Complaints Procedure

Howden Insurance Brokers Limited strives to do everything to ensure our clients receive the best possible service.

If you are not satisfied with the level of service provided by us, we will endeavour to resolve this as soon as possible. If you consider that you have cause to complain, the following information will advise you:

  • How to make a complaint
  • The procedures we are committed to follow in ensuring your complaint is dealt with promptly, fairly & effectively
  • What options are open to you if you are not satisfied with our response

How to make a complaint

If you wish to complain, you may advise any member of our staff or contact us by:

  • Writing to Howden Insurance Brokers Limited, Compliance, One Creechurch, London EC3A 5AF, United Kingdom
  • Telephoning +44 (0)20 7623 3806
  • E- mailing [email protected] • Fax +44 (0)20 7623 3807

Our complaints handling procedure

1. We aim to resolve your concerns, whenever possible, by close of business on the third working day. If this is not possible, we will promptly acknowledge your complaint in writing no later than five working days after receipt.

2. If your complaint concerns the provision of (or failure to provide) a service by another firm authorised by the Financial Conduct Authority, such as an insurer, we will promptly refer your complaint in writing to the firm. In these circumstances we will provide you with the full contact details for the firm and, if the other firm is solely responsible, our final response.

3. Where applicable, we will carefully consider, as part of our review of the complaint whether we have acted to deliver good customer outcomes in accordance with the FCA’s Consumer Duty requirements. Where we find that we have not met regulatory expectations, we will act to put things right.

4. We will endeavour to resolve your complaint at the earliest possible stage. We will thoroughly investigate the matter and will usually send our final response to you in writing no later than eight weeks after receipt of your complaint.

5. We will keep you regularly informed of our progress and the measures being taken to resolve your complaint. Where investigations are ongoing, we will issue a letter to you four weeks following the receipt of the complaint, explaining why we have been unable to resolve your complaint and indicate when we will make further contact. You are welcome to contact us at any time to check the status of our investigation.

6. If, after eight weeks, you are still waiting for us to respond, we will write to you explaining why we have been unable to conclude your complaint and the options available to you.

7. If you are a Lloyd’s policy holder and are dissatisfied with our handling of your complaint you may refer your complaint to the complaints team at Lloyd’s. The address of the complaints team at Lloyd’s is:

Complaints

Lloyd’s

Fidentia House

Walter Burke Way

Chatham Maritime

Kent ME4 4RN

Tel No: 0207 327 5693

Fax No: 0207 327 5225

Email: [email protected]

Website: www.lloyds.com/complaints

Details of the Lloyd’s complaints procedure are set out in the leaflet “Your Complaint – How We Can Help” available at the above web address. Submitting your complaint to the Lloyd’s complaints team will not affect your right to use the Financial Ombudsman (FOS) as outlined below, if eligible, should you not be satisfied with Lloyd’s response.

8. If you are either a private individual, a micro-enterprise involved in economic activity (that employs fewer than 10 persons and has an annual turnover or balance sheet that does not exceed €2 million) or a small business involved in economic activity (that has an annual turnover of less than £6.5 million, and either employs fewer than 50 persons or has a balance sheet total of less than £5 million), you may refer your complaint to the Financial Ombudsman Service (FOS), provided we have had an adequate opportunity to resolve your complaint first. We will advise you of the time limits for making a referral to the FOS with our final response. The FOS can be contacted by:

  • Accessing the website http://www.financial-ombudsman.org.uk/consumer/complaints.htm
  • Telephoning 0300 123 9123 or 0800 023 4567

9. Online Dispute Resolution

The European Commission has established an Online Dispute Resolution Platform (ODR Platform). It is specifically designed to help customers resident in the European Union (EU) who have a complaint about goods or services bought online from traders established in the EU. You can submit your complaint online through the ODR platform in any of the official languages of the EU. The ODR platform can then submit your complaint to the Financial Ombudsman Service to facilitate resolution of your complaint.

You may use the ODR service if you are resident in the EU and have a complaint about a product or service purchased from us online using the following link: http://ec.europa.eu/odr.

As the ODR platform will ultimately re-direct your complaint to the Financial Ombudsman Service, you may prefer to contact us or the Financial Ombudsman Service directly in the first instance.

If using the ODR Platform, you may find the following information helpful:

Our name: Howden

Our email: [email protected]

Our website address: www.howdengroup.co.uk

Our geographic address: One Creechurch, London EC3A 5AF, United Kingdom

We will provide whatever assistance we can to the FOS and abide with their final decision.

Your right as a client to take legal action remains unaffected by the existence or use of any complaints procedures referred to above. However, the FOS will not adjudicate on any cases where litigation has commenced.

10. Guernsey or Jersey policyholders:

Howden Insurance Brokers Limited is also licensed by the Guernsey Financial Services Commission (“GFSC”) and Jersey Financial Services Commission (“JFSC”) as an insurance intermediary. If we cannot settle your complaint to your satisfaction, you may be eligible to refer your complaint to the Channel Islands Financial Ombudsman (“CIFO”).

The CIFO is an independent and free to access service in the Channel Islands for settling disputes between eligible complainants and businesses providing financial services. Details of who is eligible to refer a complaint to the CIFO can be found on their website. The CIFO can be contacted by:

  • Accessing the website: https://www.ci-fo.org/
  • Telephoning:
    • Jersey local phone: 01534 748 610
    • Guernsey local phone: 01481 722 218

Howden is a trading name of Howden Insurance Brokers Limited, part of Howden Group Holdings. Howden Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority in respect of general insurance business under financial services register number 309639. Registered in England and Wales under company registration number 725875. Registered Office: One Creechurch Place, London, EC3A 5AF.

Our Commitment To You

It is always our intention to provide you with the highest quality service. However, we appreciate that occasionally things can go wrong and, when they do, there are four things that matter most:

That you know who to complain to;

  • That you know how your complaint will be dealt with;
  • That you feel confident that we will take your complaint seriously; and
  • That where appropriate, we will put things right quickly.

Who To Complain To

Please address your complaint, and any subsequent queries you may have in connection with the complaint, to the Compliance Officer.

Contact details are as follows:

The Compliance Officer
Howden UK Brokers Limited
Unit 2
Des Roches Square Witney
OX28 4LE
T: 01732 389915
E: [email protected]

How Your Complaint Will Be Dealt With

  1. You will receive a prompt acknowledgement of your complaint letting you know who will be dealing with this. At this stage we may need to ask you for further information.
  2. Your complaint will be investigated promptly, and if there is a delay in providing you with our response we will advise you of this, and indicate when we will be in further contact. If we are unable to give you our decision within eight weeks (2 weeks if your policy is insured in the Lloyd’s market), we will write to you again advising the reasons for the delay and when we expect to be able to provide this to you.
  3. Our investigation of your complaint will take the form of gathering information from the relevant people and reviewing documentation which we hold, and will be carried out by a person who has not been directly involved in the matter giving rise to your complaint. Your complaint will be investigated thoroughly and fairly
  4. In assessing your complaint we will consider this in light of similarities with other complaints we may have received, and relevant guidance published by; the FCA, other relevant Howden 2 regulators, and the Financial Ombudsman Service or former schemes.
  5. On completion of our investigation into your complaint, we will write to you and provide you with a clear explanation of our findings and offering a fair and appropriate settlement, or taking appropriate action, if your complaint is upheld.
  6. Where we have reasonable grounds to be satisfied that another respondent may be solely or jointly responsible for the matter alleged in a complaint, we will promptly forward the complaint, or the relevant part of it, in writing to that other respondent, and inform you why the complaint has been forwarded, and of the other respondent’s contact details.
  7. If we are unable to provide you with a decision within eight weeks and you are not satisfied with the reasons for the delay or you are unhappy with the final outcome of our investigation, you may be entitled to refer your complaint to the Financial Ombudsman Service, which is an independent resolution scheme. If this is the case we will confirmthis in our letter to you and you will be given the full name, address and telephone number of the Financial Ombudsman Service and a leaflet entitled “Your complaint and the ombudsman”

The website address for the Financial Ombudsman Service is;

www.financial-ombudsman.org.uk

Lloyds

  1. If your policy is insured in the Lloyd’s market, you are entitled to refer your complaint to Lloyd’s who will conduct a full investigation and provide you with a written final response, if you are not satisfied with our response or if you have not heard from us within 2 weeks

You should contact;

Complaints Lloyd’s
Fidentia House
Walter Burke Way
Chatham Maritime
Chatham
Kent ME4 4RN

e-mail; [email protected]
tel;+44 (0) 20 7327 5693
fax; +44 (0) 20 7327 5225
www.lloyds.com/complaints

  1. If you are not happy with the response you get from Lloyd’s, you may be entitled to refer the matter to the FOS. Lloyd’s will send you a FOS leaflet with further information at the appropriate time.

The Financial Conduct Authority (FCA) defines a complaint as ‘any oral or written expression of dissatisfaction, whether justified or not’.

The complaint may be about the provision of, or failure to provide, a financial service from which you allege to have suffered or that you may suffer a financial loss, material distress or material inconvenience. The FCA defines material as meaning ‘significant and relevant’. Oral or written includes the following:

  • In person
  • By telephone
  • By fax
  • By letter
  • By email.
  • Via ‘social media’ site (e.g. the firm’s LinkedIn group, Twitter or Blog, etc.)

A “complaint”, for the purposes of FCA rules, includes any complaint, which alleges:

  • Breach of the FCA Rules or Guidance
  • Failure to comply with any obligation arising under, or by virtue of the Financial Services and Markets Act 2000
  • Negligence, a breach of a term of any customer agreement or any enactment of other rule of llaw, which may be applicable to HEBW’s business
  • Misrepresentation, acting in bad faith or other malpractice

You may make a complaint if:

  • You are or have been a customer of HEBW or any legacy company of HEBW, (a legacy company means a company that HEBW has merged with or purchased in the past).
  • It is also possible to make a complaint without being a customer of HEBW if the complaint arises out of HEWB’s actions or failure to act for you, in your capacity as a potential customer.

How to make a complaint

If you wish to complain, you may advise any member of our staff or contact us by:
Telephoning: 020 3327 5700

Writing to:
Howden Employee Benefits & Wellbeing,
Compliance,
One Creechurch Place,
London,
EC3A 5AF

Emailing: [email protected]

Initial response


When a complaint is made, you do not have to confirm your complaint in writing. We will confirm our understanding of your complaint in writing to you when we acknowledge your complaint. Where we are able to resolve your complaint to your satisfaction by close of business on the third business day, following the day on which it is received, we will send you a letter of Summary Resolution Communication.

Where we feel we are unable to resolve your complaint to your satisfaction within the above timescales, HEBW’s Compliance team will issue a letter of acknowledgement together with a copy of HEBW’s complaints procedures to you upon receipt of your complaint. The letter will confirm the nature of your complaint as we understand it and the name and job title of the person handling your complaint.


Complaints involving other firms


Where HEBW has reasonable grounds to be satisfied that another firm may be solely responsible for the
fault alleged in a complaint, it will refer the complaint to that other firm and will:

  • make the referral in writing; and
  • inform you of the referral by way of a final response and include the other firms’ contact details

Where HEBW has reasonable grounds to be satisfied that another firm may be jointly responsible for the
fault alleged in a complaint, it will refer the complaint to that other firm and will:

  • make the referral in writing;
  • inform you of the referral and include the other firm’s contact details;
  • comply with the obligations outlined below as to the investigation of that part of the complaint that is HEBW’s responsibility; and
  • inform you of the outcome with a formal final response letter

Final or other response within 8 (eight) weeks


The Compliance team on behalf of HEBW Limited will, by the end of 8 (eight) weeks after receiving your initial complaint, send you either:

  1. A ‘final response letter’, which will detail our investigations and the reasons why we are: a) Upholding your complaint with an offer of appropriate compensation; or HEBW Complaints Procedure v1.0 Feb 2024
  2.  b) Rejecting your complaint.

If you are unhappy with the outcome, you may be able to refer the matter to the Financial Ombudsman Service (FOS) provided you meet the requirement of being an ‘eligible complainant’, details of which are outlined below.

FOS will then investigate the complaint and provide their adjudication as to whether to uphold or reject your complaint.

You will have 6 (six) months from the date of our final response letter to seek adjudication from the FOS.

Where we have identified you as an ‘eligible complainant’ our letter will also enclose a copy of the FOS explanatory leaflet and their contact details.
Or
2) A ‘holding letter’ response which
a) Explains why HEBW are still not in a position to provide you with a final response, giving our reasons for the further delay, and indicating a timescale of when we expect to be able to provide you with a final response.
b) In addition, and provided we have identified you as an ‘eligible complainant’, will:
- inform you that you can refer your complaint to the FOS if you are dissatisfied
with the delay
- Enclose a copy of the FOS explanatory leaflet and their contact details.


Referral to FOS


If we have been unable to resolve your complaint to your satisfaction you may ask FOS to investigate and adjudicate on your complaint, provided that you are an ‘eligible complainant’ as categorised below:

Eligible complainants

A ‘person' that is:

  • A consumer
  • A ‘micro-enterprise’ which employs fewer than 10 people and has a group annual turnover or annual balance sheet of less than €2 million at the time the complaint is made
  • A ‘small business’ which has an annual turnover of less than £6.5 million, and either employs fewer than 50 persons or has a balance sheet of less than £5 million
  • Charities, which have an annual income of less than £6.5 million at the time the complaint is made
  • Trustees of a trust, which has a net asset value of less than £5 million at the time the complaint is made
  • Authorised representatives acting on behalf of the above

Ineligible complainants

If you are in doubt about whether you are an eligible complainant for FOS purposes you should contact the Compliance team who will determine whether HEBW categorises you as an eligible complainant.