COMLAINTS MANAGEMENT POLICY AND PROCEDURE

Purpose and Objective

Universal Life aims to continuously improve the services provided to its clients. Effective complaints management is fundamental to the provision of quality services and provides a platform for obtaining feedback from its clients with the purpose of resolving disputes and reforming policies and procedures.

For this purpose, Universal Life has developed and established a Complaints Management Policy, which is designed to provide guidance on the way in which the Company receives and manages complaints. The application of this policy will ensure that complaints received are dealt with fairly, promptly and in an efficient and confidential manner.

Policy Statement

Universal Life through this policy is committed to effectively manage complaints promptly and fairly, ensuring that:

• Your complaints will be investigated in depth, will be handled in an efficient and effective manner and you will be treated courteously.
• We will be fair both to you and any employee or insurance intermediary for whom a complaint may refer to.
• We will not charge you for making a complaint.
• Our Complaints Management Policy will always be available on our website www.universallife.com.cy.
• We will always observe privacy and confidentiality of any personal data, in line with the European Union directives and the “Processing of Personal data (Protection of Individuals) Law of 2001”.
• We will record and analyse complaints on a regular basis for the identification and rectification of erroneous procedures and practices as well as for the avoidance of recurring omissions.
• Any individual involved in the complaint or responsible for the management of the complaint will not participate in the investigation process should there be conflict of interest.
• Our employees will undergo continuous training on the Complaint Management Policy and will have direct access to related documentation in order to facilitate the effective handling of complaints.
• Our Board of Directors, Management, Employees and Insurance Intermediaries acknowledge your right to file a complaint and are committed to the efficient and fair resolution of complaints or problems that may arise from the services we provide.

Review of the Complaints Management Policy

The complaints management system included in this Policy and internal procedures will be reviewed periodically (at least annually) aiming to
enhance the transparency, efficiency and the greatest possible satisfaction of the clients of Universal Life.

Complaints Procedure/Lodging a Complaint

1.    Who can file a complaint

Any complaint can be submitted by the Owner of an individual or group Policy. Also any member or insured person or  covered person of any  Policy, can submit a complaint provided that the Owner of the Policy is notified (in case of group the company or organization). We are oblidged to discuss any complaint with the Owner of the Policy.

2.    First point of contact

Should you worry about any aspect of the services we offer, your first point of contact should be your Insurance Intermediary or our Head Office.

3.    Complaints procedure steps

If you find it necessary to pursue the matter further, you should submit a formal complaint letter (by regular mail or electronic mail) addressed to:

Complaints Management Officer

Universal Life

P.O.Box 21270

505 Nicosia

Cyprus

email: complaints@unilife.com.cy

who will investigate the matter independently.

Having received a reply from the Complaints Management Officer and if you are still not satisfied with the way in which your complaint has been handled, you may then write to:

General Manager - Insurance Operations

Universal Life

P.O.Box 21270

1505 Nicosia

Cyprus

We strongly recommend that you make any formal complaint in writing in order to protect your interests. This will support our objective of ensuring any complaints received are dealt with fairly, promptly, efficiently and in confidence.

We expect from you:

 - To indicate your policy/membership number as well as your full contact details

 - To describe your complaint clearly and accurately

 - To be specific with respect to the reasons for which you are filing a complaint

 - To mention your expectations clearly, in regards to the resolution of the issue

4.    Response timeframes in complaints handling

       If your complaint can not be resolved immediately, its investigation will go through the following timeframes: 

- Acknowledgement of your complaint within 2 working days of receipt.

- Your complaint will be addressed within 15 working days. A relevant response will be sent immediately.

- On rare occasions where more time is required for the proper and detailed investigation of your complaint, an extension period will be requested in writing. In our letter, besides any additional information that we may request, we will inform you of our actions taken so far and any further actions required for the completion of the investigation.

- Our aim is to ensure that you receive our final response within 10 working days from the time of the extension notification or the receipt of any extra information requested from you.

5.    Status update request

Should you wish to request an update at any stage of the complaint investigation, you can do so by contacting the Complaints Management Officer.  

6.    If you are still not satisfied 

If you continue to be dissatisfied you can request for an arbitration or to refer your complaint to the Financial Ombudsman.

For arbitration we will refer your complaint to an independent arbitrator or to an arbitrator upon which we jointly agree, but who will not be a member of Universal Life or AXA PPP healthcare (in case of a Policy under the MultiCare International Health Plan) or their associated companies. Arbitration will take place in Cyprus and the decision of the arbitrator will be binding on both parties.  The same right of referring a complaint to arbitration can be exercised by Universal Life. For MultiCare Policies, the relevant decision will be made by the Director – International Markets, AXA PPP healthcare.

For any referral to the Financial Ombudsman, you can find more details in the website www.financialombudsman.gov.cy.  For your convenience, we have uploaded summary information in the link “FINANCIAL OMBUDSMAN – BASIC FACTS ON THE COMPLAINT REFERRAL PROCEDURE”, in which you can find a mongst other who is eligible to apply/refer a complaint, how to apply and what are the prerequisites that should be met for a complaint to be valid. 

Your right to legal action

None of the above affects your right to take legal action except in the case of your complaint being referred to arbitration or, under specific ircumstances to the Financial Ombudsman.