Complaints handling

According to EIOPAs "Guidelines on Complaints-Handling by Insurance undertakings" published 16th of November (EIOPA-BoS-12/069) and directive "Retningslinjer for forsikringsselskapers interne klagebehandling" published by The Financial Supervisory Authority of Norway (Rundskriv 4/2013), all insurance companies are to have in place a well functioning complaints handling process and they are also obliged to make this information public.

A complaint is a formal document in writing from the assured to the insurer that expresses dissatisfaction associated with the insurance policy or services delivered. The complaint is to set out the facts and reasons that the filing party or parties believes are sufficient to support the complaint. Complaints handling do not involve regular claims-handling or cases referred to an adjuster for his opinion or subject to legal proceedings by way of arbitration or before any court in Norway or any other country. Nor does complaints handling involve request for execution of the insurance contract, information or clarification.

The Compliance Officer is responsible for the complaints-handling process within Norwegian Hull Club and all complaints are to be directed, in writing, to the following email address:

All complaints received by the Compliance Officer are to be investigated fairly and possible conflicts of interest to be identified and mitigated. The Compliance Officer is also responsible for issuing a receipt for received complaints including an indicative handling timeline. The Compliance Officer is also responsible for communicating with the complainant, in a clear and accurate manner and also communicates the outcome of the complaint-handling process.

The Compliance Officer is to analyze, on an on-going basis, complaints-handling data to ensure that we identify and address any recurring or systematic problems, and potential legal and operational risk, for example, by:

  • Analyzing the causes of individual complaints so as to identify root causes common to types of complaint;
  • Considering whether such root causes may also affect other processes or products, including those not directly subject to complaints; and
  • Correcting, where reasonable to do so, such root causes.