COMPLAINTS POLICY

(Standing Operating Procedure)

Date Issued: 31^st May 2013

Review Date: 31^st May 2015

COMPLAINTS POLICY

Introduction

Complaints are a source of customer feedback that provides an indicator that an area of the business is not operating to the satisfaction of the customers. They are an opportunity to improve performance.

Effective and prompt analysis of the root causes of complaints combined with a commitment to remedy these causes can help to drive improvement and ensure fairer treatment to current and future customers.

These are regulatory requirements to adhere to a formal complaints procedure.

The policy has been written to conform with the Financial Conduct Authority (FCA) on handling customer complaints and may be updated from time to time.

Definition

A complaint is an expression of dissatisfaction requiring a response communicated orally or verbally or in writing by a customer or his or her representative. Complaints may be based on:

• Service provided
• Technical problems
• Administration

Purpose

This Standing Operating Procedure (SOP), details the way in which complaints will be acknowledged, documented, investigated, reported and trended. The purpose of this complaints procedure is to establish a clear framework within which complainants will be managed at Premier Engineering & General Finance Ltd (PEGF).

Scope

This procedure covers any complaint or negative feedback that may be received by the businesses. The process may also be used for staff to record internal complaints on suppler product or service quality.

It excludes management and personnel issues raised by staff.  It also excludes payments for compensation.

Responsibilities

This SOP is applicable to all staff involved in the activities detailed in the SOP. Individual responsibilities are detail within the body of the procedure.

1. General Principles
2. General Guidance for face to face and telephone complaints
3. Confidentiality
4. Complaint Process – Actions + Documentation
5. Complaint Process – Investigation + Outcomes

General Principles

Any customer has the right to complain about any aspect to the business whether this is a product. Facility, services or administration related.

Complained are generally received in the following ways:  face to face, telephone or in writing by letter or email.

It may be appropriate to address a complaint at the time it arises without using a formal complaints procedure, however staff should not deter a complaint from taking a more formal route if they wish to do so.

In either case, the complaint should be treated with respect, no matter how small or trivial the complaint may appear.

• Negative comments received via a customer that appears to be a complaint may be followed up using this procedure if the customer is identifiable.

As a general policy, Premier Engineering & General Finance Ltd (PEGF) will not normally consider complaints if they are made more than  12months after the complaint become aware of the matters that gave rise to the complaint.

• Complaints greater than 12 months old will be assessed on a case by case basis and may be investigated if it is considered a need to do so.

Anonymous complaints cannot be investigated unless these are sufficiently detailed to perform a general review and will be raised as an internal incident.

Complaints will not be considered if the complainant refuses to identify precisely the issues that they wish to be investigated despite reasonable efforts by staff to help them identify their concerns.

General Guidance for ace to Face and Telephone Complaints

Verbal complaints, and in particular emotional complaints, are usually the most difficult to handle. Customers failing to find anyone to accept personal responsibility for resolving their problems or complaint is a major cause of extra upset and frustration, so when a distressed customer finds someone who promises to take responsibility this lifts an enormous pressure.

The following is intended as guidance to help staff function effectively in these circumstances.

• Listen – let the other person talk and explain.
• When you listen, listen with feeling and empathy

The complainant will be acutely sensitive to (and potentially upset further) by an automation-like reaction, so try to really empathise on the individual basis.

• Ask “How can I help?”
• Take notes and get the facts. Take time and let it be known that you are doing so.

This shows you are taking the problem seriously, that you value their words and time spent explaining the problem. By encouraging the other person to focus on the facts, you can help to move the engagement away from emotion and into content and facts, which will normally reduce stress for the both of you.

• Try to step back and look at the situation objectively with the other person, rather thn getting drawn into confrontation.

Encourage the approach where you both work on the problem together to agree what should happen next.

• Understand how the other person feels. This is not the same as agreeing with the person.

It is important to show understanding. It is not possible to agree with an emotional interpretation or a mood, and until the facts are properly known, it is not always possible to agree with even a perfectly reasonable complaint unless or until you can substantiate the facts.

You can always show that you understand how the other person feels, and this is a very big part of a customers need at the time of complaining.

• Tell the customer what process or steps you will use to resolve the problem for them.

No statement accepting responsibility or admitting liability shall be made by any member of staff. Note that an expression of regret that the customer has felt the need to complain is not, of itself, an admission of liability and will often bring a complaint to an end.

If a problem cannot be resolved informally then the formal complaint process should be offered to the customer and the nest steps explained.

• The formal complaints procedure should be prominently displayed for the customers and should be given to the customers when visiting the premises.

Confidentiality

The names of customers or complaint shall remain confident except to facilitate the investigations of a complaint. The names of staff members shall remain confident except to facilitate the investigation of a complaint. Care needs to be taken when dealing with complaints and relatives, friends and close family relatives such as children of the customers.

Date may be disclosed to other individuals or bodies if legally required or permitted to do so under the Date Protection Act 1998.

• For customers under 16, assume the parents or legal guardians have right to deal with the issue and have access to all the available information.
• For customers ages 16-18, a judgement needs to be made in each individual case, and where appropriate, permission sough from the customer before dealing with any third party which includes parents.
• For customers aged over 18, permission will normally be sought from the customer to disclose information to a third party before the disclosure of any information.
• Where a husband or wife is complaining on behalf of their spouse, a judgement should be made in each individual case, and, where appropriate, permission sought from the spouse to be disclose information
• Where the customer is a vulnerable adult (of any age) special care should be taken to protect their interested and this includes the disclosure of information to third parties.

Complaint Process – Actions + Documentation

All formal complaints whether verbal or written, must be documented on the Complaints Receipt Form.

The complaint receipt form should be used by staff where possible to record details of a customer’s complaint. However where the complaint is received for instance by letter or email, it may be more practical for the complaint to be passed directly to Keith Pallett (KP) Managing Director.

Paper documents will be considered to be the original record. Photocopies, PDF and electronic copies may be obtained as a backup copy.

The complaint must be promptly documented in sufficient detail to allow a formal investigation.

It is the responsibility of the person receiving the complaint to record the event factually and accurately. Ensure the key details such as customer name, complaint number, date, time and other relevant information should be recorded.  Also the names of staff involved should be recorded.

The nature of the complaint and the sequence of events should be clearly documented.

Complaint forms and copies of the complaint forms MUST NOT be retained in the customer’s records. Receipt of a complaint may be recorded in the customer records, but all detailed events and communication must be kept within the complaint investigation records.

Each complaint will be assigned with a unique number and will be regularly monitor complaint progress and produce performance trending.

An initial acknowledgement may be made verbally or by email, but this will be followed up with a formal letter within 2 working days.

The acknowledgement must give the name and contact details of the person who will be responsible to the complainant.

Correspondence should be clear that the contents are for the addressee only.

Care should be taken to maintain the customer’s confidentiality.

Complaint Process – Investigation + Outcomes 

KP will formally investigate complaints with the appropriate staff, company and any relevant information.

The investigation must be conducted in a manner to that ensures complaints are handled fairly, effectively and objectively.

• Staff investigating complaints should be not be involved in the circumstances that led to the complaint.
• All communication relating to a previous complaint from the same person should be cross-referenced.
• All information provided to insurance companies and legal teams should have all personally identifiable information redacted or deleted.

• Where a complaint has legal implications, it may also be necessary to pass the investigation outcomes to company lawyers for review before issue to the complainant.

If it becomes evident during the investigation that it is necessary to consider any confidentiality or data protection implications, details of the investigation may be reviewed and commented on again.

Outcomes of complaints will be formally issued in writing to the complainant within 20 working days of the date of the receipt. If the investigation or outcomes cannot be fully resolved in 20 working days, than a holding letter may be issued, explaining the circumstances and a timescale for a reply.

The outcome of any investigation should provide clear reasons for the decision to uphold or dismiss the complaint.

The outcome and any corrective actions will also be documented.

KP will approve the final investigation and outcomes, before the final letter is sent out to the complainant. Then when the final letter is sent out to the complainant, this complaint is considered closed.  However if a complainant is still unhappy with the outcome of the investigation, they can contact the Financial Ombudsman Service at www.financial-ombudsman.org.uk or by contacting them on 0800 023 4567.

A complaint response record will be completed to document key dates, including communication to management and details of the complaint and the outcome.

It is the responsibility if local management to ensure that the outcome of complaints is discussed with staff, including any corrective actions that may have taken place to prevent a recurrence.

Eva Pallett – Account Executive will maintain and archive complaints documents including original letters, investigation records and responses to completes.