Applied Financial Lines® Complaints Procedure

We take complaints very seriously and would ask that you follow the procedure outlined below if you need to make a complaint to or about us.

What is a complaint

A complaint is any oral or written expression of dissatisfaction, whether justified or not…about the provision of, or failure to provide, a financial service where the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience. Informal steps to correct a specific problem are not considered a complaint, provided the problem is resolved as part of the registrant’s normal activities and the consumer has not filed a complaint.

Eligible Complainant

Eligible complainants are entitled to submit a request to Applied Financial Lines® and/or the Autorité des Marchés Financiers (“AMF Ombudsman”)should they remain dissatisfied with the decision.

Eligible complainants include policyholders who are private individuals and businesses with an annual turnover of less than EUR € 2,000,000 and less than ten employees.

Under the Applied Financial Lines and AMF Ombudsman Service schemes, there are no restrictions to an eligible complainant’s domicile, however more specific local rules and schemes may be applicable.

We will comply at all times with the complaints handling procedures mandated or recommended by local or national law or regulation.

For All Assureds

If for any reason, you feel that we have failed to meet the high standards that we have set ourselves, we would like to know and would encourage you to follow the complaints procedure set forth below.

Firstly, raise the issue either orally or in writing with the person at your broker’s office dealing with your insurance. If you have obtained your insurance through a broker and your complaint relates to their services, please contact your broker. Within five business days of receipt by your broker your broker should have sent you a written acknowledgement advising you of the person who will be addressing your concerns.

Within twenty business days of receipt of your complaint we will provide you or your advisers with a written response unless the matter is sufficiently complicated to require further investigation, in which case we will advise you or your advisers of this in writing, with an explanation of why we cannot yet make a determination. We will also advise you or your advisers of when you may expect our final response.

None of the above procedure in any way affects your right to obtain legal advice or assistance or to seek assistance from your local insurance regulator.

Claims Specific Complaints

If a complaint, as earlier defined, is received relating to any aspect of the claims handling procedure the following steps should be followed:

• The Claims Director and Claims Manager should be notified immediately of the details of the complaint. Contact details for both individuals may be found on our team page on this website.

• The Claims Director and/or Claims Manager will be responsible for issuing a formal response to the complainant. This process should be carried out within a reasonable timescale depending on the nature and complexity of the claim.

Please Note: If the complaint is made by, or on behalf of, an eligible complainant domiciled in the EU, Applied Financial Lines procedures require the formal response is issued within two weeks of the complaint’s initial receipt. For an eligible Applied Financial Lines complainant, if it is likely that after eight weeks the complaint will still not be resolved then a further letter should be sent to the complainant. At this point the complainant must be advised of their rights, as a possible eligible complainant, to further the complaint either to Applied Financial Lines Policyholder and Market Assistance Department, if they have not already been involved in the complaints process, or the AMF Ombudsman Service.

Investigation Requirements

The complaint will be handled by the Claims Director and Claims Manager for review. The review shall consist of an initial file review followed by communication with underwriters, claims staff, brokers, adjusters, professional advisers and others as the reviewer may consider necessary. The results of the review should be documented.

The Claims Director and/or Claims Manager will be responsible for issuing a formal response to the complainant. This process should be carried out within a reasonable timescale depending on the nature and complexity of the claim.

During the course of any investigation the parties shall take all reasonable steps to ensure that the complaint is handled with due care and diligence and that the complainant is kept informed of progress. Should an agreed course of action not be reached during this process then the final decision will rest with the Managing Director.

Applied Financial Lines or the AMF Ombudsman Service choose to carry out an independent review of the complaint and make a subsequent file request, the Compliance Officer and/or the Claims Director shall endeavour to promptly provide the following documentation.

• Copies of all relevant files, papers, reports, notes of meeting and any other information which may be requested.

• Responses to complainant to date.

• Full assistance and cooperation with the investigation.

Useful Contacts

A number of useful contacts can be found below, if you require details of a specific contact please visit the team page of our website and a member of our team will endeavour to provide that contact if we are able to do so.

• Full contact details for Applied Financial Lines can be found within our contact us section on this website.

• The AMF Ombudsman Service website provides information on complaints procedures within the financial services industry.