Phone

      020 7964 1000 (FOS Switchboard)

      0300 123 9123 (within the United Kingdom) 
      +44 20 7964 0500 (outside the United Kingdom)
      020 7964 1001 (FOS Fax number)

      By email 
      complaint.info@financial-ombudsman.org.uk

      Online
      https://www.financial-ombudsman.org.uk/contact-us/complain-online

      Social Media 

      Send a Direct Message to FOS on 

      Facebook 
       
      https://www.facebook.com/financialombuds

       
      https://x.com/financialombuds

    7. Unisure Confidentiality and Data Protection

      All complaints and related information are treated with the utmost confidence and will only be shared with those who need to know to effectively handle your complaint. We may ask for your permission to use anonymised details (that is, information with your personal details removed) of your complaint for internal training and quality improvement purposes. All personal information that we may collect (including, but not limited to, your name and address) will be collected, used and held in accordance with the provisions of Data Protection legislation. 

  2. Complaints in relation to our insurance partners and/or complaints regarding claims adjudication conducted by our insurance partners

    Please refer to the table at the beginning of this Policy for guidance on the insurance partner responsible for the product and/or claims adjudication to which your complaint relates.

    All complaints in relation to our insurance partners and/or claims adjudication conducted by our insurance partners must be first registered with Unisure complaints@unisuregroup.com.

    Please provide the following information:

    1. Your full name, address, telephone number and email address. All formal communication related to your complaint will be via email. 
       
    2. If you are making a complaint on behalf of someone else, please include that person’s name and contact details, as well as your own.

    3. If you are making a complaint about a particular product and/or claims adjudication, include the Customer Reference Number (Policy Number/Quote Number/Claim Number/Other Reference).

    4. If you are making a complaint about an employee or contractor of our insurance partners, include the name and, where appropriate, position of that employee or contractor.

    5. Full details of your complaint, including details of all applicable times, dates, events, and people involved.

    6. Any supporting documents or other evidence you feel is applicable or relevant in support of your complaint.

    7. Details of what you would like our insurance partner to do to resolve your complaint.

    We will acknowledge the registration of your complaint within three working days of receiving it and provide you with a Complaints Reference.  

    We will advise our insurance partners of your complaint and you will then be advised by our insurance partners of their own complaints process and how to conduct a complaint. 

    We may at the request of the insurance partner, continue to correspond with you on their behalf. 

  3. External Resolution

    Please refer to the table at the beginning of this Policy for guidance on the regulatory authority responsible for supervision of the insurance partner to whom your complaint relates. If you are unsure, we will advise you which regulatory authority you should contact to escalate your complaint.

    Quantum Leben – Lichtenstein

    There are a number of competent authorities in Lichtenstein:

    1. The Financial Market Authority (“FMA”)

      The FMA is responsible for supervision and enforcement of the Financial Market Authority Act (FMA Act, FMAG) and of the laws and associated implementing ordinances listed in article 5(1) FMAG. It is especially  competent in the following cases: 

      1. violations of supervision law by supervised financial intermediaries or TT service providers (e.g., failure to meet a permanent licensing condition)

      2. deficits requiring measures under supervision law; 

      3. monitoring of the licensing or registration obligation and the prohibition of activities subject to a licence or registration on a professional basis by non-licensed persons (combating abuse);

      4. monitoring of the proper use of protected designations (e.g., the title of “professional trustee”).

    2. The Conciliation Board

      In what cases is the Conciliation Board the competent authority?

      1. The extrajudicial Conciliation Board is responsible for settling disputes under civil law between clients and banks, investment firms, asset management companies, payment service providers, trust companies, and other financial intermediaries.

      2. Its task is to mediate between the parties and to bring about an amicable settlement. If no settlement is reached, the parties are referred to the courts.

    3. The Professional Ethics Committee

      In what cases is the Professional Ethics Committee the competent authority?

      1. The Professional Ethics Committee is responsible for exercising disciplinary power over professional trustees and trust companies if they violate the code of conduct (articles 68 et seq. of the Professional Trustees Act). The Professional Ethics Committee imposes disciplinary penalties and orders interim measures. The investigator, who performs the function of a prosecutor for the Professional Ethics Committee, is competent to receive complaints.

    4. How should complaints be filed with the FMA?

      1. The FMA recommends filing complaints in writing by way of a letter or email. To ensure efficient processing, the complaint should contain the following information:Concerning the person filing the complaint:

      2. first and last name;

      3. contact information (address, telephone number, email address).Concerning the involved persons:

      4. first and last name or business name of the supervised financial intermediary or other person or entity;

      5. address;

      6. type of relationship (client, interested person, etc.).Concerning the content (what is the complaint about?)

      7. description of the facts;

      8. reason for the complaint;

      9. any supporting documents (correspondence, account and custody account statements, contracts, investor profile, product information, advertising materials, etc.). Note: copies, no originals.Date and signature. Complaints to the FMA must be addressed to:

        Email: info@fma-li.li

        Postal address:

        Financial Market Authority Liechtenstein
        Landstrasse 109
        P.O. Box 279
        9490 Vaduz
        Liechtenstein 

  4. Guardrisk Insurance Company and Guardrisk Life International Limited

    1. Your name and address;

    2. The name and address of the financial institution against which you have made the complaint;

    3. The nature of the complaint and the fact and circumstances giving rise to the complaint;

    4. The relief sought;

    5. A written declaration to the effect that the complaint was made, with evidence of delivery, and that you have sufficient interest in the subject matter of the complaint;

    6. A declaration as to whether the financial institution replied to your complaint;

    7. A copy of the reply, if any, from the relevant financial institution to which the complaint was made; and

    8. A copy of the documents on which you propose to rely.

      The contact details of the Office of the Ombudsperson for Financial Services are as follows:

      Office of Ombudsperson for Financial Services

      8th Floor, SICOM Tower
      Wall Street
      Ebene 72201
      Mauritius

      Tel: +230 468 6475
      Fax: +230 468 6473
      Email: ombudspersonfs@myt.mu

  5. Best Meridian Insurance

    The Cayman Islands Monetary Authority is responsible for complaints connected with the operations or management of licensees (or persons operating without a proper licence) should be directed to the Deputy Managing Director – Supervision, Mrs. Anna McLean.

    How to File a Complaint

    All documents can be submitted by any of the following means: 

    Online. Refer to above instructions or complete the form below; or

    Hand delivered to the receptionist at SIX, Cricket Square, George Town, Cayman Islands; and/or   

    Post:
    P.O. Box 10052
    Grand Cayman KY1-1001
    Cayman Islands   

    The Authority will acknowledge receipt of the complaint within five working days.
     

  6. Questions and Further Information

    If you require further information about any aspect of our Complaints Policy and Procedure, please contact us by email at complaints@unisuregroup.com.

  7. Policy Responsibility and Review

    Senior Management of Unisure Limited are responsible for this Complaints Policy and Procedure and its implementation.

    This Complaints Policy and Procedure was last reviewed on 1 September 2022 and will next be reviewed on 31 August 2023, unless it is appropriate it be reviewed and updated prior to that date.