• Our client had recently withdrawn complaints handling authority from its third parties. This had presented an additional regulatory risk given the number of third parties that were overseas and using different complaint handling approaches.
  • Their policyholders in the UK and overseas total over one million. Individual team leaders or senior management were now responsible for complaints handling. However, there were variations in the levels of complaints recognition, speed of resolution and quality of responses.
  • Our client’s existing complaints model fell short of regulatory requirements as it could not evidence the fair customer outcomes expected by the FCA.
  • A lack of a complaints governance framework and absence of root cause analysis (RCA) activity being undertaken, along with sub-standard management information (MI), meant that they needed to act as soon as possible.


  • We built an effective end-to-end complaints function responsible for all aspects of the complaints process across their UK and overseas business. This was compliant with regulatory requirements and demonstrated that customers were receiving a fair outcome.
  • Our key actions included the formation of:
    • A practical complaints framework with a complaints database producing a suite of quantitative and qualitative MI; an internal procedure operating in accordance with the requirements of the FCA Dispute Resolution (DISP) sourcebook; a training and competence scheme for complaint handlers; and a robust RCA approach.
    • A centralised complaints function at our client’s UK Head Office, which included recruitment of a Head of Complaints and a small team, a ‘pilot’ period to test the complaints framework and the recruitment of ‘complaints champions’.
    • A programme to ensure the complaints model, centralised team and complaints champions would be adopted into the company’s culture and deliver effective results quickly. This programme incorporated training on complaints recognition, workshops for the nominated complaints champions and bespoke training for the team.


  • After building the complaints framework, we helped embed it, and provided validation that the framework, and MI being produced would enable our client to evidence fair customer outcomes were being delivered.
  • We enabled our client to undertake better RCA, reduce the volume of complaints received and establish a better QA system to identify and rectify poor decisions.
  • We implemented the framework in the cover holder population and all overseas branches to ensure a consistent and effective complaint operating model was in place, delivering both fair customer outcomes and facilitating the accurate reporting of complaint numbers - meeting current and future regulatory requirements.