Complaints Management Policy
Updated:
1. Introduction
Nova provides insurance advisory, intermediary, policy servicing, claims support and related administrative services to personal and commercial insurance clients. As a financial services business operating as a juristic representative, Nova is required to maintain a fair and effective complaints process that enables clients and other complainants to raise concerns about the financial services or related service levels provided by Nova. This Complaints Management Policy explains how complaints may be submitted, how they will be handled, how they will be escalated where required, and what remedies may be available if a complainant is not satisfied with the outcome. Nova’s complaints process is designed to:
treat complainants fairly;
make it simple to lodge a complaint;
record and track complaints properly;
acknowledge complaints within a reasonable time;
investigate complaints objectively;
escalate complex or unresolved complaints where required;
provide clear written feedback;
maintain proper records;
support Treating Customers Fairly outcomes.
2. Definitions
For purposes of this policy:
Advice means any recommendation, guidance or proposal of a financial nature provided to a client in relation to an insurance product or financial product, as contemplated under the Financial Advisory and Intermediary Services Act, 2002 (“FAIS Act”). Client Query means a request for information, assistance or servicing relating to an insurance product, policy, claim, premium, renewal, endorsement or related process. A client query does not automatically constitute a complaint. Complaint means an expression of dissatisfaction by a client, potential client, policyholder, beneficiary, representative or other complainant relating to a financial service, insurance product, policy, claim, service level, advice, intermediary service or related process, where it is alleged or indicated that:
Nova, its representative or service provider has contravened or failed to comply with an agreement, law, rule or code of conduct;
Nova, its representative or service provider has caused harm, prejudice, distress or substantial inconvenience through an action, omission, maladministration or service failure;
Nova, its representative or service provider has treated the client or complainant unfairly.
Complainant means any person or entity who submits a complaint, including a client, potential client, policyholder, beneficiary, successor in title, person paying a premium or authorised representative of a client. Complaints Handling means the process of receiving, recording, investigating, resolving and closing a complaint, including communication with the complainant. FAIS Ombud means the Ombud for Financial Services Providers established under the FAIS Act. Intermediary Service means any act performed by a person for or on behalf of a client or product supplier, other than advice, including arranging, maintaining, servicing or administering an insurance product, submitting or processing claims, or facilitating transactions relating to an insurance product. National Financial Ombud Scheme South Africa or NFO means the recognised ombud scheme that may assist with certain financial services and insurance-related complaints. Rejected Complaint means a complaint that is not upheld and where Nova communicates that it does not intend to take further action to resolve the complaint, including where the complaint is considered unjustified, invalid or unsupported. Reportable Complaint means a complaint that is not resolved immediately or within ordinary client query processes and must be recorded and managed through Nova’s complaints process. Treating Customers Fairly or TCF means the regulatory approach requiring financial services providers and representatives to deliver fair outcomes to clients throughout the product and service lifecycle. Upheld Complaint means a complaint that is finalised wholly or partially in favour of the complainant.
3. Purpose of This Policy
The purpose of this policy is to establish a fair, transparent and effective complaints management process. Nova’s complaints process aims to ensure that:
complaints are easy to submit;
complaints are recorded and tracked;
complaints are assessed objectively;
complainants receive timely acknowledgement and feedback;
unresolved or complex complaints are escalated appropriately;
complainants are advised of external escalation options where applicable;
complaint records are retained for compliance and audit purposes;
complaint trends are reviewed to improve service and operational controls.
4. Allocation of Responsibilities
Nova’s directors and management are responsible for ensuring that complaints are handled fairly and effectively. The operational complaints owner is: Name: Anthony Heiss Role: Director, Principal Adviser and Registered Representative under NovaOne Advisory’s juristic representative structure Email: anthony@novainsurance.co.za Anthony Heiss is responsible for overseeing the operational handling of complaints, claims escalations and unresolved client service issues in his capacity as Director, Principal Adviser and Registered Representative under NovaOne Advisory’s juristic representative structure. Compliance and Key Individual oversight apply through Nova’s compliance and juristic representative structure. Nova’s Information Officer for POPIA-related complaints is: Name: Brad Rimmer Designation: Operations and Systems Email: info@novainsurance.co.za Direct Email: brad@novainsurance.co.za Complaints may be submitted to: info@novainsurance.co.za
Where a complaint relates to a privacy, personal information or PAIA/POPIA issue, it should be escalated to Brad Rimmer as Information Officer. Where a complaint relates to advice, intermediary services, claims handling, policy servicing, premium issues or client treatment, it should be escalated to Anthony Heiss as the operational complaints owner.
5. Responsible and Adequate Decision-Making
Any person responsible for making decisions or recommendations in respect of a complaint must:
have appropriate experience, knowledge and skill;
understand the subject matter of the complaint;
consider the fair treatment of the complainant;
avoid conflicts of interest;
act objectively and impartially;
be able to escalate the complaint where required;
ensure that the complaint record is complete.
Where a conflict of interest exists, the complaint must be escalated to another appropriate person for review.
6. Categories of Complaints
Nova may categorise complaints as follows:
Advice — The client believes advice was unsuitable, unclear or incorrect.
Information Provided — The client believes information was unclear, incomplete or difficult to understand.
Product or Cover — The product, cover or policy outcome did not meet the client’s expectations.
Service — The client believes service was poor, delayed or insufficient.
Accessibility — The client found it difficult to communicate with Nova or obtain assistance.
Complaints Handling — The client was dissatisfied with how a complaint was handled.
Claims Handling — The client was dissatisfied with claim communication, support, outcome or process.
Premium / Finance — The client has a concern relating to premiums, billing, payment or finance-related processes.
Renewal — The client has a concern relating to renewal handling, terms, timing or communication.
Endorsement / Policy Change — The client has a concern relating to a policy amendment or endorsement.
Other — Any complaint that does not fall clearly into one of the above categories.
Nova may add or amend complaint categories where required to improve monitoring, reporting and client outcomes.
7. How to Submit a Complaint
A complaint should preferably be submitted in writing. Complaints may be submitted to: Email: info@novainsurance.co.za Website: www.novainsurance.co.za The complainant should include:
full name and surname;
company name, where applicable;
contact details;
policy number or client reference, where available;
description of the complaint;
date of the financial service, event or issue complained about;
supporting documents or correspondence, where available;
desired outcome or remedy, where applicable.
Where a complaint is first raised verbally, Nova may request that the complainant submit the complaint in writing to ensure that the complaint is accurately recorded and properly investigated.
8. Internal Complaint Escalation and Review Process
Nova is committed to a complaints process that is clear, accessible and not unnecessarily burdensome. The internal complaints process will generally follow these stages:
8.1 Complaint Received
When a complaint is received, Nova will:
identify whether the matter is a complaint or a general client query;
record the complaint in the complaints register;
assign an owner;
request any missing information where required.
8.2 Acknowledgement
Nova will acknowledge receipt of the complaint in writing within 48 hours of receiving the complaint, where reasonably possible. The acknowledgement will confirm:
that the complaint has been received;
who is handling the complaint;
any additional information required;
the next step in the process.
8.3 Initial Assessment
Nova will assess:
the nature of the complaint;
the category of complaint;
whether the complaint is urgent;
whether the complaint is reportable;
whether the matter can be resolved quickly;
whether the complaint requires escalation.
8.4 Request for Further Information
Where more information is required, Nova may request supporting documents or additional details from the complainant. Nova will aim to contact the complainant within 7 days of receiving the complaint where additional information or clarification is required.
8.5 Investigation
Nova will investigate the complaint fairly and objectively. This may include reviewing:
client records;
policy documents;
advice records;
claims records;
emails and correspondence;
atWork records;
insurer or underwriting manager correspondence;
service provider input;
relevant legal, regulatory or compliance obligations.
8.6 Ongoing Updates
Where a complaint requires further investigation and cannot be resolved quickly, Nova will provide updates to the complainant at reasonable intervals. Nova will aim to update the complainant every 14 days while the complaint remains unresolved, where reasonably possible.
8.7 Resolution and Feedback
Nova will aim to provide formal feedback within 21 working days where the complaint requires full investigation or escalation. The response may include:
the outcome of the complaint;
reasons for the outcome;
any corrective action to be taken;
any remedy offered;
external escalation options where applicable.
Where Nova cannot meet the expected timeline, Nova will inform the complainant and provide an explanation.
8.8 Closure
Once the complaint has been resolved or finalised, Nova will:
update the complaints register;
save all complaint records;
confirm the outcome to the complainant;
close the complaint file;
record any lessons or corrective actions where relevant.
9. Reportable and Non-Reportable Complaints
Nova may distinguish between complaints that are resolved quickly within ordinary client query processes and complaints that require formal recording and escalation.
A complaint may be treated as non-reportable or resolved within ordinary process where:
the matter is upheld immediately;
the issue is resolved quickly through ordinary client service processes;
the matter does not require formal investigation;
the complainant accepts the resolution.
A complaint should be formally recorded and managed as reportable where:
it cannot be resolved immediately;
it relates to advice, claims handling, service failure, unfair treatment, premium issues or regulatory obligations;
it requires investigation;
it may indicate client prejudice or possible non-compliance;
the complainant remains dissatisfied.
Where there is doubt, the matter should be treated as a complaint and recorded.
10. External Escalation
If a complainant is not satisfied with Nova’s response or the complaint remains unresolved, the complainant may have the right to escalate the matter to an external dispute resolution body.
10.1 National Financial Ombud Scheme South Africa
The National Financial Ombud Scheme South Africa (“NFO”) may assist with certain financial services and non-life insurance-related disputes. Contact details: National Financial Ombud Scheme South Africa Telephone: 0860 800 900 WhatsApp: +27 (0)76 574 8055 Email: info@nfosa.co.za Website: www.nfosa.co.za
10.2 FAIS Ombud
The FAIS Ombud may assist with complaints relating to financial services rendered by a financial services provider or representative. Contact details: Office of the Ombud for Financial Services Providers Telephone: 012 762 5000 Sharecall: 086 066 3274 Email: info@faisombud.co.za Website: www.faisombud.co.za Physical Address: Menlyn Central Office Building 125 Dallas Avenue Waterkloof Glen Pretoria 0010 A complainant should generally first give Nova a reasonable opportunity to resolve the complaint before escalating the matter externally.
11. Recordkeeping, Monitoring and Analysis
Nova will keep records of complaints and complaint-related communication for at least five years or for such longer period as may be required by applicable law, regulation or internal recordkeeping requirements. Complaint records may include:
complaint details;
complainant details;
complaint category;
date received;
acknowledgement date;
owner assigned;
correspondence;
supporting documents;
investigation notes;
outcome;
corrective action;
closure date.
Nova will periodically review complaints to identify:
recurring issues;
service gaps;
operational weaknesses;
claims handling problems;
advice or disclosure concerns;
training requirements;
process improvements.
12. Treating Customers Fairly
Nova’s complaints process is aligned to Treating Customers Fairly principles. Nova aims to ensure that:
clients can raise complaints without unreasonable barriers;
complaints are handled fairly and consistently;
clients receive clear and timely communication;
complaints are investigated properly;
outcomes are explained clearly;
service failures are corrected where appropriate;
complaint trends are used to improve the business.
13. Policy Review
This policy will be reviewed periodically or when required due to changes in law, regulation, business operations, complaints trends or compliance requirements. The latest version will be made available on Nova’s website or on request.