Complaints Policy

CARVADO

COMPLAINTS POLICY

Document ID:

CAR-LGL-009

Version:

1.0

Classification:

Public

Status:

Draft for Final Legal Review

Document Owner:

Carvado Membership Team

Effective Date:

[To be completed]

Review Date:

[To be completed]

Last Updated:

[To be completed]

ABOUT THIS DOCUMENT

This Complaints Policy forms part of the Carvado Membership Legal Centre.

This document should be read together with the Terms & Conditions.

Where any inconsistency exists between this document and the Terms & Conditions, the Terms & Conditions shall take precedence unless applicable law requires otherwise.

The purpose of this document is to explain how Members may raise complaints, how complaints are investigated and how Carvado aims to resolve concerns fairly, consistently and professionally.

CONTENTS

1 Introduction

2 Our Commitment

3 What Is A Complaint?

4 How To Make A Complaint

5 Complaint Investigation

6 Complaint Outcomes

7 Escalation

8 Complaints Standards

9 Malicious Or Abusive Complaints

10 Continuous Improvement

11 Governing Law

12 Version History

Carvado is committed to providing Members with a high standard of service.

Where something goes wrong, we want to know about it.

Complaints allow us to investigate issues fairly, resolve concerns wherever possible and continually improve the Membership experience.

This Complaints Policy forms part of the Membership Legal Centre.

Capitalised terms have the meanings given within the Terms & Conditions unless expressly defined otherwise.

This Policy applies to complaints relating to:

• Membership;
• Member Accounts;
• Membership Benefits;
• Insurance Review services;
• Member support;
• payments;
• Referral Programme participation;
• website functionality;
• Digital Resources;
• Events;
• staff interactions;
• any other Membership service operated by Carvado.

Every complaint will be considered fairly.

No Member will be treated less favourably simply because they have submitted a genuine complaint.

Complaints will be handled professionally, respectfully and objectively.

Our aim is always to understand the issue before reaching a conclusion.

We ask Members to raise complaints honestly and in good faith.

Similarly, Carvado will investigate complaints honestly and impartially.

Complaints are viewed as an opportunity to improve.

Where appropriate, lessons learned from complaints may lead to improvements in:

• Membership Benefits;
• operational procedures;
• customer communications;
• website functionality;
• Member support;
• training;
• future Membership development.

3 WHAT IS A COMPLAINT?

A complaint is any expression of dissatisfaction regarding Carvado's Membership services where the Member expects a response or resolution.

Examples include concerns relating to:

• Membership administration;
• support received;
• delays;
• billing;
• referrals;
• website issues;
• Dashboard issues;
• communications;
• Membership Benefits;
• staff conduct.

The above examples are illustrative only.

General suggestions, feature requests and ideas are welcomed but are not normally treated as formal complaints unless the Member requests this.

Members may submit complaints using the communication methods made available by Carvado.

These may include:

• email;
• the Member Dashboard;
• online contact forms;
• written correspondence;
• another communication method published by Carvado.

To assist our investigation, Members are encouraged to provide:

• their name;
• Membership details;
• a description of the issue;
• relevant dates;
• supporting documents where available;
• the outcome they are seeking.

Providing additional information may help us resolve the complaint more quickly.

Where reasonably practicable, Carvado will acknowledge receipt of a complaint within a reasonable period.

Acknowledgement confirms receipt only and does not indicate the outcome of the investigation.

Once a complaint has been received, Carvado will carry out an investigation that is appropriate to the nature, complexity and seriousness of the issues raised.

Every complaint will be assessed individually.

As part of the investigation, Carvado may review information including:

• Member Account records;
• Membership history;
• payment records;
• communication history;
• support conversations;
• website activity where relevant;
• documents provided by the Member;
• internal operational records;
• any other information reasonably necessary to investigate the complaint.

Where appropriate, Carvado may request additional information from the Member to assist with the investigation.

Failure to provide requested information may affect Carvado's ability to fully investigate the complaint.

Investigations will be conducted fairly, impartially and in good faith.

The Member's previous complaint history will not, by itself, affect the outcome of a new complaint.

Each complaint will be considered on its own facts.

Carvado aims to investigate complaints as promptly as reasonably practicable.

The time required will depend upon:

• the complexity of the issues;
• availability of relevant information;
• involvement of third parties;
• regulatory requirements;
• operational workload.

Any response times published by Carvado are targets only and do not constitute contractual guarantees.

Following completion of the investigation, Carvado will communicate its findings to the Member.

Where appropriate, Carvado may explain:

• what happened;
• the outcome of the investigation;
• any action taken;
• any proposed resolution;
• any further steps available to the Member.

Depending upon the circumstances, complaint outcomes may include:

• clarification or explanation;
• an apology;
• correction of an error;
• administrative action;
• payment correction;
• goodwill gesture;
• service improvement;
• no further action where the complaint is not upheld;
• another reasonable resolution considered appropriate by Carvado.

Where Carvado provides a goodwill payment, account credit, Membership extension or other gesture of goodwill, this does not constitute an admission of liability unless expressly stated.

Where Carvado considers that its investigation has concluded, a final response will normally be issued.

The final response will explain the outcome together with any further options available to the Member where appropriate.

If a Member remains dissatisfied after receiving Carvado's response, the Member may request that the complaint be reviewed further where an internal review process is available.

Where significant new evidence becomes available after the original investigation, Carvado may review the complaint again where appropriate.

Nothing within this Policy limits any legal rights available to Members under applicable law.

Where appropriate, Members may also have rights to refer matters to an appropriate regulator, ombudsman, alternative dispute resolution provider or court, depending upon the nature of the complaint and applicable legal requirements.

Carvado expects all complaints to be handled professionally by both Members and staff.

Constructive discussion often assists in reaching a satisfactory resolution more quickly.

Members should communicate respectfully throughout the complaints process.

Carvado similarly commits to treating every Member with courtesy, professionalism and respect.

Information relating to complaints will normally be handled confidentially and shared only where reasonably necessary to investigate, resolve or comply with legal obligations.

Carvado welcomes genuine complaints and constructive feedback.

Members should never hesitate to raise legitimate concerns.

Where Carvado reasonably believes that complaints are deliberately abusive, malicious, fraudulent, repetitive without new information or intended primarily to harass staff rather than resolve a genuine issue, Carvado may take reasonable steps to manage those complaints appropriately.

Examples may include:

• repeated complaints raising identical issues after full investigation;
• abusive or threatening communications;
• knowingly false allegations;
• complaints intended solely to disrupt business operations;
• excessive communications which prevent reasonable handling of other Member enquiries.

These examples are illustrative only.

Before restricting communications wherever reasonably practicable, Carvado will seek to distinguish genuine dissatisfaction from abusive conduct.

Any action taken will be proportionate to the circumstances.

Carvado regularly reviews complaints to identify opportunities to improve:

• Membership Benefits;
• operational procedures;
• Member communications;
• training;
• technology;
• website functionality;
• Member Dashboard functionality;
• support services.

This Complaints Policy may be updated periodically to reflect legislative changes, regulatory guidance, operational improvements and Member feedback.

The latest version will always be available within the Membership Legal Centre.

Document:

Complaints Policy

Document ID:

CAR-LGL-009

Version:

1.0

Classification:

Public

Status:

Draft for Final Legal Review

Effective Date:

[To be completed]

Review Date:

[To be completed]

Last Updated:

[To be completed]

Document Owner:

Carvado Membership Team

Review Cycle:

Annual or earlier where required by changes in legislation, regulation or Membership operations.

Revision History

Version 1.0

Initial publication.

END OF COMPLAINTS POLICY