Complaints Policy
REVIEWED 2023
This document provides guidelines for the resolution and the treatment of complaints made by our customers.
POLICY STATEMENT
At Nutec Insulations Ltd, we believe that if a customer wishes to file a complaint or express dissatisfaction, it should be easy for them to do so. It is Nutec Insulations policy to receive complaints and consider them as an opportunity to learn, adapt, improve and provide a better service.
In addition, a quick resolution of a complaint, in a way that respects and values the person’s feedback, can be one of the most important factors in recovering the persons confidence in our products and services. It can also help prevent further escalation of the complaint. A responsive, efficient, and fair complaint management procedure can assist us to achieve this on each complaint.
The purpose of this policy is to ensure that complaints are dealt with consistently and properly and that all comments and complaints are taken seriously. This organisation expects staff at all levels to be committed to fair, effective and efficient complaint handling.
OUR PRINCIPLES
Nutec Insulations Ltd will ensure that:
Our customers have a right to…
• be treated fairly and sensitively;
• be kept informed about what is happening with their complaint;
• and be advised of the service standards they should expect;
• the timescale for acknowledging and responding to a complaint; and any right of appeal.
Our employees will…
be sensitive to the particular needs of customers;
treat complaints as confidential, where possible;
be accessible and clearly identified.
Our policy will…
• be open, easily accessible and widely promoted to all our customers and those who represent them
• be easy to understand and use by all customers and employees;
• set out how to complain and how a complaint should be handled
PURPOSE
This policy is intended to ensure that Nutec Insulations handle complaints fairly, efficiently and effectively. The company’s objective is to ensure that its complaints policy and procedures is properly implemented effectively, and that complainants feel confident that their complaints, worries or concerns are listen to and acted upon promptly and equitably.
Our complaints management system aims to:
• Allow us to respond to questions raised by people who file a complaint in a timely manner
• Increase the confidence of the person making a complaint or providing feedback and comments, in our administrative procedures, and
• Provide information that we can improve the quality of our products and services, staff training and complaint handling
This policy provides guidance to all our staff and to individuals who wish to file a complaint about our key principles and concept of our complaints management system.
Legal and Regulatory Requirements
The Financial Conduct Authority (FCA) expects firms to deal with complaints fairly and promptly, using competent staff and where appropriate provide compensation. Firms’ have the dual challenge of having to handle complaints in line with regulatory requirements whilst ensuring fair outcomes for their customers. We publish the details of our complaints process so that eligible complainants know how to contact the firm, to make a complaint.
Any firm regulated by the FCA is bound by its ‘Principles for Business’. Some of these Principles are directly relevant to Complaint Handling:
• Principle 6 – A firm must pay due regard to the interests of its customers and treat them fairly.
• Principle 7 – A firm must pay due regard to the information needs of its clients and communicate information to them in a way that is clear, fair and not misleading.
• Principle 8 – A firm must manage conflicts of interest fairly both between, itself and its customers and between a customer and another client.
The FCA defines a non-payment services related complaint 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, which alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience’.
The FCA defines a payment services related complaint as ‘any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a payment service user about the provision of, or failure to provide, a financial service or a redress determination:
(a) which alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience; and
(b) concerning the rights and obligations arising under Parts 6 and 7 of the Payment Services Regulations*
SCOPE
This policy applies to all staff receiving or managing complaints from customers made to us or about us, regarding our products, services, staff and complaint handling.
WHAT IS A COMPLAINT?
A complaint is an expression of dissatisfaction about our products, services, our staff, our actions or lack of actions taken regarding operations, facilities, advertising and marketing information and any body or company acting on our behalf.
A formal complaint means a complaint that has not been successfully resolved through our complaint management systems outlined in this policy.
The complainant has chosen to formalise the complaint by completing our complaint form, or by writing to us.
An informal complaint means a complaint that has been received by us, by phone, email, postal mail or in person, which has not been submitted on our complaint form.
WHAT TYPE OF COMPLAINTS WILL WE RECEIVE?
Our customers may complain:
• about the goods and services, we have supplied and installed, the way in which the sale was completed;
• the way that the goods were sold by our member of staff;
• the behaviour of any of our staff, including any of our senior managers;
• the cost of the goods;
• the way in which they have paid for the goods, including finance
This list is not exhaustive and they may complain about any aspect of our business and the service we have provided. Staff must treat all complaints with care and ensure they use our procedures and tools.
It is accepted that there will always be a degree of subjectivity in assessing if a customer is complaining, and the education and training provided to employees is designed to help drive consistency, in this important part of the Complaint Handling Process.
It is expected that the majority of complaints can and will be resolved to the customers satisfaction, by close of the third business day following the day on which it is received, by the business line receiving the complaint.
More complicated complaints and those that cannot be resolved by close of the third business day following the day on which it is received, will be dealt with by the named complaints contact, Robert Fodor, the director of the business.
Customers in vulnerable circumstances are more likely to have different needs when dealing with a firm than the average consumer. The firm and its staff need to recognise and meet those needs as vulnerable customers are more likely to suffer harm from a poor service. Vulnerable customers should experience outcomes as good as those for other consumers.
There are six main stages to a complaint:
1 – Recognising a Complaint
2 – Recording a Complaint
3 – Investigating and resolving a complaint fairly, consistently and promptly
4 – Compensation payments
5 – Root Cause Analysis (RCA)
6 – Lessons Learned
COMPLAINT MANAGEMENT SYSTEM
a) Oral Complaints
Nutec Insulations staff who receive a verbal complaint should try to resolve this immediately if possible. If staff cannot resolve the issue immediately, they should offer to refer this to the complaints manager for resolution.
• The complaints manager will be a named person who deals with complaint through the process. When staff or management receive an oral complaint, both should listen sincerely to the issues raised by the complainant. Any contact with a complainant must be polite, courteous and sympathetic. At all times, staff and management must remain calm and respectful.
• After discussing the issues raised each staff member or management handling the complaint should suggest an action plan to resolve the complaint. If this action plan is acceptable, staff or management should clarify the agreement with the complainant and agree on a way in which the results of the complaint will be communicated to the complainant – this may mean a meeting or in writing.
• If the proposed action plan is not acceptable to the complainant, staff or management should ask the complainant to make their complaint in writing to Nutec Insulations and provide a copy of our complaint’s procedure and a complaint form.
• In both situations, details of the complaint should be recorded on a complaint form and uploaded to the firm’s customer data base.
b) Written Complaints
• When a complaint is received in writing, it must be forwarded to the named complaints contact, Robert Fodor director of Nutec Insulations, who must enter the details into the complaints log and then send a acknowledge receipt within 3-working days in order to establish a relationship of confidence with the person who has raised the complaint.
• If necessary, further clarification should be obtained from the complainant. If the complaint is not made by our customer, but is made on their behalf, the customers consent, preferably in writing, must be obtained in advance from the customer.
• After receiving the complaint, a copy of the complaint’s procedure must be given to the customer. Clearly and politely explain the complains process, the time it may take and realistic expectations. We may have to arrange a visit to the customer’s home. This must be arranged within 14-days and confirmed in writing.
• Immediately on receipt of the complaint Nutec Insulations will launch an investigation and within 28-days should be in a position to provide a written explanation to the complainant, either in writing or arranging a meeting to visit the individuals concerned. On some occasions this may not be possible. We will write to the customer and explain that we are still investigating, why there is a delay and propose a date that we hope to provide them with an explanation.
MANAGEMENT INFORMATION
Complaints are an important management tool which allows us to learn about the products and services we provide. They are a useful source of information about how the customers see our services and how we are serving our customers.
To ensure that Nutec Insulations Ltd can learn from its complaints, the following data should be collected for every complaint received:
• The name and address of complainant
• Contact details for the complainant
• The name and role of the person dealing with the complaint
• The dates on which the complaint was received and on which it was responded to
• The nature of the complaint
• The outcome of the complaint
• How the complaint was received
• Remedial/Redress action carried out in response to the complaint
• Lessons learnt from the complaint
It is important that complaints information is reported and considered on a regular basis and shared at all levels with Nutec Insulations.
The following methods will be used to report complaints information.
• A weekly report to the management (directors/owners)
• A monthly overview report complied by the management team
• A 6-monthly report to show the data, causes and actions taken to avoid these complaints in the future
We use some core principles that help us to provide effective management data, effective root cause analysis. Not only will these help the analysis quality, but these will also help the analyst gain trust and buy-in from staff and customers.
• Focus on correcting and remedying root causes rather than just symptoms.
• Do not ignore the importance of treating symptoms for short term relief.
• Realize there can be, and often are, multiple root causes.
• Focus on HOW and WHY something happened, not WHO was responsible.
• Be methodical and find concrete cause-effect evidence to back up root cause claims.
• Provide enough information to inform a corrective course of action.
• Consider how a root cause can be prevented (or replicated) in the future.
The above principles illustrate when we analyse deep issues and causes, it is important to take a comprehensive and holistic approach. In addition to discovering the root cause, we should strive to provide context and information that will result in an action or a decision. Remember: good analysis is actionable analysis.
COMPLAINTS REPORTING
Nutec Insulations Ltd is authorised and regulated by the Financial Conduct Authority (FCA). As a regulated firm we will have to report to the FCA annually. We will need to report on all complaints received in relation to credit-related regulated activities only. All customer complaints are recorded on our complaints log, we will record on the log fi the customer has paid for the goods using the lenders finance product. We can then easily recognise those customers who must be provided with information about the Financial Ombudsman services.
DATA PROTECTION
To process a complaint, Nutec Insulations will hold personal data about the complainant. This includes data the complainant provides us and information that other people provide, about the complaint, in response to our enquiries.
Nutec Insulations will hold this data securely and only use it to help process the complaint.
The identity of the person making the complaint will only be made known to those who need to consider the complaint and will not be revealed to any other person or be made public by us. However, it may not be possible to preserve confidentiality in some circumstances, for example, where relevant legislation applies, or allegations are made which involve the conduct of any third parties, for example delivery of the goods from a manufacturer. Under the Freedom of Information Act 2000, customers have a right to obtain a copy of their personal data. However, there are exceptions to this right. We normally destroy our complaint files six years after the complaint has been closed. We will maintain records for finance customers for a maximum of 10-years.
OUR PROCEDURE
Any complaint verbal or written, including electronically, will be referred to our complaint’s manager at the earliest opportunity or to a member of the management if the complaints contact is unavailable. We will also:
• Record details on the firm’s complaints management system immediately
• We will not delay your complaint by asking you to write to us about your complaint
• We will acknowledge the complaint in writing promptly
• We will make contact to seek clarification on any points where necessary
• Fully investigate the complaint
• Keep you informed of our progress
• Discuss with you our findings and proposed response
• Provide clear deadlines to respond
• Provide the customer with a Final Response
You will receive contact from us advising on progress if we cannot respond immediately. We will let you have our final response as soon as possible and not later than eight weeks.
Customers may express dissatisfaction to us about our products, services, staff or advertising. We will need to establish if the complaint relates to the information given, the firm or the service and installation. If unclear, this must not delay investigation and we will proceed with our own investigation. The complaints contact will review this matter and take the complaint to the firm for them to investigate and provide a written explanation and any supporting information. This may include photos, checklists or remedial satisfaction notes.
INVESTIGATION
The complaints manager will establish the nature and scope of the complaint having due regards to the Financial Conduct Authority’s direction:
• Deal with complaints promptly and fairly
• Give complainants clear replies and, where appropriate, fair redress
• We may take up to 8-weeks to provide a response
We will:
• Document and report the complaint
• Provide written information to the customer on the progress of their complaint
• Determine if we need to attend the customers property where the goods have been installed
• Arrange an appointment to survey the property
• Interview staff/installers
• Gather evidence including photographs
• Review and evaluate the information collated
• Take any necessary action
• Document your conclusions
• Follow-up
By keeping your customers informed about a problem you are proactively showing them that you are aware of it. And you are doing something about it. For most customers, this is enough to let them give you the benefit of the doubt and they will give you the time you need to fix the issue.
OUR CHANNELS OF COMMUNICATION
• Phone: Customers still love to speak to someone – especially when it comes to urgent issues. While it’s nice to be digital, always make sure a customer can reach someone by phone.
• Messaging apps: There are a number of communication channels for that our customers will be familiar with, messaging apps WhatsApp, Facebook Messenger, Text messages, Viber all are a great way to handle customer service messages over an extended period of time as they are managed as an ongoing conversation.
• Social media: Your customers use social media. They also use it to express how they feel, so unlike a direct email to your support team, engaging with customers on social media requires you to be proactive. Find existing conversations and engage with your customers.
• Email: After phone support, email is the most-used customer service channel. The great thing about email is that it creates a digital record of correspondence – both for you and the customer. And with the right technology, you can automate, escalate and route emails within your organization to improve response times.
• Chat: Great for helping people directly on your website, live chat allows you to communicate with customers in real time. The great thing about live chat is that it can be used by sales reps for upselling, marketing departments for lead generation and customer service teams to handle questions from customers.
All channels must be documented on the customer’s file. It is important to remember that our customers may be frustrated, upset or with limited ability to express themselves clearly, their language may not be acceptable. It is vital that all staff use appropriate, accurate and respectful information and responses to our customers.
We must retain accurate records for the relevant period required by the FCA DISP rules and in accordance with data protection legislation.
When we receive the initial compliant, we will provide a written acknowledgement. This must be in letter or email format. It is best to find out early on how the customer wishes to be communicated by. We must consider their personal circumstances as they may be working with limited access to their phones, work night shifts, they may not have access to a mobile phone, laptop or any technology.
It is a minimum expectation to keep our customers updated of their complaint via their preferred method of communication on a weekly basis. However, there may be occasions where a customer will want more or less updates. We should be clear with all our customers and dependant on the potential length of time to resolve their complaints, for example we may need to order replacement goods and there may be a manufacturer delay, we should speak with our customers and ask what works for them so we can work together to resolve their complaint.
This information must be clearly documented on the customer’s file. The firm has documented our suppliers and their delivery timescales. This helps staff to manage customer expectations as well as our workflow.
ELIGIBLE COMPLAINTS
It is the firm’s policy to treat all complainants the same, however, eligible complainants, customers that have purchased goods and services using a lenders finance, are legally defined and have additional rights in law that we must acknowledge and adhere to.
THE FINANCIAL CONDUCT AUTHORITY RULES APPLY TO COMPLAINTS:
• Made by, or on behalf of an eligible complainant.
• Relating to regulated activity.
• Involving an allegation that the complainant has suffered, or may suffer, financial loss, material distress or material inconvenience.
FINAL RESPONSE
This will set out clearly our decision and the reasons for it. If any compensation is offered a clear method of calculation will be shown.
The firm must include details of the Financial Ombudsman Service in the final response if dealing with an eligible complainant and a regulated activity, we will:
▪ Explain that the complainant must refer the matter to the ombudsman within six months of the date of the final response letter or the right to use this service is lost
▪ Indicate whether or not we consent to waive the relevant time limits.
COMPLAINTS SETTLED WITHIN 3 BUSINESS DAYS
Complaints that can be settled to the customer’s satisfaction within three business days can be recorded and communicated differently.
Where we consider a complaint to be resolved to the customer’s satisfaction under this section, the firm will promptly send a ‘Summary Resolution Communication’, being a written communication from them which:
(1) refers to the fact that the customer has made a complaint and informs them that they now consider the complaint to have been resolved to the customers satisfaction.
(2) The firm will tell the customer that if they subsequently decide that they are dissatisfied with the resolution of the complaint they may be able to refer the complaint back to the firm for further consideration or alternatively refer the complaint to the Financial Ombudsman Service;
(3) Provide the website address of the Financial Ombudsman Service; and
(4) Refer to the availability of further information on the website of the Financial Ombudsman Service.
In addition to sending you a Summary Resolution Communication, the firm may also use other methods to communicate the information where:
(1) We consider that doing so may better meet the customer’s needs; or
(2) They have already been using another method to communicate about the complaint. This may include recorded calls, emails or text messages.
COMPLAINTS FORWARDING
DISP 1.7 Complaints forwarding rules – FCA Handbook
The FCA has specific rules about informing our customers if we believe that their complaint may be solely or jointly the responsibility of another firm, person, a body or regulator. As a business we must ensure we document this on the customers file and provide the customer with written communication of this. This may be done via post, or email. There may be some circumstances, where the customer has communicated their preferred method of communication, that we communicate in the customers preferred method.
We will communicate this as soon as possible and explain the reasons for our decision in a clear and concise way.
A respondent (the firm) that has reasonable grounds to be satisfied that another respondent may be solely or jointly responsible for the matter alleged in a complaint may forward the complaint, or the relevant part of it, in writing to that other respondent, provided it: (1) does so promptly; (2)
1. does so promptly;
2. informs the complainant (customer) promptly in a final response of why the complaint has been forwarded by it to the other respondent, and of the other respondent’s contact details; and
3. where jointly responsible for the fault alleged in the complaint, it complies with its own obligations under this chapter in respect of that part of the complaint it has not forwarded
As a firm we may receive a Complaint via Complaint forwarding. On receiving a forwarded complaint, the standard time limits will apply from the date on which the respondent receives the forwarded complaint.
COMPENSATION PAYMENTS
Nutec Insulations Ltd has a customer centric approach to complaint handling where colleagues are empowered to take ownership and resolve customer dissatisfaction in a timely fashion and in a manner that impresses our customers. We understand that some complaints might seem similar to others, but every complaint is different, and compensation needs to reflect the impact on each customer.
For each complaint, will be reviewed by the director and they will consider the individual circumstances to decide whether it is appropriate to offer compensation.
Robert Fodor will follow the examples as set out in the compensation guidelines to assist in deciding the appropriate level of payment to make to customers so that customers are treated fairly and any compensation payments are consistently applied. This may involve one or more of the following:
Apology: A financial award is not always appropriate. Often, a simple, heartfelt apology will be sufficient and may go a lot further than offering a monetary payment.
Redress: A payment to restore the customer to the financial position they would be in if things had not gone wrong.
Distress: The emotional impact caused to the customer by something going wrong.
Inconvenience: The time it has taken the customer trying to right something that has gone wrong.
The Financial Ombudsman (FOS) defines distress as including upset, embarrassment, anxiety, disappointment, loss of expectation and stress. They expect a firm to consider how much their action has affected the complainant and respond accordingly.
All colleagues should be aware of the firm’s financial mandate as to whether they have the authority to make the appropriate level of payment necessary or should refer it to their line manager for authorisation
The firm needs to comply promptly with any offer of remedial action or redress accepted by the complainant.
CLOSING A COMPLAINTS
We will consider a complaint closed when we have made our final response to the customer. This does not prevent a customer from exercising any rights they may have to refer the matter to the Financial Ombudsman Service.
Our final response must include:
(a) if we accept the complaint and, where appropriate, offers redress or remedial action; or (b) offers redress or remedial action without accepting the complaint or (c) rejects the complaint and we will give our reasons for doing so; and which: we will provide our customers with a copy of the Financial Ombudsman Service standard explanatory leaflet and the contact details including full postal address, phone number, email and a link to their online complaint form.
If you remain dissatisfied, you may refer your complaint to the Financial Ombudsman Service.
FINANCIAL OMBUDSMAN SERVICES
We will co-operate fully with the Ombudsman in resolving any complaints made against us and agree to be bound by any awards made by the Ombudsman. The firm undertakes to pay promptly any fees levied by the Ombudsman.
HOW LONG YOU HAVE TO COMPLAIN TO THE FINANCIAL OMBUDSMAN SERVICE
You have the right to refer your complaint to the Financial Ombudsman Service, free of charge – but you must do so within six months of the date of our final response letter.
If you do not refer your complaint in time, the Ombudsman will not have our permission to consider your complaint and so will only be able to do so in very limited circumstances. For example, if the Ombudsman believes that the delay was as a result of exceptional circumstances.
The Ombudsman might not be able to consider your complaint if:
• what you’re complaining about happened more than six years ago, and
• you’re complaining more than three years after you realised (or should have realised) that there was a problem. We think that your complaint was made outside of these time limits, but this is a matter for the Ombudsman to decide. If the Ombudsman agrees with us, they will not have our permission to consider your complaint and so will only be able to do so in very limited circumstances
CONTACT DETAILS FOR THE FINANCIAL OMBUDSMAN SERVICE
The Financial Ombudsman Service, Exchange Tower, London E14 9SR
Tel: 0800 023 4567 (free for most people ringing from a fixed line) or 0300 123 9123 (cheaper for those calling using a mobile) or 020 7964 0500 (if calling from abroad)
Email: complaint.info@financial-ombudsman.org.uk
Website: www.financial-ombudsman.org.uk
You can make a complaint through one of the Financial Ombudsman Services online forms, and find out more about the information you’ll need to have to hand before you start filling the form in.
RESPONCIBILITY FOR THE POLICY
The directors and owners of the business as responsible for monitoring the policy on an annual basis. Robert Fodor is responsible for the overall policy and its reviews.
To be signed by all members of staff to confirm their understanding of this policy and have completed
Complaints Policy:
A signed copy to be kept on your personnel file, and to include annual training as a minimum. This policy will be reviewed and updated annually by the directors of the business.
NUTEC INSULATIONS LTD – COMPLAINTS CONTACT DETAILS
Complaints Contact
Robert Fodor – Director and Business Owner
T: 0800 246 1910
