SI Insurance (Europe), SA (Sompo International)

Global Benefits Europe BV (GBE) is committed to providing a quality service for all of our customers. One of the ways in which we continue to improve our service is by listening and responding to the views of our customers, and in particular by responding positively to complaints, rectifying errors we identify through our complaints handling process, learning from mistakes that may have been made and implementing change when necessary.

Therefore, our aims are to ensure that:

• Making a complaint is as easy as possible.

• All complaints are investigated competently and diligently, and when appropriate, confidentially.

• Customers are kept informed regarding the progress of our investigation.

• A fair and reasonable outcome is delivered, following a thorough investigation into the complaint.

• Feedback we receive is used to improve the service we provide to our customers.

• The complaints policy and procedure are reviewed on a regular basis.

GBE is an Insurance Broker therefore we may use a panel of different companies, who provide various aspects of a customer’s insurance requirements. We also enter into agreements with insurers to act as their agent and in these instances will deal with your complaint as per their complaint handling process.

Please refer to the relevant company (listed below in Appendix 1) for further details of the correct process applicable for the company your complaint relates to.

How to make a complaint to GBE

If you are dissatisfied with our service you may submit your complaint via our Complaint Form, which may be accessed by visiting our website and navigating to the Forms page: www.gbg.com/#/OurSolutions/Forms.

Toll-Free +1.866.914.5333 (within the U.S. and Canada)

Phone +1. 905.669.4920 (outside the U.S. and Canada)

Email complaints@gbg.com

Or write to us at: Global Benefits Europe BV, Penningkruid 203984 BK, Odijk, Netherlands for the attention of The Complaints Manager.

Complaints Procedure

Recording your complaint

Upon receipt of your complaint, it will be logged on our internal complaints database. The complaint information stored is then analysed to help GBE identify any areas of concern and generally improve the service we provide to our customers.

Resolving complaints

GBE strives to resolve customer complaints as quickly as possible, our agents are often able to resolve a problem at the first point of contact, if this is not achievable, our aim is to resolve your complaint by close of business on the third day, following receipt of the complaint. If we have resolved your complaint within this timeframe, we will issue to you an Acknowledgement and Final Response Letter. This letter will detail the findings from our investigation into your complaint and the outcome.

Depending on your circumstances you may be able to refer your complaint to the Financial Services Complaints Tribunal (Kifid)*.

*Please refer to the Kifid section of this document for further details.

Complaints that require further investigation

In the event of GBE being unable to resolve your complaint within this time, GBE will send an Acknowledgement letter to you within five business days of you initially expressing dissatisfaction. This letter will confirm receipt of your complaint and advise that we are completing an investigation. As soon as we have completed our investigation we will contact you to discuss the outcome and look to resolve and close your complaint. Once the complaint has been closed we will issue to you our Final Response letter.

The Final Response letter will detail your right to refer your complaint to the Kifid*.

*Please refer to the Kifid section of this document for further details.

We always aim to resolve your complaint and provide a final response within four weeks, but if it looks like it will take us longer than this, we will let you know the reasons for the delay and regularly keep you up to date with our progress.

Eight weeks, following receipt of your complaint, GBE will either:

• Contact you to discuss the resolution to your complaint and send our Final Response letter, which will detail your right to refer your complaint to the KIFID*.

• Send a further Interim resolution letter, detailing why we are not yet in a position to discuss the resolution to your complaint, we will also indicate when we believe our investigation will be completed. At this point you will also be given the right to refer your complaint to the Kifid*.

*Please refer to the Kifid section of this document for further details.

Financial Services Complaints Tribunal (Kifid)

If you decide that you are dissatisfied with the outcome of your complaint, you may have the right to refer your complaint to the Kifid, but you must do so within three months of the date of the Final Response letter.

Further information about how to access the facility and how the process works can be obtained from: www.kifid.nl/#

Alternatively, you can contact Kifid by:

Phone: 070 - 333 8 999

Email: consumers@kifid.nl

Online Sales

If you, as the Insured, are a consumer under the ODR regulation (Regulation (EU) 524/2013) and purchased the policy online, you may also make a complaint via the EU’s online dispute resolution (ODR) platform. The website for the ODR platform is:http://ec.europa.eu/odr

Appendix 1

If GBE is not the appropriate respondent to your complaint

GBE is an Insurance Broker and Managing General Agent and therefore we use a panel of different companies, who each cover various aspects of a customer’s insurance policy.

In the event your complaint lies with one of the companies we use, we will pass details of the complaint to them and they will investigate the complaint, and contact you directly with their response. We will also send you a letter confirming your complaint has been forwarded to the relevant company and provide you with their contact details.

Please refer to the relevant company (listed below) for further details of the correct process applicable for the company your complaint relates to.

If your insurer is SI Insurance (Europe), SA (also known as Sompo International) the process is as follows:

Complaints related to a claim denial should be submitted as soon as possible.

The Insurer will review the information and provide an acknowledgment of receipt within a period not exceeding 10 working days from receipt of the complaint unless the response itself is provided to the complainant within that period. The Insurer undertakes to respond to each complainant without unnecessary delay and in all cases within a period of 30 days as from the date of receipt of his/her complaint, except where the complexity of the request requires an extensive analysis, in which case the Insurer will indicate the causes of the delay and the foreseeable date of its response.

Complaints can be sent using the form above or addressed to:

The Compliance Officer
SI Insurance (Europe), SA
40 avenue Monterey
L-2163 Luxembourg
Grand Duchy of Luxembourg
Email: complaints@sompo-intl.com

Step Two: Beyond Your Insurer

If we can’t respond fully to your complaint after you contact us, or you are unhappy with our final response, you can submit your complaint to the competent supervisory authority or, if you are a consumer, to the insurance mediation organization, before starting the legal proceedings.

In case you have not received a response or a satisfactory solution within 90 days of your complaint to the Insurer, you can contact the Commissariat aux Assurances (the CAA) in Luxembourg for the out-of-court complaint resolution within one year (12 months) term from the date of your complaint to the Insurer.

Commissariat aux Assurances
7 boulevard Joseph II,
L-1840 Luxembourg,
Grand Duchy of Luxembourg
Fax: +352 22 69 10
Email: reclamation@caa.lu
Website: www.caa.lu

You may also use the Complaint Form available at the following address:

http://www.caa.lu/uploads/documents/files/DRER_EN.pdf

Alternatively, if you are a consumer, you can refer your complaint to an Insurance Ombudsman in Luxembourg:

Association des Compagnies d'Assurances (ACA)
c/o Médiateur en Assurance
B.P. 448
L-2014 Luxembourg
Grand Duchy of Luxembourg
Fax: +352 44 02 89
Email: mediateur@aca.lu
Website: https://www.aca.lu/