Creating your firm's complaints policy

Questions you need to address within your policy:

Addressing minor errors

Is the customer ringing with a formal complaint or a minor grumble that can be quickly resolved e.g. a mistype or missing attachment? Staff make errors and most customers are accepting of minor one-off mistakes that are quickly rectified. You need to decide whether to record all errors or just those leading to formal complaints.

Formal Complaints
Routes for customer complaints

How can customers make a complaint? If a complaint is received by phone, does the client need to put it in writing?

Dealing with third parties

Can someone else complain on their behalf? Should you ask for permission from your customer to deal with a third party on their behalf?

Who should your client contact?

How will your company deal with a complaint? Who is competent to deal with complaints? Who will review the response? Do you need a complaints manager?

Timing of responses

How quickly should the customer expect a response? If the complaint isn’t adequately resolved can they complain to another party e.g. your Managing Director or your regulator?

Audience for your policy

Who will you share your policy with? Will it be internal only or external? Will it be a link on your website? Could you send it out with your Terms of Business? Or will you only send it to those clients who complain?

Notifying Insurers

Insurers need prompt notification of complaints that may give rise to a claim. If you buy your insurance through a broker, such as Ntegrity, you should notify us in the first instance and we will liaise between you and the insurer.


You need to decide how you will monitor complaints, including resolved ('closed') issues and those still outstanding (‘open’). There needs to be enough detail for you to spot patterns, to identify solutions and to fully disclose outstanding matters for your regulator and at your next insurance renewal.

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