COMPLAINTS HANDLING PROCEDURE

This document applies to Leslie B Holmes (Securities) Ltd trading as LBH Insurance.

At LBH Insurance, we are committed to providing a quality and professional service, and to act with honesty, integrity, and transparency. However, we understand that there may be times when you may feel we do not meet your expectations, and we want to know about these immediately, so any issues can be resolved quickly.

The way in which we handle and resolve complaints is consistent with the high levels of service we aim to give all our clients. It is our policy to ensure that all valid complaints are settled fairly, consistently, and promptly.

LBH Insurance is committed to ensuring that complaints are handled in accordance with the FCA's Dispute Resolution (DISP) rules and Consumer Duty requirements. We will seek to identify, prevent and remediate customer harm, particularly where complaints indicate systemic issues or poor customer outcomes.

Our complaints procedure is also designed to be consistent with regulatory requirements regarding dispute resolution, and additional rights will be available to ‘eligible complainants'.

ELIGIBLE COMPLAINANTS

An eligible complainant is defined in accordance with the FCA Handbook DISP rules and includes categories of complainants who may be entitled to refer complaints to the Financial Ombudsman Service ("FOS").

The definition of an eligible complainant may change from time to time in accordance with FCA rules. LBH Insurance will assess eligibility based on the FCA requirements applicable at the date the complaint is received.

RESPONSIBILITY

Overall responsibility for this procedure is assigned to LBH's Managing Director who will be made aware of all complaints received by LBH and will ensure that the correct procedures are enforced.

The Managing Director will receive regular management information regarding complaints, complaint trends, root-cause analysis, customer outcomes and any remedial actions taken.

INTRODUCTION

For the purposes of this procedure, we use the following definition of a complaint, which is “any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of a person about the provision of, or failure to provide, a financial service”.

Complaints may be made by customers, prospective customers, former customers, beneficiaries, representatives or other parties entitled to complain under applicable FCA rules.

HOW TO MAKE A FORMAL COMPLAINT

In the event, that you wish to make a complaint, you may lodge it in any format (face-to-face, telephone, letter, or email). 

However, we would ask that, in the first instance, you address your complaint to your Account Handler, Claims Handler, Company Secretary at:

LBH Insurance 

Units 1–6,

327 Southchurch Road,

Southend-on-Sea,

Essex,

SS1 2PE

Tel: 01702 347889

If you wish to lodge a complaint via email please send to enquiries@lbhinsurance.co.uk .

LBH Insurance will make reasonable adjustments where required to support vulnerable customers or customers with disabilities when making or pursuing a complaint.

Complaints can be submitted free of charge and will be handled fairly, promptly and impartially.

WHAT HAPPENS WHEN LBH INSURANCE RECEIVES YOUR COMPLAINT?

Initially your complaint will be assessed to determine if it can be resolved to your satisfaction within three business days of us receiving it. If you are an eligible complainant and we have resolved your complaint within three business days, we will confirm this by issuing to you a Summary Resolution Communication Letter. This letter will provide you with details of how to refer your complaint to the Ombudsman, should you subsequently decide you are unhappy with the resolution of the complaint.  

If the complaint cannot be resolved within three business days, the Managing Director will be informed.

The complaint will then be assessed to determine its nature and an appropriate independent Complaint Handler will be assigned to manage your complaint until it is resolved. The Complaint Handler will be a suitably skilled and experienced individual, who will not have been directly involved in the issue or event that caused the complaint. The Complaint Handler's handling of the complaint will be supervised by the Head of Operations of the relevant business unit and the Company Secretary.

The Complaint Handler will respond to you in writing, no later than five working days after receipt of the complaint.

The Complaint Handler will introduce themselves to you, acknowledge receipt of the complaint and will remind you of our Complaints Handling Procedure so you understand the process. The letter will give you an indication of when you can expect a final response. We aim to resolve all complaints at the earliest possible opportunity. 

If your complaint does not relate to a service that LBH Insurance provides, we will inform you in writing as soon as possible, but no later than five working days of receipt of the complaint. We will also assist you to identify the correct person or entity to whom your complaint should be addressed.

In order to fully understand the nature of the complaint and how it occurred, we will review all relevant documentation and materials, and speak to the LBH Insurance personnel involved in the issue, and you, if appropriate.

As part of our investigation, we will consider whether the complaint identifies actual or potential customer harm, foreseeable harm, poor customer outcomes, failures in systems or controls, deficiencies in products, services or communications, or issues that may affect more than one customer.

Where such issues are identified, LBH Insurance will take appropriate remedial action and consider whether wider corrective action is required to address any underlying causes and prevent similar issues from recurring.

You will be informed of delays that may affect our ability to resolve the complaint in a timely fashion or to your satisfaction.

We will aim to provide you with a final response by the date indicated in the acknowledgement letter. If at any time we consider that this will not be possible, we will send to you a holding response, which will explain to you the reason for the delay and indicate when you can expect a final response. If you are an eligible complainant and we are unable to provide you with a final response within eight weeks of receiving your complaint, we will write to you explaining the reasons for any delays and FOS referral rights. 

The final response will address the subject matter of each point raised in your complaint and, where appropriate:

• explain the outcome of the investigation;
• confirm whether the complaint has been upheld, partially upheld or rejected;
• explain the reasons for our decision;
• detail any offer of redress or remedial action; and
• provide details of the complainant's right to refer the matter to the Financial Ombudsman Service where applicable.

We will regard a complaint as closed once a final response has been issued, or where the complainant has confirmed acceptance of our proposed resolution.

Administrative closure of a complaint by LBH Insurance does not affect any rights an eligible complainant may have to refer the complaint to the Financial Ombudsman Service within the applicable regulatory time limits.

LBH Insurance will retain complaint records, correspondence, investigation materials and supporting documentation for a minimum period required by applicable legal and regulatory requirements and, in any event, for not less than five years from the date the complaint is closed.

VULNERABLE CUSTOMERS

LBH Insurance recognises that some customers may be vulnerable due to health, life events, resilience or capability factors.

Where vulnerability is identified, we will take reasonable steps to ensure the customer receives appropriate support and that communications are clear, accessible and tailored to their needs.

ROOT CAUSE ANALYSIS

LBH Insurance will analyse complaints to identify recurring issues, systemic weaknesses, training requirements, process failures and opportunities for improvement.

Where trends or recurring causes are identified, management will consider appropriate corrective and preventative measures to reduce the likelihood of future customer detriment.

COMPLAINT REPORTING AND GOVERNANCE

LBH Insurance will maintain appropriate management information relating to complaints, including complaint volumes, complaint categories, complaint outcomes, complaint handling times, root causes, customer harm identified and remedial actions taken.

This information will be reviewed periodically by senior management to support regulatory compliance, Consumer Duty obligations and continuous improvement.

ELIGIBLE COMPLAINANTS' REFERRAL RIGHTS

If you are an eligible complainant, you may have the right to refer your complaint to the Financial Ombudsman Service. Details of the applicable time limits for referral will be provided in our final response letter.

Further details on the FOS can be found on its website at www.financial-ombudsman.org.uk . Alternatively, it can be contacted at:

The Financial Ombudsman Service

Exchange Tower

London E14 9SR

Tel: +44 800 023 456