Complaints

LHK Group Complaints Handling Procedure

Last updated January 2021

This procedure is operated by the firm in relation to its financial services provided under the Consumer Protection Code.

Our objectives:

• To respond to complaints in a courteous, timely and fair manner.
• To endeavour to address the specific issues raised by our customers and, where appropriate, update our procedures to avoid re-occurrence of problems.
• To endeavour to achieve a situation where our customer feels we have addressed the complaint, but if he/she remains dissatisfied with the outcome of our efforts, to ensure that he/she is notified of the right to refer the matter to the Financial Services Ombudsman or Pensions Ombudsman.

In the event of a complaint the following code will apply:

1. Where the firm receives an oral complaint, we will offer the consumer the opportunity to have the complaint treated as a written complaint. The firm will investigate the complaint on the basis of our understanding of the issue.

2. The complaint is logged on the complaints log in the S Drive and cross referenced as necessary to the client line and provider.

In the case of a complaint relating to a policy bound by Lloyd’s Brussels (Aspen or Axa XL) we are obliged to notify the Underwriters immediately upon becoming aware of any matter arising which has resulted or could result in a complaint to any regulatory authority or give rise to proceedings against the Underwriters or the Coverholder. The managing agent e mail to report complaints is:

Aspen Axa XL

See the below link for further reference:

https://www.lloyds.com/market-resources/complaints/complaints-handling/international-complaints-handling/ireland

3. Our team will endeavour to sort out the complaint straight away. If this is not possible, they will acknowledge the complaint in writing within 5 working days of receipt, and inform the complainant how long it will take before they can give an answer unless:

a. the complaint is resolved within 24 hours to the complainant’s satisfaction
b. the Final Response can be issued within thistimeframe.

This acknowledgement will contain a copy of these procedures and notification that the complainant can refer the matter to the Financial Services Ombudsman if he/she is not happy

with the outcome of our investigation, or if the matter has not been resolved within 40 business days, the anticipated timeframe within which the firm hopes to resolve the complaint. Contact details of the Financial Services Ombudsman will also be provided.

4. We shall investigate the complaint as swiftly as possible, and, the complainant will receive an update on the complaint at intervals of not greater than 20 days starting from the date on which the complaint is made.

5. If the complaint cannot be resolved satisfactorily within Step 1, the complaint can be elevated to the Director to request a review and seek resolution. We will also seek the support of the relevant managing agent if required.

6. If the response to the complaint is not satisfactory, the Financial Ombudsman Service may be of assistance. The complaint must be taken to the Financial Ombudsman Service, if the complainant is not satisfied with the Compliance Director’s response within 6 months of the issuing of a Final Response Letter. The Financial Ombudsman Service can be contacted at 3rd Floor, Lincoln House, Lincoln Place, Dublin 2, Ireland Tel:(01) 662 0899.

7. Within 5 business days of the conclusion of our investigation of the complaint, the firm shall send a written report of the outcome of this investigation. This report shall include, an explanation of the terms of any offer that the firm is prepared to make in settlement of the complaint. We will also inform the complainant of the right to refer the complaint to the Financial Services Ombudsman or Pensions Ombudsman and will provide the consumer with the contact details of such Ombudsman.

8. Where it appears to the firm that the complainant is not satisfied with the outcome of our investigation, and where we feel that we cannot progress the issue further, we will immediately write to the complainant advising them of their right to refer the dispute to the Financial Services Ombudsman or Pensions Ombudsman.

9. A senior manager will review the file before its conclusion and attempt to identify any procedures that can be implemented by our firm to avoid a repeat of the type of complaint received. Any new procedures will be immediately communicated to all staff and placed in the Written Procedures file.

The person responsible for complaints in this firm is Mr. Graham Hohn (Dublin) and Mr. Stephen Patterson (Drogheda). All correspondence in relation to customer complaints will be retained for a minimum of six years from the date of the last correspondence about the matter. This correspondence is stored in the client file on our Relay System.

ENDS

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