Kotak Mahindra Old Mutual Life Insurance Ltd.

Grievance Redressal Policy
Kotak Mahindra Old Mutual Life Insurance Ltd.
9'h Floor, Godrej Coliseum, Behind Everard Nagar, Sion East, Mumbai 400022
Page 1 of 22
1 POLICY STATEMENT ...........................................................................................................................................3
2 APPLICABILITY ...................................................................................................................................................... 3
3 CONTEXT ................................................................................................................................................................ 3
4 OBJECTIVES & BENEFITS ..................................................................................................................................4
5 BACKGROUND, PURPOSE & SCOPE ................................................................................................................4
6 DEFINITIONS .........................................................................................................................................................5
7 PROCESS ..................................................................................................................................................................7
7.1 CO\II'I. \IN'I RI:(:I(II'"1'R RI':GIs I'R \'I'ION ..................................................................................................................7
1.1 Receipt of (.omp/aiuts ......................................................................................................................................... 7
.1.2 R girlenlrg Complends ........................................................................................................................................ 7
7.2 COMPI..\IN'I'.\N.\IXSIS ............................................................................................................................................ 8
7
.2./ (.ate'go,itiniion ................................................................................................................................................... 8
'.2.2 Priorititiution .................................................................................................................................................... 9
-.2.3 ss gniug IZeupon ihilil. ..................................................................................................................................... /0
7.3 COMIPI..\IN'1' Rls( )I.I''I'IO^ ..................................................................................................................................... 10
7.3.1 Follone np ^' F.s a/a/eon Process ......................................................................................................................... 11
7.3.2 (.ouiplninti. Ia,,agement (.ommlltee c Review of CoFup/ainis .................................................................................. I I
7.4 C \IN'I CL( )s('ItF ........................................................................................................................................... 12
8 GLOSSARY ..............................................................................................................................................................13
9 ANNEXURE ...........................................................................................................................................................14
9.1 CO\IPI..\IN'I' IZI((.IS'I I;K 1'OR\L\'I ............................................................................................................................. 14
9.2 '1':\'I' & F SC \I..VI ION :\L\TR1\ ................................................................................................................................ 16
9.3 RI(I'OR'I'IN( IN'I'I?RN.11.R F.S'fISRN 1I .................................................................................................................. 17
10 DESIRED GRIEVANCE REDRESSAL MECHANISM -TO ADOPT IN FUTURE ................................... 18
11 APPROACH FOLLOWED IN RESOLUTION OF GRIEVANCES UNDER CONSUMER PROTECTION
ACT. 20
12 STEPS TAKEN/TO BE TAKEN BY THE COMPANY FOR CONSUMER EDUCATION ........................ 21
13 OUR GRIEVANCE REDRESSAL OFFICERS AT THE FOLLOWING LOCATIONS ................................ 22
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Grievance Redressal Policv
Policcy Statement
I •:ffective complaints management is good business practice. k I .I H listens and positively- receive
customer complaints. We ensure all complaints are dealt with fairly and employees have the
necessary skills to manage these expressions of dissatisfaction confidently and competently to their
resolution.
The following principles underpin KLII F complaints management:
• fair deal to all customers
• responsiveness towards customer complaints
• complainants are not to suffer reprisal for making a complaint
• ensure all complaints are dealt as per the regulations prescribed by the regulatory authorities
• complaints are addressed fairly, reasonably and in a timely manner
• easy access to information and advice for all stakeholders
• application of natural justice and provision of avenues for review
• protection of confidentiality and complainants respectfully treated
• complaints data is integrated into business improvement processes
• the complaint management policy and its application is reviewed regularly to ensure it
remains an effective and appropriate mechanism to business improvement.
2 Applicability
This policy applies to all employees (including contractors and consultants engaged by the
department ). The policy applies to internal and external complaints about KI.IFE policies, products
and services and/or its employees . However, it does not include complaints under unusual events
reporting and employee harassment policy.
The following are not classified as complaints:
• enquiries and requests for information
•
input and feedback provided as a result of consultation processes.
3 Context
A key element toward achieving excellence is to engage with our customer and have high regard for
their input. Effective complaints management is one avenue from which we can collect information
to inform continuous business improvement.
The policy advocates accessible, transparent and accountable complaints management that:
• promotes and supports competent complaint handling
• is receptive to customer complaints
• develops a culture that respects people's right to complain about any aspect of the
department's operations
• provides an efficient and fair mechanism to resolve complaints and communicate outcomes
• uses the information from complaints to identify and rectify recurring and systemic
problems to improve planning and future service delivery.
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Grievance Redressal Policy
4 Objectives & Benefits
The objective of the RI] I' 1: complaints management policy is to:
• encourage the expression of customer dissatisfaction in a positive environment
• have fair, consistent and prompt investigation, decision making, and redress which
should be embedded in well documented procedures
• provide a uniform process across KI,II1L for effective and prompt resolution of
complaints
• provide meaningful and useful information highlighting trends and systemic issues
associated KI,IFIi processes, products or services enabling improvements in business
• have effective and prompt analysis of the root causes of complaints, and a commitment
to remedying such causes, to ensure fairer treatment to current and future customers
• promote customer confidence in KI,IFI by ensuring openness and transparency in
handling complaints.
This policy expresses principles to inform decision making across the department enabling
c o nsi stent and effective com plaints management.
5 Background , Purpose & Scope
KLIFI is in the life insurance business with centralized operations and decentralized business
sourcing PAN India through different channels namely Tied channel ( business sourced by
individual life advisors ), alternate channels ( other Kotak group companies, corporate partners etc),
business associate and telesales teams. Life Insurance businesses are mostly sourced by partners and
non Kotak employees. "Plus often gives rise to varied level of service, commitments which are not
always as per the company standards. This often leads to customer dissatisfaction which results in
complaints from customers through various modes and through different departments. The main
idea of this document is to ensure that all complaints get recorded in KLIFI : books irrespective of
the department where it was received and to provide a uniform process all across for effective and
prompt complaint resolution
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Grievance Redressal Policy
6 Definitions
Complaint
A complaint is an expression of dissatisfaction verbally or in writing,
about policies, products and services provided by 1,J A I ' F or o f an
action of an KI.IFE employee. E.g:
• An error committed by anyone associated with KU (1:rroneous
documents/wrong information)
• Compensation transactions (resulting due to incorrect
conversions /s\N itches etc.)
• I\liss-selling by the Sales team
• Forgery
• Overwriting in proposal form
• Deficiency in service
• Any servicing issue which causes inconvenience to the client etc.
Complainant
This is a person who expresses dissatisfaction with KI.II^E policies,
products or service or action of an employee.
Internal
Customer/Complainant
Kotak Life Employees
Internal Partners
Life Advisors, Channel Partners, Doctors, Medical Centers, Media
Partners, Kotak Group companies for whom Kotak Life is
accountable
External
Policy I lolders
Customers /Complainant
Standard Complaints
'I'bis is a failure of a product, service, system, policy or procedure
which causes or contributes to a complaint, as opposed to an
employee's error of judgement. Eg: Non receipt of UL statements,
delay in receipt of policy document etc
Special Complaints
Non standard complaints which are a result of a willful act of
miscotnmum'cation, cheating, suppression of facts, misbehaviour etc.
Eg: i\lisselling, Forgery, Misappropriation of funds etc.
Miss-selling
Miss-selling would imply cases wherein:
• The charges have not been communicated to the client correctly
• The client was explained a different product but sold a different
product
• Promising/projecting a benefit/ return to customer which is not
ex licitly promised in Product features.
Fraud
I\Gsappropriation of Funds (putting money to some other use other
that pnrlx),( for which it was collected), unauthorized use of funds
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Grievance Redressal Policy1
I orl;er-, Document tamprrinl;, scribbling on document on customer behalf,
signing on document on customer's behalf, certifying customer
details (address, profession, details in \11 IR, ctc) without proper
verification
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Grievance Redressal Policy]
7 Process
7.1 Complaint Receipt & Registration
7.1.1 Receipt of Complaints
Complaints can be received from internal or external customers of KLIFE.
• KLIF1F, customers can register a complaint by way of :
■
F.niails
■
Snail Mails
■
Phone Calls
■
E-Complaints - Kotak Life Insurance -\vebsitc as well as the complaint section
on the Online Policy Manager
■
Legal notices
• KLIFE customers can register a complaint with
■
KLIFE Customer Care ( Client Service Desk & Contact Center)
■
KLIFF Branches
■
KLIFF Processing departments ( New Business, Policy Servicing, Channel
Support, Claims, RCU etc)
■
KLIFE Legal & compliance department
■
\Vebsite
■
Chairman's office/MD's office/Ell's office/COO's office
■
IRDA
■
Ombudsmen
■
Other statutory and regulatory bodies
7.1.2 Registering Complaints
• KI1IFF Customer Care( Complaints Management team) will be the central repository of all
complaints across the company.
• Complaints received through any mode and by any department across the company should
be forwarded to Customer Care Within 24 hours of receipt from the customer
• Complaint management team at customer care will update the complaint in the complaint
register maintained by them ( refer annexure) and provide a complaint number
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Grievance Redressal Policy
• It is the responsibility of the complaints management team to ensure completeness and
maintenance of the complaints register. '['hey have the right to reject re lucsts for registering
complaints which do not follow the defined process.
• All written complaints received would be in warded with date, time stamp as well as
receiver's signature.
• Complaints on phone need to be recorded in III :;V1' ( Internal CRM for K11I) for record
• A photocopy of the complaint would be made and sent for scanning and indexing in content
manager ( Document Management/Imaging System) under the concerned policy number
• The complaint management team((,-NI'I') appointed by the customer service head would
ensure that a I IL:A'I' call ( Internal CRM for KLI) is logged for the particular complaint on
the same day
• The complaint management team would also ensure that the complaint is updated in the
complaint register ( refer annexure) with all the necessary details on the same day and a
complaint number is generated against for the same
7.2 Complaint Analysis
It is the responsibility of the complaints management team to analyze the complaint, establish
merits/demerits of the complaint based on initial investigation, categorize the complaint, prioritize on
the basis of facts of the case, identify and assign responsibility for resolution.
7.2.1 Categorization
As a first step of analysis , each complaint needs to be assigned a category based on the nature of the
complaint . The nature of the complaint can be deciphered from the complaint description. Below is
initial list of categories . More categories can be added after discussion with customer care head from
time to time.
Category
Sales Related
Nature of Complaint
• Instances of mis-selling, nus-representation of facts,
suppression of facts, mis-leading, over commitments, false
promises etc
• Non-responsiveness and inappropriate behavior from agents,
channel partners, KLIFF. sales managers etc
Product Features Related
Complaints related to dissatisfaction over product features and policy
Terms & conditions
• Alteration requests which cannot be processed on account of
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Grievance Redressal Policy
Nature of Complaint
Category
product specs eg: Reducing premium Without reducing sum
assured
• I ugh deductions from premiums towards administrative/sales
charges
• Request for premium reduction not approved as per product
specs
• Non ability to surrender before 3 years etc
Forgery/Fraud Related
Complaints related
• forged signature on documents
• tampering details on customer's documents done by
document recipient (agent, employees at branches, I-IO, etc.)
• ;Misappropriation of customers funds
• Frauds etc
Customer Servicing Related
i.e. deficiency in service
Complaints related to non responsiveness, inadequate service,
inappropriate service and inappropriate behavior from branch, CPC &
1-IO, pending payment, inadequate payment and incorrect payment to
channel partners, agents, media partners, service providers
Process & Controls /Others
Complaints related to unreasonable, unjustifiable process steps and
process controls and other miscellaneous complaints
7.2.2 Prioritization
• \X'hile the maximum TAT for resolution of all complaints is frozen at 10 working
days ( 15 days for misselling and forgery cases), certain complaints need to be
prioritized for resolution on an ASAP mode. Standard servicing complaints as
defined earlier will be closed as per the "I'XI defined in SL.\ matrix (Refer annexure)
Once the merit of the complaint is established, customer
care/departments/branches should immediately prioritize them on the basic of the
facts ascertained during initial investigation.
Complaints once prioritized needs to be treated in special ways. Customer care to follow up with
concerned teams for end to end resolution teams and resort to escalation to highest level( refer
escalation matrix) for speedy closure
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Grievance Redressal Policy
7.2.3 Assigning Responsibility
• On the basis of the initial investigation done by the complaints management team, the team
would assign responsibility for various actions that need to be executed for resolving the
complaint. I:.g : Sales team to get approval from their channel head/ NID/F .D/COO for
processing a cancellation for misselling, Ops to actually affect the cancellation in system once
the approvals are received etc
• The complaints management team would also intimate the concerned teams/ members the
requirements in terms of documents / approvals / actions to resolve the case
• 111 cases of forgery and fraud will be rnandatorily reported to RCU ( Risk Control Unit) for
investigation and their final feedback/ recommendation will have to be updated in the
complaints register.
7.3 Complaint Resolution
Resolution of the complaints is responsibility of customer care - complaint management team.
Complaint resolution may be possible by customer care alone or with the help of actions taken by
other departments.
• For all cases received by customer care, complaints management team would respond to the
customer (via letter/email/phone) within 1 working day from date of receipt of complaint.
• The complaint management team would need to confirm the receipt of complaint and the
expected time frame to revert back to the customer.
•
For all complaints, initial investigation will he done on the same day based on the complaint
received , past documents in content manager ( document management/imaging system ), policy
details in Life A sia( core system), discussion with relevant parties and a case sheet would be
prepared
• Incase the complaint does not have any merit ; the complaints management team would close the
same in the complaint register and also close the corresponding I IFAT (internal CRNI) call.
• The complaints management team would also send a formal letter ( incase of snail mail/walk-ins)
or an email (incase of emails / web / phone calls ) to the customer citing clear reasons for rejection
of hi s complaint
• Complaints management would ensure that the reason mentioned for rejection and the language
used in the letter is appropriate from customer service and compliance point of view. All
rejection letters to be sifnied / approved by complaints management head( customer service non voice head) or customer care head before being released to the customer
• The letter/email should assure the customer of best service from Kotak Life and must he
assured that he may get in touch with Kotak Life incase he is not happy With the resolution.
• Incase, customer care believes that the complaint received holds merit, customer care would
follow the subsequent steps within 24 hours to ensure resolution:
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1
Grie%ance Redressal Policy
■
■
Identify the concerned teams to whom responsibility needs to be assigned
Forward emails with the facts of the case and reasons for finding merit in the
complaint to the concerned teams/metnbcrs eg: sales/operations/ RCi-/legal
etc
■
Clearly define in the email as to what is expected out of the concerned teams collection of documents/approvals from respective heads/issue of warning
letters/ termination of agents etc
■
Complaint management team to also define in the email the timeframe within
which a revert is expected from the teams/members
r
7.3.1 Follow up & Escalation Process
The complaint management team bears the responsibility of resolving the complaint for
customers within a maximum TAT of 10 days (15 days for miss-selling and forgery cases). The
complaint management team would ensure follow ups with the concerned teams/metnbcrs for
prompt and timely resolution.
• The complaint register ( currently maintained in excel) is updated with formulae which throw
up cases which have crossed the various threshold of escalation within the TX! of 10 days
• Complaints management team would also escalate cases based on the escalation matrix( refer
annexurc)
• Complaints management team would publish fortnightly MIS of number of open cases Branchwise/ Channel wise/Ageing wise/SM wise
• Complaint management team would also highlight these cases in the review committee( refer
8.3.3 )
• For IRDA /Ombudsmen/legal complaints, incase no positive revert is received for closure
from the concerned teams/members, follow ups and escalations will be taken over by Chief
Manager - Compliance from the Level 2 escalation ( 7 days from date of receipt of
complaint)
7.3.2 Governance Structure - Complaints Management Committee
• The Complaints Management Committee would consist of MJFE MI), K!.1H ED &
KLIFF. COO.
• Complaints management team would organize periodic review meetings with the Complaints
Management Committee to get conclusion on open cases pending beyond "1':x"1'
• The review meetings to be held with the committee with special invitation to Sales I leads
and Operations Head. Complaint management team would present all open cases with
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Grievance Redressal Policy
relevant details in a presentation format to the management and decision given on each cases
by M1l)/I-D/COO would be minuted and implemented.
• Periodic review should evaluate following aspects:
■
l'urnarounds for complaint resolution
■
Review of pending and open cases with reasons
■
Directions and trends arising from complaints & complaint resolution
■
Impact of complaints and resolu tion
compliance, etc)
■
■
■
formulation of plans and policies based on the trends & impact analysis
Corrective and pre-emptive actions for future
on 1<1] F l (Brand , Financial,
Any other matter or policy in relation to complaints and grievances that the
Complaints Management Committee deems fit.
7.4 Complaint Closure
• Complaints would be eligible for closure
■
when the merit in the complaint is accepted by all concerned teams / members
and written acceptance is forwarded to customer care along with necessary action
for resolution - e.g.: necessary approvals /issue of warning letters etc and the
complaints management team agrees that the resolution is adequate and fair to
the customer
■
when the case is escalated to higher authorities - Level 1:
Sales/Ops/Compliance heads and Level 2: MMD/ED/COO and necessary
approvals are received from them and the complaints management team agrees
that the resolution is adequate and fair to the customer
■
when the cases are discussed in the fortnightly review meeting and approvals are
received from MD /ED /COO directly and the complaints management team
agrees that the resolution is adequate and fair to the customer
• Letter/limail to be sent to the customer informing him that his complaint has been resolved,
apologizing about the aberration in service and informing him that we would love to be
associated with him in future.
• Once a favourable closure is chalked out for the customer and closure letter forwarded to
the customer, the complaint management register would have to be updated as closed by the
complaints management team.
• The complaints management team to go through the checklist ( all or combination may be
applicable for case on case ) before closing the complaint in the complaint register;
■
Necessary approvals
■
Warning letters/Termination letters
■
Complaint withdrawal letter
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Grievance Redressal Policy
■
Necessary details are updated in complaint register ( e.g. ch(-yuc details for
refund cases/POD details for closure letters sent to customer etc)
■
Necessary documctit, /conununications /approvals are scanned in content
manager
■
Closure of I I I Vl calls
8 Glossary
Description
Abbreviation
Sr. Num
1
CPC
Central Processing Center
2
Ctii1'
Complaints Management Team
3
COO
Chief Operating Officer
4
CS
Channel Support
5
CSO
Customer Service Officer
6
ED
Executive Director
7
HNI
I ugh Networth Individual
8
IRDA
Insurance Regulatory Development Authority of India
9
KLIFE
Kotak Nlahindra Old Mutual Life Insurance Limited
10
MD
Managing Director
11
NB
New Business
12
PS
Policy Servicing
13
RCU
Risk Control Unit
14
SCI
Sales Manager
15
`1'A'1'
Turn Around lime
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(: rieva n cc Iced ressa l Policy
9 Annexure
9.1 Complaint Register Format
SR.
Num
Field
To be filled
in by
Explanation
1
Sr. Num
Auto Generated
Auto generated serial number for the register
2
Master Complaint ID
CSD
• To be given only by CSD team for all the
departments.
• All departments to take the complaint number
from (:SD on receipt of the complaint at their end.
• No approvals to be given by higher authority
without the mention of complaint number
3
1 teat 11)
Concerned
Department
resolving the
complaint
4
Proposal/ Policy
Concerned
Department
5
Clients Name
Concerned
Department
6
Branch
Concerned
• All complaints to be also logged in I IEAT
• No approvals to be given by higher authority
without the mention of HEAT 11)
• The branch to which the policy is attached
Department
7
Channel
Concerned
Department
• The channel through which the business was
sourced
• Drop Down Available - TA (Tied), CA
Alternate), BA ( Business Associates), DM ( Direct
Nlarketing),'I'S (TeleSales)
8
9
10
Received By -
Concerned
Department
Department I Iandling the complaint
Department
Received By - Name
Concerned
Department
Person working on the complaint from that
department
Concerned
Department
• Drop Down Available - Direct C ustomer/Direct
I.,A/IRDA/Ombudsmen/I.ife
Source
Counsel/Legal/Udays Office/Mgnu Desk/Police
FIR/Others
11
Mode
Concerned
Department
• Drop Down Available - Letter/ I-:mai1/Call/portal
12
Received Date
Concerned
Date on which the complaint was received by customer
care/branch/ CPC dcpartnurnts.
Department
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Grievance Redressal Policy
13
Complaint - Description
Concerned
Department
Brief gist of the complaint
14
Complaint - Category
Concerned
• Drop Down Available - \Iisselling/Service
Related/ Product Related/Forgery/Others
Department
15
Action - In progess
Concerned
Department
The action being taken for resolution
16
Final Revert Rccvd Date
Concerned
Department
• Date on which final resolution has been received.
Auto Generated
• This is a formula driven field
17
Prompt for Escalation
• Interim dates should not be tilled in
• Will prompt if a complaint is pending for
resolution beyond TAT
• Will also prompt the level of escalation
• To be used to track open cases
18
Due for Closure - Date
Auto Generated
• This is a formula driven field
• Will prompt the date by which the complaint
should surely be closed (Maximum closure time)
• To be used to track open cases
19
20
21
Complaint Status
Concerned
• Drop Down Available - Open/Closed - Rejected/
Department
Closed - Resolved
Concerned
Date on which the complaint was finally/completely
Date
Department
closed
Ageing
Auto Generated
• This is a formula driven field
Complaint Closed -
• Will prompt the TAT for closure
• To be used for MIS reporting
22
23
Closure Description
Concerned
Department
Brief description
Action taken/Warnings
Concerned
Department
• Drop Down Available - Yes/No
Given
• Action letter/Warning letter issued by Sales Flead,
Shekhar Bhandari/Suresh Agarval) or Ops I lead
I litesh Veera) needs to be collected and scanned
in CM
24
Closed by
Concerned
Name of the person closing the complaint
Department
25
26
Whether forwarded to
Concerned
RC I'
Department
RCU Comments
Concerned
• Drop Down Available - Yes/No
Brief Description of comments given by RCU
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Grievance Redressal Policy
Dcparnnent
27
I"inal Resolution
Concerned
final recommendation given by RCt'
Department
28
29
Case Reopened:'
Reason
Concerned
To be tilled it customer conic back with addition
Department
proofs/documents on an already closed complaint
Concerned
Brief description as to why the case is being reopened
Department
30
Reopen Date
Concerned
Department
l)ate of which the case is reopened - Date of receipt of
complaint
31
Reopen - Complaint Ill
Concerned
Department
New complaint ID in the register for reopening the
case
9.2 TAT & Escalation Matrix
TAT in Days
Escalation Matrix.
:- Nfail with case History sent to
• I or Sales : To SM with copy to BSI and RI\l,
• For Sales ( Kotak Group Companies) -To RMls with copy to Thakur Bhaskar
• For Branch: To BOEs & ROC with copy to 1-lead of Branch Ops
• For CPC : To department heads with copy to CPC Head
• For RCU : To concerned team member with copy to RCU I lead
U
• For Underwriting : To concerned team member with cop), to Underwriting I lead
Escalate to Sales Heads (Tied I-lead/Alternate I Iead/Kotak Direct I lead),
5
Operations Head , RCU I lead, Underwriting Head
7
Escalate to MD/Ell for Sales and COO for Ops/RCU/Underwriting
10
Final closure to customer
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Grievance Redressal Police
9.3 Reporting - Internal & External
Internal Reporting
Frequency
Recipients
Pending Report - Channelwise/Branch wise
Pending
Weekly - Wednesday
Sales/Ops/RCU/Claims
Heads, CPC Department
Heads. KL.I BMs
Pending Report - Functionwise/Channelwise/
Branchwise Pending
Weekly - Wednesday
Sales/Ops/RCU/Claiins
Heads. CPC Department
Heads, KL.I BMs
Pending Report - Sales Pending ( Channel/
Ageing)
Weekly - Wednesday
Sales/Ops/RCU/Claims
I leads, CPC Department
Heads, KLI BMs
Pending Report - Dcpartmentwise Ageing
Weekly - Wednesday
Sales/Ops/RCU/Claims
Heads, CPC Department
Heads, KLI BMs
Report
External Reporting
IRDA requires every life insurance company to publish in their websitc statistics pertaining to
complaints received from customers against the agents.
External Reporting to be done as per process " Process Note on Complaints relating to
ATIs/ Agents"
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Grievance Redressal Policy
10 Desired Grievance Redressal Mechanism - To Adopt in Future
Complaints Management Process is a reactive measure taken by most of the companies to address
customer issues faced by them on account of service aberrations, unethical business acquisition -which
lacks suitability and affordability. Our focus in the coming years should be to reduce complaints instead
of reacting to complaints. Our business model of sourcing business through extended partners in the
form of agents and brokers snake it extremely critical for us to believe and drive the. importance of
ethical & honest practices. Ilowvever, the high attrition in advisors, sales force and their movement
within different insurance companies make it very difficult to control instances of rnisselling /forgery fo r
short term gains. The times ahead demand quality on the kind of business sourced so that we do not
lose out on our customers to optional cancellations, future lapsations and disputes. It requires us to be
highly compliant in all aspects and practice conformity in letter and spirit and not just on paper.
Some of the proactive steps that we would like to take as a company in future along with the help of
IRD;1 and other insurance companies in the industry:
• Establishing a credit bureau similar to CIBIL, comprising of a comprehensive repository of data
pertaining to all Sourcing agents from all insurance providers regulated by IRDA. This will enable us
to track the movements of all advisors and maintain a tight leash around them, so as to prevent/
rnimn-aze occurrence of any unethical selling practices and subsequent customer dissatisfaction.
• More transparency & convenience in the grievance redressal procedure, Involve usage of technology
to integrate the existing systems available and ensure increased level of automation
a. Automating the complaints management system
h. Customer is to be provided the functionality to lodge a complaint using the online
customer portal, from where the same will be picked up and be dealt with.
c. Customer will be able to check on the status/ progress of the complaint by logging in to
the portal and track the progress of the complaint by date and the stage it has reached.
d. Customer should also he able to receive a Short summary on the status of the complaint
by sending us an SMS (Keyword + Complaint Ref no).
c. A similar function can be enabled on the IVR as well, subject to feasibility of the same.
• Ethical acquisition of business - Guideline of best practices to be followed by sourcing agents, so
that any new business acquired is not done through any untoward/ nefarious means, failing which
they would be eligible for punitive action as the situation may warrant.
• F xtreme caution needs to be exercised, both at the acquisition stage as well as during the complaint
handling stage that no unrealistic commitments whatsoever are made to the customer at any time
and in any form, -which we may not be able to deliver later.
•
Benefit of doubt to be provided to the customer, in case a situation reaches a deadlock/ stalemate.
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Grievance Redressal Police
• Clearer guidelines in terms whether a complaint demands merit or not ; in terms of timescales within
which a customer can revert, legitimacy of the facts presented.
• 1 lowever, as each and every complaint is unique in itself, we must adopt a more pragmatic approach
and ensure that every complaint received is treated with apt jurisprudence.
• Greater involvement is also needed in terms of providing consumer education initiatives ( informing
customer about their rights, etc .). T his can be attained by issuance of newsletters / news bulletins
and putting relevant content on the websitc.
• Greater levels of clarity in all our communication / terminology listed on the Policy document needs
to be made more lucid, such that any layman may he able to interpret the same.
Page 19 of 22
Grievance Redressal J'olicv
11 Approach followed i n resolution of grievances under Consumer Protection
Act.
• On receipt of complaint/summon/notice from Consumer Courts for cases filed under the
Consumer Protection Act, our Legal team first studies the case & investigates into the merits.
• The Legal team will contest only those cases tiled against K1A which holds merit. Legal team will
not contest all cases filed against K1.I just for the sake of contesting cases.
• Our Legal team will collate necessary facts & information on the issue based on which, strengths
& weaknesses are ascertained.
• Once the merit of the case is ascertained, our Legal team entrusts the matter to the advocate to
represent.
• Drafting, pleading, filing of replies , affidavit , written arguments are in-house activities of the
Legal team.
•
Based on the facts & info gathered, if it is not a fit case or customer's grievance / allegations are
genuine, Legal team would take up the matter with competent authority to settle the case
amicably out of court.
• Necessary approval /s will be taken & legal team will take it up for logical conclusion.
Compliance with Court orders / judgements:
• On receipt of the final verdict/order, Legal team will study the order & provide its views on
gravity /criticality of the issue.
• Legal team will look into the merits. Based on the possibility/probability of winning as well as
on the legal aspects, Legal team will provide its views and opinion for logical conclusion whether
to prefer an appeal or not.
Page 20 of 22
I
Grievance Redressal Policy
p any for consumer education.
12 Step s taken to be taken b y the com
• At the very outset, language used in all customer correspondence, particularly the Policy document
needs to be made simpler, such that am' layman may be able to interpret the same. A dedicated l-:\(
booklet explaining all terms and conditions arc to be enclosed with every Policy documents.
• Consumer education initiatives can be fulfilled in a major way by way of Newsletters/ leaflets/
mailers, which can be sent to the customers through snail mail & e-mail, educating them about their
rights and creating awareness.
• Relevant content also needs to be uploaded on the website from time to tithe; updates on the sane
can be flashed on the customer portal in the form of a ticker.
• Consumer education through every customer touch points
• Inbound Contact Center -Through IVRs and agents
• Outbound Contact Center -Through agents
• SKIS Alerts
• All insurance providers, at the behest of the 1RDA would require to set-up a dedicated consortium
such as a Consumer forum/ helpline, wvhich would review and adjudicate the complaints received.
A dedicated resource to be posted at all branches who can be approached by the customer to seek clarity
about the product or about any procedure that may he need to be followed in the event of any servicing
r
need/ complaint/ discrepancy
Page 21 of 22
Grievance Redressal Policy
13 Our Grievance Redressal Officers at the following locations
Complaints
Management Cell
1'\N Indi a
Chief Grit ranee
\Ialieshkumar
O b ee r
Radhak ri hnan
P - \\ I n di a
I litesh \ ' ecra
PAN India
clientservice desk (I kotakcom
1800 209 8800
n-lahesh. kumar(a;kort k.com
022 66215865
Senior Vice
3
President -
( )perations &
hitcsh ._^_eera .9 kotlk.com
022-66215103
Service I lead
Customer Service
I lead
5
Regional ( ) pcrations
Controller
Kalparupa Datta
PAN India
West Bengal, Bihar,
Rajiv Bagaria
Jharkhand, ( ) rissa,
I:alpan ) .datta a kota^.com
ra bagaria(a-wak`com
k
09836112212
Assam
Regional ( ) pcraiions
Controller
Regional ( ) pcrations
Controller
Regional ( )perations
Controller
9
10
Regional ( )perations
Controller
Regional ( ) pcrations
Controller
Rajneesh Nangia
Digvijav Karki
Rahul Arora
Priti Punjabi
\lithun Shanbhag
Maharashtra & Goa
022-66215195
raincesh ran is
kotak.com
09920606088
Delhi, NCR &
Rajasthan
diaiia
iia y. kart i.(t k-ptokc;om
09999200391
Punjab & I lan'ana
rah I arora(2kot k.cQm
09216911681
Gujarat
South 1 - Andhra
Pradesh &
Karnataka
rr unjabi(aLkclabsczrrr
09825260336
rni. th un. s h a n [email protected]. corn
09845579777
South 2 -Tamil
Nadu & Kerala
seshadri.r p%kotakcom
09282345450
Uttar Pradesh &
\ladhva Pradesh
sriv-astav a.shashank(t kotak.com
09935557561
Regional ( )pcrarion,
II
12
Conrrollc-r
Regional ( )pcrations
Controller
Seshadri R
Shashank
Srivastava
For an grievances, we suggest you w
clicnts rite in to our dedicated complaints management cell at
en-icedesk(citkotak,com, Our officers will revert to \•ou with resolution within 2 business days. 11o^^ever, i
y
if
YOU are not satisfied with the resolution provided, you can highlight your complaint to the Grievance Redressal
Officers of your region or to the Grievance Officers at our I lead Office.
Page 22 of 22