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Your feedback is valuable to us

At Utmost International, we strive to maintain high standards of customer care. Unfortunately, there may be circumstances where you feel that we have not delivered to these high standards.

If you’re not satisfied:

Where you feel it necessary to make a complaint, we will aim to resolve your complaint as effectively and fairly as possible. Your business is important to us and we want you to be entirely satisfied with the service that you receive from us.

Our goal is to resolve all complaints quickly and efficiently. Every complaint is taken seriously and goes through the same process. We want to:

• Make it easy for you to tell us about your experience
• Carry out a thorough investigation
• Consider our decision carefully
• Explain our conclusions to you clearly
• Ensure you are treated fairly
• Learn from our mistakes.

Our process

• We will acknowledge receipt of your complaint within five business days.
• Where possible, we will provide a full response to complaints within ten business days.
• If we are unable to give a full reply to your complaint within 20 business days of receiving it, we will write to you with details of the progress of our investigation. In this letter we will tell you when we expect to be in a position to fully respond and will give you details of our continuing investigation.
• In exceptional circumstances, where we are unable to complete an investigation after 40 business days, we will send you an explanation of why we are not able to send a final response letter and when we expect to be able to do so.

If you wish to make a formal complaint, please see the steps below.

You can submit your complaint to us in writing, by email or over the phone. Please note that emails are not secure as they can be intercepted, so think carefully before sharing personal or confidential information in this way. Telephone calls may be recorded.

If you write to us, please mark it clearly as a complaint and if possible, provide the following information:

• Specific facts, policy number(s) and relevant documentation
• Proof of losses sustained with calculations (if relevant)
• The solution you require to resolve your complaint

Please include as much detail as you can about what happened which will enable us to understand your complaint and investigate it thoroughly. If you are happy for us to contact you by telephone, please also provide a contact number.
Details of contact number, email and address for each of our product providers can be found below.

1. INTRODUCTION

1.1 Purpose/background of the Policy

On 14 June 2012, the European Insurance and Occupational Pensions Authority (EIOPA) issued “Guidelines on Complaints-Handling by Insurance Undertaking” which require that a “Complaints management policy” is put in place by insurance undertakings. On 21 December 2012, the Luxembourg insurance regulator, the Commissariat aux Assurances (CAA), has informed EIOPA it would fully apply these guidelines and has thus issued the Circular Letter 14/1. According to this Circular Letter, the EIOPA guidelines are to be considered as minimum standards for complaints handling.

On 26 February 2019, the CAA issued a regulation n° 19/03 relating to out of court complaint resolution (the 2019 Regulation)

This complaints management policy (the Policy) sets out how Complaints are managed by the Company.
This Policy is designed to address the risk of inadequately responding to Complaints. The impact of non-compliance may result in:

• Regulatory sanction;
• Litigation;
• Reputational impact;
• Financial loss.

For the purposes of this Policy, the words and expressions set out below shall have the following meanings:
“Complainant” means a person who is presumed to be eligible to have a Complaint considered by an insurance undertaking and has already lodged a Complaint e.g. a policyholder, insured person, beneficiary and, in some jurisdictions, injured third party.

“Company” means Utmost International Luxembourg including its branches.
“Complaint” means a written dissatisfaction addressed to the Company on a dysfunction of the latter which is not resolved by the agreement of both Complainant and the Company no later than the first working day following the receipt of the Complaint.

Specifically, a dysfunction relates either to:

• The Company’s overall organization;
• The life insurance contract; or
• The insurance service the Company has provided or failed to provide. Is therefore not regarded as a Complaint:
• The simple request for execution of the contract;
• The request of the provision of the service;
• The simple requests for information or clarification;
• The grief resolved no later than the first working day following its receipt, provided that the Company’s proposed solution has been accepted by the Complainant; and
• The Complaint received by the Company concerning activities other than those regulated activities or activities related to another entity for which it has no competence.

1.2 Administration of the Policy

As per the Utmost Group Policy Framework, the Risk Oversight Committee (ROC) has the final authority to approve this Policy.
The Chief Operating Officer is responsible of the Complaints-handling for the Company and has delegated the Complaint management process to the Partner & Client Services and to the Legal Departments. Consequently, the ROC delegates the responsibility to design, review and propose amendments to this Policy to the Partner & Client Services and to the Legal Departments.
This corporate Policy will be reviewed annually or when major changes occur.
The Partner & Client Services and the Legal Departments have communicated this Complaints management Policy appropriately and effectively and made it easily accessible to all relevant functions and departments. This Policy is published on the intranet of the Company and is accessible on demand to all clients.

2. POLICY STATEMENT

2.1 Basic principles

The basic principles that are appropriate to the Company are the following:

• Visibility and accessibility;
• Fairness and objectivity / customer-focused approach;
• A single point of contact for all Complaints;
• Rigorous standards for response and resolution;
• Accountability;
• Continuous improvement.

2.2 Process for Complainant

2.2.1 A single point of contact for all Complaints – Partner & Client Services Department (PCS)

A Complaint may be addressed to the Company in writing.
In order to facilitate the interaction between the Complainant and the Company, any Complaint can be addressed to and will be managed by the relevant PCS desk and shall contain at least the following information:

• Name, first name, address and details of the Complainant;
• Quality of the Complainant (policyholder, life assured, beneficiary, partner, …);
• Policy number (where applicable);
• Clear and detailed description of the Complaint.

Complaints can also be forwarded to the Company by the intermediary of the Complainant.
By their nature, some Complaints are likely to be difficult to resolve and may require a technical legal approach. For these Complaints, PCS may ask the support of the Legal Department (Legal).

2.2.2 Complaints received at the Italian branch of the Company (the Italian Branch)

The Company (i) has established a working function aimed at assuring that Complaints received at the Italian Branch are investigated fairly and in compliance with the applicable law and regulation (the Function); and (ii) has appointed a senior manager responsible with overall regulatory responsibility for the Function and relevant process (Complaints Officer).
The Function will operate in compliance with the applicable provisions of the IVASS regulation n. 24 of May 2008 (Regulation 24), as amended by IVASS regulations n. 30 of March 2015 and n. 46 of May 2016.

The Complaints Officer will provide any information on Complaints and Complaints handling to IVASS and will be in charge should any problem arise in the management of Complaints received at the Italian Branch.
In case of Complaints directly submitted to IVASS, the latter may require for the Company to provide clarification directly to the complainant. In this scenario, the Complaints Officer shall send a copy of its reply to IVASS.
The Italian Branch notifies IVASS, within 10 working days from the relevant appointment, about the Function, the name of the Complaints Officer and the relevant contacts.
The Company guarantees the independence of judgment of the Function by adequately placing it within the organization and by envisaging appropriate procedures aimed to avoid conflicts of interest with the structures or subjects whose behaviour is the object of the Complaint.
Moreover, the Italian Branch: (i) ensures the necessary internal flows of information and reporting lines for Complaints management, as appropriate; and (ii) controls the effective and efficient treatment of Complaints, also considering this Policy.

2.2.3 Complaints received at the Belgian branch of the Company (the Belgian Branch)

Any Complaint received by the Belgian Branch will, by default, be handled by the Belgian Branch itself.
However, in case of informational and/or technical constraints, the Belgian Branch can request PCS and/or Legal Luxembourg (depending on the nature of the Complaint) to respond to the Belgian Branch that in turn will respond to the Complainant.
In addition, it is to be noted that information related to Complaints received at the Belgian Branch should be sent to PCS Luxembourg for logging purposes in the internal logging tool (the “Complaints’ Register”).

2.3 Internal process

All Complaints must be acknowledged and answered within agreed corporate service standards and should take the Complainant’s history into account. To this effect, the Company shall adopt an internal procedure.
Upon receipt of a Complaint, PCS takes the following actions:

• PCS logs the Complaint within the Complaints’ Register.
• PCS performs an initial review of the Complaint within 2 working days of receipt.
• PCS acknowledges receipt of the Complaint to
• Complainant within 10 business days of receipt.
• A detailed response shall be sent to the Complainant within 30 days from the date of the receipt of the Complaint.
• When an answer cannot be provided within 30 days, the Company shall inform the Complainant about the causes of the delay and indicate when the Company’s investigation is likely to be completed.
• All Complaints shall be reported to the Senior Management pursuant to internal reporting process.

In case of a Complaint received by the Belgian Branch, the above actions (with the exception of the first one) are taken by the Belgian Branch.

2.4 Rights of the Complainant

The Complainant has the following rights:

• The right to be informed about the complaints management policy;
• The right to a fair, swift and comprehensive treatment;
• The right to receive updates regarding the progress, if any, in the handling of the Complaint;
• The right to be advised in respect of the alternative dispute resolution methods;
• The right to be informed regarding the management of conflict of interests.

2.5 Conflict of interests

Internal procedures shall be adopted to ensure that conflicts of interests are managed properly and effectively alleviated.

2.6 Escalation

2.6.1 Escalation to senior management

When the Complainant has not obtained an answer or a satisfactory answer at the level at which he/she submitted the complaint in the first instance, the Complainant may raise the Complaint up to the Chief Operation Officer – Laurent Muguet.

2.6.2 Escalation to authorities

Without prejudice to any court action, in case the answer provided by the Company is not satisfactory to the Complainant, he/she can address the Complaint to the following authorities.
Escalation may also be addressed to other authorities in the country of residence of the Complainant. Please refer to the applicable general terms and conditions of your contract for more information.

a) Out of court procedure with the CAA
The 2019 Regulation creates an out of court procedure allowing Complainant to escalate their Complaint to the CAA (the Procedure).
Following to the 2019 Regulation, a request can be submitted to CAA only to the extent:

• The formal Complaint has been filed in writing with the Company and have not been answered or satisfactorily answered within 90 days.
• The request is admissible pursuant to article 4 of the 2019 Regulation.
• The request to CAA is filed in Luxembourgish, German, French or English and does contain the information listed in article 5 (2) of the 2019 Regulation.

The CAA may request the production of additional documents or information it deems necessary. It will acknowledge receipt of the request within 10 business days and transfer a copy of the request to the Company which shall take position within 30 days.

The CAA shall issue a reasoned conclusion within 90 days once it has received all the information necessary to its analysis. The 90 days period may be extended in case of highly complex cases; in which event the CAA will inform the Complainant and the Company.

The Complainant and the Company may be represented or assisted by a third party at any stage of the Procedure.

The Procedure is in writing, free of charge and its conclusions are not binding upon the Complainant or the Company.

More information on the Procedure can be found on the CAA website:
English version
French version

b) Other remedies

Médiateur en Assurances: c/o Association des Compagnies d’Assurances, 12 rue Erasme, L-1468 Luxembourg-Kirchberg, Grand-Duché de Luxembourg; and/or
Union Luxembourgeoise des Consommateurs (ULC) 55, rue des Bruyères, L-1274 Howald.

2.6.3 Italian policies

For any Complaint related to an Italian policy, the Complainant can address the Complaint to the following authorities in case the answer provided by the Company is not satisfactory:

For issues related to the contract, to IVASS (Italian Insurance Authority – Istituto per la Vigilanza sulle Assicurazioni) – Servizio Tutela degli Utenti, Via del Quirinale 21 – 00187 Rome, +39 06 42133745 or fax +39 06 42133353, certified email (PEC) [email protected];

For issues related to informative transparency, to CONSOB (Commissione Nazionale per le Società e la Borsa), Via G.B. Martini 3 – 00198 Rome.

For resolving cross-border disputes, the Complainant can submit a complaint to IVASS or activate the FIN-NET procedure (by accessing the website http://ec.europa.eu/internal_market/fin-net/members_en.htm).

The Complainant may also use alternative dispute resolution methods (ADRs) as set out in the General Terms & Conditions of the policy and enlisted in the Company internet site regarding “Complaints management”, such as: “mediation procedure” (pursuant to Legislative Decree n. 28 March 4, 2010,) and “assisted negotiation procedure” (pursuant to Legislative Decree n. 132 September 12, 2014 turned into Law n. 162/2014).

The Complainant is also entitled to contact the Commissariat aux Assurances 7, boulevard Joseph II, L-1840 Luxembourg.
All the above is without prejudice to any court action.

2.6.4 Arbitrator for Financial Disputes (only for Policies issued by the Italian branch)

In addition to the methods listed above and just in case of policies issued by the Italian branch, if the Complainant is not satisfied or has not received a response by the Company within 45 days, she can refer to the Arbitrator for Financial Disputes (ACF). ACF is a system of extrajudicial resolution of disputes between investors and intermediaries on the infringement made by intermediaries of diligence, honesty and transparency duties including cross-border disputes and Regulation (EU) No 524/2013 disputes. ACF does not manage complaints for requests of payment of sums > € 500,000.

For further information on how to submit a complaint to ACF and the scope of its competence, please visit the website https://www.acf.consob.it/ or contact Consob or the Italian branch.

The right to submit a complaint to ACF cannot be waived by the investor.

2.6.5 Belgian branch

For any Complaint related to the Belgian Branch, the Complainant can address the Complaint to the following authorities in case the answer provided by the Belgian Branch is not satisfactory:
– Service de l’Ombudsman Assurances, square de Meeûs 35, B-1000 Bruxelles (www.ombudsman.as; tél: +32(2) 547 58 71, fax: +32(2) 547 59 75);
– Financial Services and Markets Authority (FSMA), Rue du Congrès 12-14, B-1000 Bruxelles, Belgique;
– Commissariat aux Assurances 7, boulevard Joseph II, L-1840 Luxembourg;
and this without prejudice to any court action.

2.6.6 Portuguese market

If the Company’s internal complaints procedure is concluded and the issue has not been solved in a satisfactory manner for the Complainant, either for not agreeing with the outcome of the reply or as a result of the failure by the Company to reply within the applicable deadline, the Complainant may file its Complaint to the Company’s Ombudsman. The internal regulation applicable to the Company’s Ombudsman function can be found in the appendix I of this Complaints management policy.
The Complainant may also file a Complaint to the following entities, without prejudice to recourse to the judicial courts:

Autoridade de Supervisão de Seguros e Fundos de Pensões, at Avenida da República, 76, 1600-205 Lisboa; or Portuguese Securities and Exchange Market Commission (Comissão do Mercado de Valores Mobiliários), at Rua Laura Alves, n.º 4, 1050-138 Lisboa.

Our process

• We will acknowledge receipt of your complaint within five business days.
• Where possible, we will provide a full response to complaints within ten business days.
• If we are unable to give a full reply to your complaint within 20 business days of receiving it, we will write to you with details of the progress of our investigation. In this letter we will tell you when we expect to be in a position to fully respond and will give you details of our continuing investigation.
• In exceptional circumstances, where we are unable to complete an investigation after 40 business days, we will send you an explanation of why we are not able to send a final response letter and when we expect to be able to do so.

If you wish to make a formal complaint, please see the steps below.

You can submit your complaint to us in writing, by email or over the phone. Please note that emails are not secure as they can be intercepted, so think carefully before sharing personal or confidential information in this way. Telephone calls may be recorded.

If you write to us, please mark it clearly as a complaint and if possible, provide the following information:

• Specific facts, policy number(s) and relevant documentation
• Proof of losses sustained with calculations (if relevant)
• The solution you require to resolve your complaint

Please include as much detail as you can about what happened which will enable us to understand your complaint and investigate it thoroughly. If you are happy for us to contact you by telephone, please also provide a contact number.

Please address your complaint for the attention of the Complaints Team.
E: [email protected]
T: + 44 (0) 1624 643345 (UK products) 1
+ 44 (0) 1624 655555 (Rest of World products) 2

1 Current UK products include but are not limited to PWP UK, Selection, Delegation, Evolution, Generation Planning Bond and the Estate Planning Bond. Policyholders of any ex-AXA products should also use this number

2 Current Rest of the World products include but are not limited to Executive Investment Portfolio, Managed Capital Account, Life Insurance Portfolio, Life Insurance Portfolio Plus, Executive Bond (Life and Redemption), International Investment Bond – Redemption, Executive Investment Plan, Executive Investment Account, Silk Life Plan (Life Cover Only), Silk Life Plan (Life Cover Plus). Policyholders of any ex-Quilter products should also use this number

Or write to us at:
Utmost International Isle of Man Limited
King Edward Bay House
King Edward Road
Onchan
Isle of Man
IM99 1NU
British Isles

What if I’m not satisfied with the outcome?

We will do everything we can to resolve your complaint but if you are not satisfied with our response, you can refer the matter to the Isle of Man Financial Services Ombudsman Scheme (FSOS).

The FSOS is an independent body that will consider your complaint impartially to reach a conclusion. There is more information about this service on the FSOS website.
You can contact the IOM Ombudsman at:

The Financial Services Ombudsman Scheme for the Isle of Man
Thie Slieau Whallian
Foxdale Road
St John’s
Isle of Man
IM4 3AS
E: [email protected]
T: +44 1624 686500
W: Isle of Man Government – Financial Services Ombudsman Scheme

Making a complaint will not affect your right to take legal proceedings during mediation. However, if you elect to have your case referred to the Financial Services Ombudsman Scheme then, other than on a point of law, their decision is binding on you and Utmost.

Our process

• We will acknowledge receipt of your complaint within five business days.
• Where possible, we will provide a full response to complaints within ten business days.
• If we are unable to give a full reply to your complaint within 20 business days of receiving it, we will write to you with details of the progress of our investigation. In this letter we will tell you when we expect to be in a position to fully respond and will give you details of our continuing investigation.
• In exceptional circumstances, where we are unable to complete an investigation after 40 business days, we will send you an explanation of why we are not able to send a final response letter and when we expect to be able to do so.

If you wish to make a formal complaint, please see the steps below.

You can submit your complaint to us in writing, by email or over the phone. Please note that emails are not secure as they can be intercepted, so think carefully before sharing personal or confidential information in this way. Telephone calls may be recorded.

If you write to us, please mark it clearly as a complaint and if possible, provide the following information:

• Specific facts, policy number(s) and relevant documentation
• Proof of losses sustained with calculations (if relevant)
• The solution you require to resolve your complaint

Please include as much detail as you can about what happened which will enable us to understand your complaint and investigate it thoroughly. If you are happy for us to contact you by telephone, please also provide a contact number.

Please address your complaint for the attention of the Complaints Team.
E: [email protected]
T: +44 (0) 203 868 5300

Or write to us at:
Utmost PanEurope dac
IDA Navan Business Park
Athlumney
Navan
Co. Meath
C15 CCW8
Ireland

What if I’m not satisfied with the outcome?

If you are not happy with our response to your complaint, you have the right to refer your complaint to The Financial Services and Pensions Ombudsman in Ireland (address below) or to your local Ombudsman.
The Financial Services and Pensions Ombudsman
3rd Floor, Lincoln House
Lincoln Place, Dublin 2
D02 VH29
Ireland

E: [email protected]
T: +353 (0) 1 567 7000
W: www.fspo.ie

Making a complaint will not affect your right to take legal proceedings during mediation. However, if you elect to have your case referred to the Financial Services Ombudsman Scheme then, other than on a point of law, their decision is binding on you and Utmost.

Our process

• We will acknowledge receipt of your complaint within five business days.
• Where possible, we will provide a full response to complaints within ten business days.
• If we are unable to give a full reply to your complaint within 20 business days of receiving it, we will write to you with details of the progress of our investigation. In this letter we will tell you when we expect to be in a position to fully respond and will give you details of our continuing investigation.
• In exceptional circumstances, where we are unable to complete an investigation after 40 business days, we will send you an explanation of why we are not able to send a final response letter and when we expect to be able to do so.

If you wish to make a formal complaint, please see the steps below.

You can submit your complaint to us in writing, by email or over the phone. Please note that emails are not secure as they can be intercepted, so think carefully before sharing personal or confidential information in this way. Telephone calls may be recorded.

If you write to us, please mark it clearly as a complaint and if possible, provide the following information:

• Specific facts, policy number(s) and relevant documentation
• Proof of losses sustained with calculations (if relevant)
• The solution you require to resolve your complaint

Please include as much detail as you can about what happened which will enable us to understand your complaint and investigate it thoroughly. If you are happy for us to contact you by telephone, please also provide a contact number.
Please address your complaint for the attention of the Complaints Team.
E: [email protected]
T: +44 (0)1481 715800

Or write to us at:
Utmost Worldwide Limited
Utmost House
Le Truchot
St. Peter Port
Guernsey
GY1 1GR

Financial Ombudsman and similar services

In the event that you are not happy with the outcome of your complaint, it is possible to refer your complaint to the Channel Islands Financial Ombudsman (CIFO) within six years of the act or omission on our part that you wish to complain about.

You may also be able to refer your complaint to the ombudsman applicable to your servicing branch (if any) or a relevant regulatory body, including the Guernsey Financial Services Commission. Further details are available from the Complaints Team.

You can contact the CIFO at:
Channel Islands Financial Ombudsman (CIFO)
PO Box 114
Jersey
Channel Islands
JE4 9QG
E: [email protected]
T: +44 (0) 1534 748610
W: www.ci-fo.org

Making a complaint will not affect your right to take legal proceedings during mediation. However, if you elect to have your case referred to the Financial Services Ombudsman Scheme then, other than on a point of law, their decision is binding on you and Utmost.

Italy – IVASS
https://www.ivass.it/consumatori/reclami

Spain – Servicio de Reclamaciones de la Dirección General de Seguros y Fondos de Pensiones (DGSFP)
http://www.dgsfp.mineco.es/es/Consumidor/Reclamaciones/Paginas/InformacionProcedimiento.aspx

Portugal – Autoridade de Supervisão de Seguros e Fundos de Pensões (ASF)
https://www.asf.com.pt

Finland – Financial Ombudsman Bureau (FINE)
https://www.fine.fi

Sweden – Konsumentverket
https://www.konsumentverket.se/languages/english-engelska/

Norway – Norwegian Financial Services Complaints Board (Finansklagenemnda/FinKN)
https://www.finkn.no

Belgium – Ombudsman des Assurances
https://www.ombudsman.as/fr/complaint/formulaire-de-plainte

Czech Republic – Finanční arbitr České Republiky
https://www.finarbitr.cz

Germany – Versicherungsombudsmann
https://www.versicherungsombudsmann.de/

France – Médiateur de l’Assurance
https://www.mediation-assurance.org/

UK – Financial Ombudsman
https://www.financial-ombudsman.org.uk/

Jersey – Channel Islands Financial Ombudsman

Home

Gibraltar – Gibraltar Financial Services Commission
https://www.fsc.gi/consumer/aboutfirm/

Cyprus – Ενιαίος Φορέας Εξώδικης Επίλυσης Διαφορών Χρηματοικονομικής Φύσης
https://www.financialombudsman.gov.cy/forc/forc.nsf/index_en/index_en?OpenDocument

Luxembourg – Ombudsman Grand-Duché de Luxembourg
https://www.ombudsman.lu/

Malta – Arbitru gmas Servizzi Finanzjarji
https://www.financialarbiter.org.mt/mt/node

Hong Kong – 香港申诉专员公署
https://www.ombudsman.hk/?lang=zh-hans

Singapore – FIDReC
https://www.fidrec.com.sg/

Middle East – Sanadak / سندك
https://www.sanadak.gov.ae/en/