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2-25
Complaint examination process
The complaint examination stages at PZU and PZU Życie include:
- immediate examination of the circumstances of the case;
- assessment of the validity of the issues raised;
- taking a position;
- taking actions to rectify the identified faults, if any;
- replying the client and external body if that body lodged a complaint on the client’s behalf.
Information about the causes of the grievances is analyzed also by the persons responsible for the areas to which they pertain. This is aimed at taking actions which may eliminate the causes of the complaints and their sources in the future. This applies in particular to product offer development, sales, distribution channels, external partner network (including cooperation with service providers and contractors), customer service, claims handling and marketing.
Complaint prevention system
Based on the conclusions drawn from complaints, all employees involved in examining complaints put forward complaints-related initiatives, or ideas for improvements and on how to eradicate the sources of these complaints and client dissatisfaction, to the Client Relations Department (the owner of the complaint handling process). For this purpose, an appropriate tool has been created: the Client Improvement Database (BUK). The Client Relations Department is responsible for handling all submitted initiatives: verifying all submitted ideas, checking the reasonability of proposed changes with business owners, monitoring the progress of work and then reporting on the outcome of changes and their business impact.
Ratio of complaints handled within 30 days
| 2021 | 2022 | |
|---|---|---|
| PZU Group | 97.9% | 97.6% |
| PZU and PZU Życie | 98.4% | 98.0% |
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Penalties and proceedings
In 2022, the Polish Financial Supervision Authority imposed financial penalties on PZU, these penalties were imposed because of PZU’s failure to pay out claims timely, as referred to in Article 14(1) and (2) of the Act on the Mandatory Insurance, Insurance Guarantee Fund and Polish Motor Insurers’ Bureau Act, and in conjunction with PZU’s failure to satisfy the disclosure obligation referred to in Article 14(3) of the said Acty:
- 25 February – in the amount of PLN 397,000 (after reviewing PZU’s request for reconsideration, the FSA upheld the September 2021 decision);
- 13 May – in the amount of PLN 685,000;
- 27 May – in the amount of PLN 546,000;
- 22 July –in the amount of PLN 115,000.
| Penalties for consumer rights violation | PZU | PZU Życie | ||
| 2021 | 2022 | 2021 | 2022 | |
| Non-financial sanctions due to legal or regulatory non-compliance (number) | 0 | 0 | 0 | 0 |
| Total material penalties for legal or regulatory non-compliance | 0 | 0 | 0 | 0 |
| Cases under dispute resolution mechanisms | 0 | 0 | 0 | 0 |
| Financial penalties imposed by KNF | 1 | 3 | 0 | 0 |
| Total financial penalties imposed by KNF (in PLN ‘000) | 397 | 1,346 | 0 | 0 |
|
Comments to 2021: penalty became effective in 2022.
Comments to 2022: the penalties amounted to 0.01% of PZU’s premium in 2022. Other PZU Group companies: did not report penalties for consumer rights violations in 2021 or 2022. |
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Complaints and grievances – agents
Management of complaints and grievances in subsidiaries
PZU CO has in place the “Regulations for handling complaints/grievances reported to PZU CO regarding the Company’s agency activities.
PTE PZU has adopted a set of rules and regulations for examining complaints, procedures for handling correspondence and rules and regulations for using services provided by PTE PZU.
PZU Pomoc has in place, among others, the “Customer Service Quality Policy”, “Client Experience Management Policy” and “Guidelines for accepting and examining complaints”.
LINK4 has in place the “LINK4 TU S.A. Complaint Procedure” and the “Rules and regulations for accepting and examining complaints and appeals”.
TUW PZUW has a „Procedure for examining complaints in TUW Polish Mutual Insurance Company”.
A number of policies are in place in foreign insurance companies, defining, among other things, the processes and bases for creating and modifying insurance products, as well as the client complaint handling principles and responsibilities. Lietuvos Draudimas has, among others, the “Policy: Insurance Products”, as well as the “Client Complaint Management Policy” in place. AAS Balta has the “Insurance Portfolio Management and Development Policy” and the “Guidelines for communicating with clients”. Similarly, the Estonian Branch has adopted the “Client Complaint Examination Policy”. The companies in Ukraine, in turn, have the “Rules for examining complaints” in place.
A procedure has been rolled out in PZU Zdrowie describing the rules for the workflow, records and examination of complaints by the Client Relation Section and PZU Zdrowie branches.
It also defines responsibility in this process and the method of reporting complaints. Also in place is the “Patient Service Standards Book”, which contains non-medical service standards intended for various professional groups in medical centers. It is also conducted periodic client satisfaction surveys on clients to whom PZU provides medical care services. Through satisfaction surveys, we systematically monitor the quality of service at hotlines and medical centers. PZU Zdrowie monitors the level of loyalty and client satisfaction at the selected stages of the medical service booking and provision process, such as contact with the hotline and reception desk, visit at the treatment room and at the doctor’s surgery. A procedure has been rolled out in PZU Zdrowie describing the rules for the workflow, records and examination of complaints by the Client Relation Section and PZU Zdrowie branches. It also defines responsibility in this process and the method of reporting complaints. PZU Medical Centers also enjoy a package of regulations concerning medical safety.
TFI PZU has also adopted the “Policy for acting in the best interests of clients and funds”, which defines TFI PZU’s principles and activities aimed at generating the best possible results for the funds and the clients through the provision of professional services, having regard to the nature of the services or other aspects having a material impact on their provision. Additionally, the “Rules and regulations for the provision of financial instrument portfolio management services by TFI PZU” are in place, defining the rules and conditions for the provision of portfolio management services by TFI PZU in respect of portfolios comprising one or more financial instruments. The Client must read it before entering into the Agreement. TFI PZU also has the internal “Customer Service Procedure for Mutual Fund Clients of TFI PZU”, setting out the general customer service principles applicable at TFI PZU for clients to whom the purchase of participation units in mutual funds or subscription for mutual fund investment certificates is offered.
TFI PZU also has a procedure in place for handling complaints submitted by its clients and clients of its mutual funds. It defines the principles and guidelines for dealing with complaints submitted by clients of the mutual fund management company or its mutual funds in connection with TFI PZU’s activities in the field of mutual fund establishment and management, in particular regarding brokerage in selling and redeeming participation units, accepting subscriptions for investment certificates, providing management services for portfolios which include one or more financial instruments and fulfilling obligations towards its clients. Furthermore, TFI PZU developed a customer service procedure for clients who use the portfolio management service of Towarzystwo Funduszy Inwestycyjnych PZU. It is an internal document that governs activities related to the establishment and termination of cooperation between TFI PZU and its client related to managing portfolios of financial instruments and activities related to customer service.
Alior Bank has the “Service Quality Standards Book” in place, defining the individual and business customer service principles. The Customer Experience Team continuously monitors the quality of service, prepares market benchmarks, as well as engages in customer experience surveys and improvements through Customer Journey analyses. It also continues to build new and improve current customer service standards, having in mind all the points of contact between the client and bank. The Customer Experience Team also has the transfer of clients into the digital world in mind. It wants to encourage clients towards self-service, educate them in using Alior Bank’s functionality which its competitive edge on the e-banking market
It pursues duties within the Recommendation Group, the main objective of which is to minimize the number of complaints filed with the bank. The Group gathers key substantive and technical units, owners of business products and processes, systems, e-banking, risk, sales and quality. The Group analyzes the largest complaint categories in terms of volume, and verifies the factors which have led to the complaints, in terms of both products and processes, and issues recommendations concerning their amendment/ modification.
PZU’s Client Ombudsman
The Client Ombudsman has established cooperation with the National Association of the Deaf (PZG) to best align insurance products with the needs of deaf and mute clients. In collaboration with PZG, we made a video showing how deaf and mute persons could use PZU road assistance service. The video has been posted on PZG’s website.
| Cases reported to the PZU’s Client Ombudsman | 2021* | 2022 |
|---|---|---|
| motor insurance | 46% | 40% |
| protection insurance | 25% | 29% |
| health insurance | 12% | 5% |
| property insurance (buildings and residential units) | 8% | 9% |
| other | 9% | 17% |
In difficult and complex cases that require additional analysis, LINK4 clients can count on the support of the Client Ombudsman. The Ombudsman analyzes the cases of clients who completed the complaint procedure and still disagree with how their case was resolved. Clients can contact the Client Ombudsman via a short form available on the website, and also via mail or e-mail.
The Client Ombudsman is the voice of the clients in LINK4, but may also influence the quality of processes and products by making recommendations and suggestions to the business which result from the cases reviewed by the Client Ombudsman. The Client Ombudsman also analyzes the cases forwarded to the Management Board of LINK4.
TUW PZUW appointed a Customer Ombudsman in 2022. He or she assists customers in difficult cases and those requiring quick intervention that cannot be handled according to the standard complaint procedure or require additional legal or expert opinions.
The Customer Ombudsman also initiates and implements activities in the Society to improve, unify and streamline customer service standards.
To better understand the patients’ needs and strengthen relationships with them, in December 2020, PZU became the first insurer in Poland to appoint the Health Ombudsman. It is a unique function, which has no equal in the entire private medical care and insurance market. The chief duty of the Ombudsman is to engage in a dialog with patients and support them at every stage of their medical care, from the moment of purchase to visit or examination at medical facility. The Health Ombudsman analyzes cases reported by the patients impartially, objectively assessing service quality and the procedures applied. Close contact with patients allow him or her to have real impact on the development of new solutions and health products. Patients have slightly different requirements, needs or problems compared to insurance clients. Clients may contact the Health Ombudsman through an online form or e-mail. In 2022, the Health Ombudsman received 108 cases to consider.
The Health Ombudsman’s duties also include educating clients and promoting healthy lifestyle, preventive medical testing and physical activity. Thanks to their skills and competences, the Health Ombudsman supports the employers who have decided to take out insurance at PZU in caring for the health of their employees.
At Bank Pekao and Alior Bank, we have Client Ombudsmen who deal with specific cases which cannot be resolved within the standard complaints procedure or which require additional legal or expert opinions. They also support clients in clarifying complex and multithreaded cases. They make sure that all actions take account of the client’s perspective and propose solutions that satisfy both parties.
Best practices in subsidiaries
LINK4 client negotiations
An effective loss adjustment process and the conclusion of the case with a settlement contributes to the increased satisfaction of our Clients. The LINK4 Loss Division teams take proactive measures, including by entering into negotiations, to limit the risk of grievances being lodged with official bodies or the risk of court disputes. Strengthening Client relations is one of the main objectives of LINK 4’s strategy.
Additionally, difficult cases which due to various reasons cannot be resolved by means of a settlement at the claims handling stage are referred to the Mediation Center of the Arbitration Court at KNF. It was observed that attorneys of injured persons are eager to use this form of mediation. Thanks to the efforts undertaken, we have significantly reduced the number of appeals, complaints to the Financial Ombudsman and costly civil proceedings.