What is a Complaint

A complaint is defined by the FCA as:

“Any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, or failure to provide, a financial service or a redress determination, which:

a) alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience; and

b) relates to an activity of that respondent, or of any other respondent with whom that respondent has some connection in marketing or providing financial services or products, which comes under the jurisdiction of the Financial Ombudsman Service.”

Our Commitment to you

We are committed to delivering the highest standards of customer care and service. If you are unhappy with any aspect of the handling of your insurance, we ask you to contact the department concerned in the first instance. Should you need to make a complaint, please contact us using any of the following methods:

How to contact us with your complaint

Should you wish to contact us via email, please use: complaints@spinnuw.com

Should you wish to contact us in writing: 34 Lime Street, London, EC3M 7AT, United Kingdom

What will we do once we receive your complaint?

We have centralised the management and resolution of complaints across our group of companies to ensure consistency and swift handling of all complaints. However, we recognise that not all complaints will require a full investigation or will fall within the FOS jurisdiction. As such, we will triage all complaints received at a local level from our London offices, passing only those which require full investigation and resolution to our internal group complaints processing team.

Regardless of whether the complaint is managed and resolved locally or by our central team, all complaints from eligible complainants will be handled in accordance with the relevant regulatory and FOS expectations and timescales.

Complaint Acknowledgement

We strive to send complainants a written acknowledgement of their complaint within five business days of receipt along with a copy of this policy and procedures.

Your complaint will be referred to our Complaints Manager as soon as possible. In the event that the Head of Quality or Compliance is involved in the subject matter of the complaint, your complaint will be referred to another member of our Senior Management Team. In this acknowledgement, we will provide the name and title of the person handling your complaint. This individual will have the authority necessary to investigate and settle the complaint. We will also include a copy of this policy.

Complaint Investigation

We will investigate the complaint and, where required, may contact the complainant to obtain further information to conduct a thorough investigation. The nature of the investigation will depend on the nature of the complaint and may involve interviewing relevant staff.

The company will ensure that the individual(s) involved in investigating complaints are independent and have not been involved in the events complained about.

We will investigate your complaint fairly, consistently, and promptly, determine whether the complaint should be upheld, and (if appropriate) determine remedial action and / or redress. We will set out our conclusions in a final response to you.

We will always endeavour to communicate with you in a clear and fair manner while we are investigating your complaint.

If we decide that redress is appropriate, we will endeavour to provide you with fair compensation for any acts or omissions for which we are responsible. If you accept our offer, we will promptly provide the compensation.

Our timetable for responding to you

Once we have acknowledged your complaint, we will keep you informed of our progress. Within eight weeks of us receiving your complaint we will send you either a summary resolution (if resolved within 3 business days), a final response, or a written holding response (if we have been unable to complete our investigation and resolution) which:

• explains why we are not in a position to make a final response to you and when we expect to be able to provide one; or
• if your complaint is upheld and, where appropriate, offers redress or remedial action; or
• offers redress or remedial action without accepting the complaint; or
• rejects the complaint and gives reasons for doing so.
• outlines your right to refer the complaint to the Financial Ombudsman Service (“FOS”); and if so,
• encloses contact details for the Financial Ombudsman Service.

Financial Ombudsman Service (“FOS”)

If you are an eligible complainant, you can refer a complaint to the FOS if you are not satisfied with the outcome of your complaint. Your rights are set out in the FOS's leaflet “Your Complaint and the Ombudsman” which we will provide to you as part of the Complaints process. Please remember that if you wish to refer a complaint to the FOS, you must do so within six months of receiving our final response.

You should allow us to complete our internal Complaints Procedure before you refer your concerns to the FOS.

You can contact the FOS online, by phone, by email or in writing:

Closing Complaints

We will regard your complaint as closed in the following circumstances:

• once we have sent you a final response; or
• if you have told us in writing that you accept an earlier response that we have sent to you; or
• if you refer your complaint to FOS, when FOS informs us in writing that the complaint has been closed.

We are committed to ensuring that all complaints received are handled fairly, consistently, and promptly and that the company identifies and remedies any recurring or systematic problems, as well as any specific problems identified by a complainant. We will continue to learn from the complaints we receive to improve our level of service to you.