Complaints Resolution Policy
1. Introduction and objective
July 2020 Onespark (Pty) Ltd “Onespark” is committed to a high service standard, rendering financial services with integrity, the speedy resolve of complaints and the overall improvement of processes even in the instance where a complaint may be viewed as ‘invalid’ in terms of the relevant policy wording. In this regard each and every concern counts as valuable feedback that requires addressing in a meaningful manner.
The object of this complaints resolution policy is to formalize the process in which dissatisfaction is lodged, acknowledged, investigated, resolved and leads to overall improvements.
It is furthermore important that each and every staff member receives extensive training in this regard, that this complaints resolution policy is made easily accessible to all policyholders, that this complaints resolution policy is continuously reassessed by senior management and that overall improvements are actioned as a consequence of feedback received from policyholders.
Important and guiding material/bodies include all six Treating Customers Fairly (TCF) Outcomes, theFinancial Sector Conduct Authority (FSCA) and the Policyholder Protection Rules (PPR).
Please note that TCF and PPR(especially with regards to complaints) form part of each and every employee’s annual performance evaluation report, which is to be completed prior to any potential salary increase and/or promotion.
2. the definition of a complaint
A Complaint in terms of the Policyholder Protection Rules (PPR) means an expression of dissatisfaction by a person to an insurer or, to the knowledge of the insurer, to the insurer’s service provider relating to a policy or service provided or offered by that insurer which indicates or alleges, regardless of whether such an expression of dissatisfaction is submitted together with or in relation to a policyholder query, that:
(a)
the insurer or its service provider has contravened or failed to comply with an agreement, a law, a rule, or a code of conduct which is binding on the insurer or to which it subscribes;(b)
the insurer or its service provider’s maladministration or willful or negligent action or failure to act, has caused the person harm, prejudice, distress or substantial inconvenience; or(c)
the insurer or its service provider has treated the person unfairly;Regardless whether submitted together with or in relation to a policyholder query. The Treating Customers Fairly (TCF) Outcomes include:
i)
Customers need to feel confident that TCF is central to our culture;ii)
Customers receive clear information that is timely and relevant to them;iii)
Customers receive clear information that is timely and relevant to them;iv)
Customers receive suitable product/sales advice that takes their circumstances into account;v)
Products and services perform as expected and the service is of an acceptable standard;v)
Products and services perform as expected and the service is of an acceptable standard;vi)
There are no unreasonable barriers for customers to change or switch products, claim or complain.All complaints lodged with the Ombudsman/FAIS/FSCA are to be dealt with by the Insurer, Guardrisk Life Limited “Guardrisk” (FSP 76), exclusively. All documents and information relating to such a complaint, must be sent to Guardrisk within 24 hours of receipt of the complaint.
Note that there is no fee charged for registering a complaint.
3. the definition of a complaint - who may complain?
A complainant is a person who has a direct interest in the policy/service or someone acting on behalf of a person with a direct interest in the policy/service.
For example: a policyholder/a person that pays a premium, his/her beneficiary, a policyholder’s spouse or registered dependents, a potential policyholder whose dissatisfaction relates to the relevant application, approach, solicitation, advertising or marketing material.
4. outcomes of a complaint
1.
Rejected: complaint was rejected, and the FSP regards the complaint as finalized after advising the complainant that the FSP does not intend to take any further action to resolve the complaint. A formal repudiation letter with all complaint details will be sent. There are two variations of a rejected complaint:a)
Invalid: the complainant does not accept or respond to proposals to resolve the complaint within 7 days. This includes sending relevant documentation, acting upon the advice of the FSP as well as not being able to reach the complainant via telephone, SMS and E-mail (if applicable);b)
Invalid: the complainant does not accept or respond to proposals to resolve the complaint within 7 days. This includes sending relevant documentation, acting upon the advice of the FSP as well as not being able to reach the complainant via telephone, SMS and E-mail (if applicable);1.
Upheld:complaint was successful eitheri.
Wholly (complainant got exactly what he/ she was looking for);ii.
Partially (complainant and the FSP found a middle ground).There are also two variations of a wholly or partially upheld complaint: Compensation Payment:to compensate a complainant for a proven or estimated financial loss incurred as a result of the FSP’s wrongdoing. This is either: i.
Payment Contractually due:the complainant should have received the assistance and help from the start,ofa justified complaint;ii.
Payment not Contractually due:the complainant does not have legal standing or a legal argument, however, due to the poor handling by the FSPin the form of negligence, the FSP for example refunds the complainant his/ her premiums and cancels the complainant.a)
Goodwill Payment:the complainant is not covered in terms of the policy, but the FSPis willing and able to sponsor the matter due to extraordinary circumstances.5. the categories of complaints
The below list provides an indication of the categories into which a complaint may fall;
a)
The design of a policy or related serviceb)
Information provided to the policyholders or lack of information and feedback provided to a policyholder;c)
Advice provided by the sales representative;d)
Policy performance and/or servicing including negligence;e)
Admin services such as premium collection;f)
Policy accessibility, ability to change or switchg)
Complaints handling (complaint of a complaint);h)
Complaints relating to insurance claims, such as a rejection of a merit assessment for litigation (in-Court) cover;6. how to lodge a complaint
Should you feel that any or all of the above, in terms of the above categories and TCF Outcomes, could have been better handled by the FSPor should you feel dissatisfied with any aspect of your dealings with the FSP, please lodge a complaint to:
Email: complaints@onespark.co.za Address: 76 Boundary Road, Illovo, Johannesburg, 2196 Postal Address:Client services, PO Box 2960, Randburg, 2125 When logging the complaint ensure that you include all the relevant information for a speedy resolution,this includes:
the staff member(s)involved; your case or product details; any supporting documents;and the relevant dates and times relevant to your dissatisfaction. The reason for your dissatisfaction must be clear in order for FSPto investigate diligently.
You may send your complaint to the company details provided above. Note that complaints logged using a telephone voice recording will be reduced to writing by the officer assigned to attend to your complaint
You will receive an SMS confirming that your complaint has been received and confirmation that the relevant assigned staff member will contact you telephonically within 3 working days.
7. the internal complaints handling process
Upon contacting you telephonically, the person dealing with your complaint will introduce him/ herself and:
i)
Ask you what your preferred outcome of the complaint would be? Please refer to the outcomes of a complaint mentioned in clause 4 but do not be discouraged by the terminology, the person dealing with your complaint will listen to whatever reason you have for your dissatisfaction;ii)
Answer any and all questions to the best of his/her ability;iii)
Request your availability/preferred times for follow-up calls and preferred communications medium for feedback (e-mail/ phone call/ SMS etc.);iv)
Advise you to kindly expect feedback within 7 days, alternatively 3 days where time is of the essence such as where a Court date is involved;v)
Diarize the file for 3 days to provide feedback to you but commence investigation immediately;vi)
It is important that you cooperate by providing copies of all relevant evidence and correspondence;vii)
Should the matter remain unresolved after 3 days have passed and feedback has been provided, to diarize the complaints file in order to give feedback every 14 days;viii)
You may escalate the matter internally and change the person dealing with your complaint where he/she did not attend to your complaint as per the diary period (to receive feedback/assistance) as mentioned above. Simply follow the same steps as per clause 6 and advise that you wish to escalate the matter;ix)
Should the matter be rejected as per clause 4, you will be provided with all reference numbers/information and contact numbers of the Ombud/ Regulatory Body to take the matter further against us.8. complaints escalation and review process
In the event that your matter/complaint is rejected,and you wish to escalate the matter, you may contact the Insurer directly or the matter may be escalated on your behalf:
Email: complaints@guardrisk.co.za Address:102 Rivonia Road, Sandown, Sandton, 2146 Postal Address:PO Box 786015, Sandton, 2146 Should your complaint be against Guardrisk, please lodge your complaint with the Long-term Insurance Ombudsman. The procedure for lodging a complaint may be found on the website
for the Ombud for Long-term Insurance (www.ombud.co.za) or you may obtain it directly from the Ombud at the following contact details:
Tel: (021) 657 5000| Share call: 0860 103 236 E-mail address: info@ombud.co.za Address: Third Floor, Sunclare Building, 21 Dreyer Street, Claremont, Cape Town, 7708 Postal Address: Private Bag X45,Claremont,Cape Town,7735 Should you have a complaint against the intermediary (e.g. a broker/sales person selling you the product) the complaint may be lodged with FSCA (Financial Sector Conduct Authority) online via www.fsca.co.za/Pages/Contact-Us.Alternatively, a complaint maybe logged with the FAIS Ombud. A complaint form needs to be completed, which can be downloaded from the FAIS Ombud’s website (www.faisombud.co.za). The complaints registration form is also available from the FAIS Ombud at the following contact numbers:July 20
Telephone: (012) 762 5000 / (012) 470 9080 Fax: (0860663247/(012) 348 3447 E-mail address: info@faisombud.co.za Address: Kasteel Park Office Park,Orange Building, 2nd Floor,546 Jochemus Street, Erasmus Kloof,Pretoria, 0048 Postal address: PO Box 74571, Lynnwood Ridge, 0040 Conflict of Interest Management Policy
1. background
Section 3A(2)(a) of the General Code of Conduct stipulates that every provider, other than a representative, must adopt, maintain and implement a conflict of interest management policy that complies with the provisions of the Act.
This policy is to provide for mechanisms in place atOneSpark (Pty) Ltd (“Onespark”) to identify, mitigate and manage the conflicts of interest to which OneSpark is a party. This Conflict of Interest Management Policy is designed as prescribed in Board Notice 58 of 2010 which amends the General Code of Conduct for Financial Services Providers and Representatives published in Board Notice 80 of 2003, as amended by Board Notice 43 of 2008.
This policy is to provide for mechanisms in place atOneSpark (Pty) Ltd (“Onespark”) to identify, mitigate and manage the conflicts of interest to which OneSpark is a party. This Conflict of Interest Management Policy is designed as prescribed in Board Notice 58 of 2010 which amends the General Code of Conduct for Financial Services Providers and Representatives published in Board Notice 80 of 2003, as amended by Board Notice 43 of 2008.
2. objective of the policy
This Conflict of Interest Management Policy does not change our existing conflict of management procedures but intends to document them in simple form as required by the Financial Services Conduct Authority (FSCA).
In terms of the Financial Advisory and Intermediary Services Act, 2002, OneSpark is required to maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage conflict of interest. OneSpark has put in place a policy to safeguard its clients’ interests and ensure fair treatment of clients.
All providers, key individuals, representatives, associates and administrative personnel will commit to such policy and the processes will be monitored on an ongoing basis.
OneSpark keeps and maintains a register in which all actual or potential conflicts are recorded.
3. mission statement on conflict of interest
OneSpark is committed to ensuring that all business is conducted in accordance with good business practice. To this end OneSpark conducts business in an ethical and equitable manner and in a way that safeguards the interests of all stakeholders to minimise and manage all real and potential conflicts of interests.Like any financial services provider,OneSparkis potentially exposed to conflicts of interest in relation to various activities. However, the protection of our clients’ interests is our primary concern and so our policy sets out how:
we will identify circumstances which may give rise to actual or potential conflicts of interest entailing a material risk of damage to our clients’ interests; we have established appropriate structures and systems to manage those conflicts; and we will maintain systems in an effort to prevent damage to our clients’ interests through identified conflicts of interest. 4. understanding the definitions
Conflict of interest:
A conflict of interest may occur when in rendering a financial service to you,we do not act objectively,or do not render an unbiased or fair service to you,or do not act in your interests, including but not limited to:
c)
any relationship with a third party.A financial interest:
Any cash, cash equivalent, voucher, gift, service, advantage, benefit, discount, domestic or foreign travel, hospitality, accommodation, sponsorship, valuable consideration, other incentive or valuable consideration (exceeding R1000 per annum) other than an ownership interest
Training, that is not exclusively available to a selected group of providers or representatives, on:
a)
Products and legal matters relating to those products;b)
General financial and industry information;c)
Specialised technological systems of a third party necessary for the rendering of a financial service, but excluding travel and accommodation associated with that training.An ownership interest:
Any equity or proprietary interest for which a fair value was paid on acquisition other than such an interest held by a nominee. This includes any dividend, profit share or similar benefit derived from such interest.
Fair value:
Has the meaning assigned to it in the financial reporting standards adopted or issued under the Companies Act, 61 of 1973.
5. what may e give and receive
We confirm that we will only receive financial interest from the aforesaid providers in the form of
a)
Commission authorized under the Long-term Insurance Act, 52 of 1998;b)
Fees under the a foresaid act if these fees are reasonably commensurate to the service being rendered;c)
Fees for rendering a financial service in respect of which no commission or fees are paid as aforesaid,if those fees are specifically agreed to by you in writing and may be stopped at your discretion;d)
Fees or remuneration for the rendering of a service to a third party, which fees are reasonably commensurate to the service being rendered;e)
Subject to any other law, an immaterial financial interestf)
A financial interest for which a consideration, fair value or remuneration that is reasonably commensurate to the value of the financial interest, is paid at the time of receipt thereof.6. remuneration policy
In terms of our remuneration policy, a portion of premiums paid by clients is retained by us and covers the running costs of the company. We may, potentially, receive more than 30% from one product provider.
7. remuneration policy
Identification of Conflict of Interest
To adequately manage conflicts of interest we must identify all relevant conflicts timeously. In determining whether there is or may be a conflict of interest to which the policy applies, OneSpark considers whether there is a material risk of damage to the client, taking into account whether OneSpark or its representatives, associatesor employees:
are likely to make a financial gain, or avoid a financial loss, at the expense of the client; have an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client's interest in that outcome; have a financial or other incentive to favour the interest of another client, group of clients or any other third party over the interests of the client; receive or will receive from a person other than the client, an inducement in relation to a service provided to the client in the form of monies, goods or services, other than the legislated commission or reasonable fee for that service Our policy defines possible conflicts of interest as, inter alia:
conflicts of interest between OneSpark and the client; conflicts of interest between our clients,if we are acting for different clients,and the different interest's conflict materially; conflicts of interest where associates, product suppliers, distribution channels or any other third party is involved in the rendering of a financial service to a client; OneSpark maintains an index of potential conflict risks, taking into consideration all business areas and income streams. The index is updated with all new conflicts identified, and to ensure completeness,is reviewed on an annual basis.Apart from the register of actual conflict of interests, record is kept of potential conflicts of interest and closely monitored by the Key Individual.
All employees, including internal compliance officers and management, are responsible for identifying specific instances of conflict and are required to notify the Key Individual of any conflicts they become aware of. The Key Individual will assess the implications of the conflict and how the conflict should be managed and act impartially to avoid a material risk of harming clients’ interests.
8. measurement for avoidance and mitigation of conflict of issues
Create awareness and knowledge of applicable stipulations of the General Code of Conduct and relevant legislation relating to conflict of interest, through training and educational material. Ensure understanding and adoption of the conflict of interest policy and management measures by all employees, representatives and associates Regular inspections on all commissions, remuneration, fees and financial interests proposed or received in order to avoid non-compliance. Keep a register of conflicts of interest. Once a conflict of interest has been identified it needs to be appropriately and adequately managed. The Key Individual will assess each conflict, including whether the conflict is actual or perceived, what the value of the conflict or exposure is and the potential reputational risk. Compliance and management then agree on the controls that need to be put in place to manage the conflict. a)
Disclosure:
Where there is no other way of managing a conflict, or where the measures in place do not sufficiently protect clients’ interests, the conflict must be disclosed to allow clients to make an informed decision on whether to continue using our service in the situation concerned. In all cases, where appropriate and where determinable, the monetary value of non-cash inducements will be disclosed to clients via the disclosure letters (Letters of Introduction).a)
Publication:
We will publish our conflict of interest management policy in appropriate media and ensure that it is easily accessible for public inspection at all reasonable times. The Conflict of Interest Management policy is available in hard copy in the compliance file and is stored electronically on the server.A copy will be provided on the client’s request and may be requested by any client or member of staff from the Key Individual.a)
Declining to act:
We may decline to act for a client in cases where we believe the conflict of interest cannot be managed in any other way.9. ongoing monitoring of conflict of interest management
This policy will be reviewed annually, and must be included in our annual FSCA compliance report, containing details “...on at least the implementation, monitoring and compliance with, and the accessibility of the conflict of interest management policy.”
The Key Individual is responsible for supervision and monitoring of this policy as well as the process to be followed, for example,inspection of new business transactions, client interviews, discussion with product providers,etc.The Key Individual will, in consultation with other relevant persons,regularly monitor and assess all related matters.
10. training and staff
All employees and representatives are required to read Board Notice 58 of 2010 as well as this policy and to sign a statement to the effect that they have done so and fully understand the provisions of both documents and the application thereof.Comprehensive training on the Conflict of Interest policy will be provided to all employees and representatives as part of general FAIS training or specifically.
Training will be incorporated as part of all new appointees’ induction and refresher training provided on an annual basis.
The Key Individual will conduct ad hoc checks on business transactions to ensure the policy has been complied with. They will be implementing a detailed Operational Monitoring Process which will include all FSP policies and procedures.
The Compliance Officer will include monitoring of the Conflict of Interest policy as part of their general monitoring duties and will report thereon in the annual compliance report. Non-compliance will be subject to disciplinary procedures in terms of FAIS and employment conditions and can ultimately result in debarment or dismissal as applicable. Avoidance, limitation or circumvention of this policy via an associate will be deemed non-compliance
This policy shall be reviewed annually and updated if applicable.
11.representative incentives
We confirm we will not offer any financial interest to our Key Individuals or Representatives for:
a)
favouring quantity of business over quality of service; orb)
giving preference to a specific product supplier where more than one supplier canc)
be recommended to a client; ord)
giving preference to a specific product of a supplier where more than one product of that supplier can be recommended.12.representative incentives
With regard to existing third-party relationships, being our product suppliers, we confirm that we do not have an ownership interest or are subject to exclusive training nor are there any other circumstances which could lead to a potential conflict of interest. Should any conflicts arise with regard to any of these prior to entering into any business transaction with you we undertake to disclose these in the registers below. OneSpark has implemented the following registers:
1.
Nature and Extent of Ownership interests2.
Financial Interest Received3.
Nature and Extent of Business RelationshipsTreating Customers Fairly Policy (TCF)
1. Introduction
At OneSpark, our focus on client centricity has become deeply ingrained in our business philosophy, ethos and culture. This focus is boldly evidenced through the incorporation and embedding of the principles of Treating Customers Fairly (“TCF”) in the end-to-end client value chain.
OneSpark recognises that each intermediary is a key contributor in sustaining long-term growth requiring a client centric focus and a service orientated culture geared toward customer satisfaction at all times. The responsibility in ensuring that the principles of TCF are practiced at all times, in any form of customer engagement vests with every employee within OneSpark and each partner that we contract with. We are a client centric business with the end customer being at the forefront of all decisions and product development.
2. OneSpark’s Operating model, Mission, Purpose and Values
OneSpark is a client-centric business, everything we do focuses on how we can better serve the end-client. The financial wellness of our clients remains our strategy and purpose. However, especially in the current trading environment, OneSpark can differentiate itself by materially improving customers’ experience and implementing our strategic actions with agility.
‘To continuously innovate for the betterment of our clients and the pursuit of a better world.’
‘To move the global insurance industry forward, one step at a time.’
‘To move the global insurance industry forward, one step at a time.’
We build products we believe in and care about what we do We put our client’s best interests at the heart of every decision We focus on excellence in the little, so that the little becomes a lot We are here to make a positive difference in society We care for and develop our staff to their full potential We are dreamers and encourage the impossible We build when others don’t We believe that each individual has the power to change the world 3. Regulatory Requirements
The Financial Services Conduct Authority (FSCA), previously known as the FSB, published the TCF Roadmap in 2011, which formed the basis of the TCF framework. All organisations, specifically those authorised under the FSCA, are required to embed the TCF principles in governance processes, frameworks and furthermore to demonstrate that they measure their behaviour against these key principles, to manage conduct risks and protect their customers. The six TCF principles have been adopted within OneSpark across all business practices, governance frameworks and day-to-day processes.
Outcome 1
Policyholders can be confident that they are dealing with a product provider where the fair treatment of policyholders is central to the product provider’s culture.Outcome 2
Products are designed to meet the needs of identified types, kinds or categories of policyholders and are targeted accordinglyOutcome 3
Policyholders are given clear information and are kept appropriately informed before, during and after the time of entering into a policy.Outcome 4
Where policyholders receive advice, the advice is suitable and takes account of their circumstances.Outcome 5
Policyholders are provided with products that perform as product providers or their representatives have led them to expect, and the associated service is both of an acceptable standard and what they have been led to expect; andOutcome 6
Policyholders are provided with products that perform as product providers or their representatives have led them to expect, and the associated service is both of an acceptable standard and what they have been led to expect; andOutcome 7
Policyholders do not face unreasonable post-sale barriers to change or replace a policy, submit a claim or make a complaint.4. OneSpark TCF Standard per Outcome
OUTCOME 1 - CULTURE
Policyholders can be confident that they are dealing with an insurer where the fair treatment of policyholders is central to the insurer’s culture.
To ensure that OneSpark’s business practices are fully governed with a culture of TCF, OneSpark’s Board of Directors have adopted the TCF framework and are specifically responsible to ensure that it is embedded throughout the DNA of our organisation. Our organisation has formalized the requirements of TCF through a TCF Framework supported by robust governance structures and frameworks. Every business unit within OneSpark is required to adopt the OneSpark TCF Framework and embedded practices. In addition, business is required to measure themselves against a stringent set of standards set out in the OneSpark TCF Self-Assessment tool, which aligns to the FSCA Self-Assessment Questionnaire. The results of the TCF Assessment will be shared with all relevant overarching TCF governance structures to ensure that business not only understands how they fare against the standards but are also able to identify conduct risk associated with their practices and remedy this to improve poor customer outcomes that may result due to poor conduct or lack of oversight. The elements which make up the OneSpark TCF Framework are as follows:
TCF Training and Awareness Programmes TCF Self-Assessment Template and automated implementation plan New Business / Onboarding Assessment Template TCF Key Fairness Indicators TCF Scorecard Measurements To ensure that TCF is firmly embedded within OneSpark, a combined assurance approach will be followed to give the regulatory authorities, the shareholders, the board and executive management of OneSpark the comfort that TCF practices are established and embedded within OneSpark.
OneSpark is also committed to ensuring that we have regular, accurate, reliable data exchanges with our insurer which will allow them to proactively scrutinize management information to identify possible instances of poor customer outcomes and to then mitigate them.
OUTCOME 2 – PRODUCTS & SERVICES
Products are designed to meet the needs of identified types, kinds or categories of policyholders and are targeted accordingly.
Rigorous reviews and due diligence is conducted within OneSpark to ensure that when a target market is selected for distribution of our products, all environmental, circumstantial and financial factors are duly considered before proceeding with approval of product design, product development or defining pricing models. All new product developments, material changes to existing products and/or pricing must be ratified by the TCF committee, which will sign off whether the changes or products are deemed to have been TCF.
OUTCOME 3 – POINT OF SALE
Policyholders are given clear information and are kept appropriately informed before, during and after the time of entering into a policy
OneSpark subscribes to the most rigorous standards in relation to “disclosures” as per the Policyholder Protection Rules of the Long-Term Insurance requirements and we have documented procedures and minimum requirements to ensure all stakeholders align with same. In addition, FAIS and the General Codes of Conduct associated with various categories of licenses also governs OneSpark’s way of engagement with our customers in relation to transparency and disclosures through the policy life cycle with the organization.
OUTCOME 4 – ADVICE
Where policyholders receive advice, the advice is suitable and takes account of their circumstances
OneSpark’s call centre Representatives will not be giving advice – they will only be performing intermediary functions and will only give factual information to clients. If clients need more information or advice in certain cases, they can be referred to the Key Individual and thereafter as the business matures, we will start to train a few Representatives under supervision of our Key Individual to give advice.
When OneSpark’s Representatives start to give advice, they must always understand the client’s needs and their financial situation, to ensure that they are able to make appropriate recommendations to their clients in relation to the most appropriate risk solutions for their business. We have put robust training material and training programmes in place to ensure that our Representatives who provide advice to customers understand what their obligations are. This is done in accordance with section 8 of the FAIS Act to satisfy ourselves that our Representatives meet the FAIS product knowledge competency requirements and have the operational and technological infrastructure to support the advice process
OUTCOME 5 – PRODUCT & SERVICE PERFORMANCE
Policyholders are provided with products that perform as insurers or their representatives have led them to expect, and the associated service is both of an acceptable standard and what they have been led to expect
Product Design & Product Performance Management
At OneSpark, we have technical teams that are tasked with ensuring that all potential risks in relation to the products sold through OneSpark on our Product Providers license are identified, rectified and tracked proactively within the organization.
Marketing
To ensure that customers are not provided with misleading information or misrepresented facts, guidance documents (training materials) have been developed for our Representatives. A firm sign off processes has also been put in place to ensure that disclosures and product related marketing material is reviewed objectively by OneSpark, to ensure that the material is appropriate and that the average targeted policyholders would not be misled by the information provided.
Governance
OneSpark has implemented processes which facilitate the implementation of the TCF principles. These processes also ensure that the fair treatment of customers is prioritized and always at the forefront of staff’s mindset. OneSpark ensures that products are appropriately governed throughout the life cycle of all products. TCF principles are firmly tested and embedded before developing, amending or introducing a new product or service into the marketplace.
TCF implementation is decentralized and delegated to each business segment within OneSpark to ensure that TCF is embedded throughout the lifecycle of products offered on our licenses. Management information relating to claims, complaints and other key fairness indicators is monitored and reported on a monthly basis to ensure that the principles of TCF are tracked and monitored rigorously within OneSpark to manage and mitigate conduct risk
Quality Assurance on service levels and performance scorecards
Service requirements will be built into all performance management scorecards to ensure that higher service levels are implemented, maintained, tracked and monitored. Market Conduct standards are reviewed constantly, especially where trends of poor customer treatment are identified with specific types of products or services.
OUTCOME 6 – POST SALES BARRIERS
Policyholders do not face unreasonable post-sale barriers to change or replace a policy, submit a claim or make a complaint
At OneSpark, we believe that our customer experience throughout their journey must be of a standard and quality which does not prejudice the customer in any manner whatsoever. We have committed to developing strong overarching governance frameworks which detail the standards and requirements related to claims or complaints in relation to products originally selected.
Within the OneSpark Claims and Complaints departments, we also have strong governance and review processes to ensure that customers are not treated unfairly when dealing with our agents. Furthermore, we are fully transparent with our customers and ensure that we provide suitable channels for customers to contact us if they have complaints or queries. In addition, we monitor claims and complaint data to ensure that agreed turnaround times and minimum service standards are adhered to.
Should you wish to register a complaint, which may have caused you damage or prejudice, against one of our representatives or staff, please contact our Complaints Manager on 072 461 7151, or alternatively in writing to our Key Individual at:
PO Box 2960, Randburg, 2125
A copy of OneSparks complaints procedure is available on request or on our website.
We are committed to ensuring that we continuously monitor management information relating to complaints, claims and switching processes to identify trends of poor customer treatment and to implement corrective measures to ensure that clients do not face any post sales barriers when dealing with OneSpark or our stakeholders.
4. Governance of this Policy
OneSpark views any non-compliance to this policy as well as any non-compliance with its obligations in terms of legislation in a serious light. Any deliberate action by an employee to contravene the above will be subject to disciplinary action. All instances of non-compliance with this policy will be included within the regular risk reporting process.
This Policy will be reviewed by the Market Conduct Manager on an annual basis and submitted for approval to OneSpark’s Exco, as deemed necessary.
