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Complaints Resolution

Introduction

Naked Financial Technology (”Naked”) is a digital platform for automated sale and self-service administration of personal lines short-term insurance.

Naked is an authorised Financial Services Provider (FSP 48822). Policies are underwritten by The Hollard Insurance Company Limited, a Licensed Non-Life insurer and authorised Financial Services Provider (FSP 17698). Naked has a full binder from Hollard for product development & pricing, entering into and administering of policies, and handling of claims.

Definition and application of a complaint in terms of Financial Advisory and Intermediary Services Act 37 of 2002 (“FAIS”)

FAIS defines a complaint as an expression of dissatisfaction by a person to a provider or, to the knowledge of the provider, to the provider’s service supplier relating to a financial service provided or offered by that provider. This expression of dissatisfaction indicates or alleges one of the below:

The provider or a representative has contravened or failed to comply with an agreement, law, rule or code of conduct that is binding on the provider or to which it subscribes.

This applies to an allegation made by a client against Naked that:

  • The features of the product in question were not properly explained at point of sale;
  • The client was not given enough information that would enable them to make an informed decision about the financial product;
  • The policy documentation was not delivered and received by the client;
  • There is not enough information with regard to the submission of a claim;
  • There is not enough information about premium payment and the frequency thereof; or
  • Does not recall buying the financial product.

The provider or a representative has wilfully or negligently rendered a financial service that caused the client harm, prejudice, distress or substantial inconvenience.

This applies to an allegation by a client that Naked has:

  • Provided an incorrect service to the client;
  • Acted without the client’s knowledge or consent;
  • Cancelled a policy without the client’s knowledge/consent; or
  • Effected any policy change without the client’s knowledge/consent which has caused prejudice to the client.

The provider or a representative has treated a client unfairly.

This applies to allegations against Naked that:

  • The client has been unnecessarily directed back and forth without a resolution;
  • A representative have been rude to the client;
  • Different representatives provided conflicting information to the client when contacted about the same issue on the financial product; or
  • Naked gave an undertaking to the client that was not fulfilled.

How to submit a complaint

While you may contact the Ombudsman at any time or take legal action against Naked within 270 days of receiving a claims decision, we would encourage you to please contact Naked first and follow the step-by-step process below:

Step 1: Complain to Naked

  • Speak to one of our customer care specialists on 086 0995 125 or email us on help@naked.insure
  • If required, ask to speak to a manager to further discuss your concerns.
  • If, after speaking to a manager, your complaint is not yet resolved, you can take the matter further by writing to our internal dispute resolution committee on: complaints@naked.insure.You need to set out all the relevant information and attach all applicable documentation in order to enable Naked to resolve your complaint timeously and without delay. Your concerns will be investigated by a person with full authority to deal with the complaint. We will acknowledge receipt of complaints within 1 working day of receipt and we aim to inform you of the outcome of your complaint within 7 working days. Please note that complaints resolution timelines may extend beyond the 7 working day period depending on the nature of the complaint.

Step 2: Complain to Hollard

  • Contact Hollard Insure Complaints on 011 351 2200 or email them at hollardinsurecomplaints@hollard.co.za
  • If you are unhappy with the outcome of Hollard Insure Complaints’ decision, you may email Hollard’s Office of the Internal Adjudicator (“OIA”) at oia@hollard.co.za, who will investigate the complaint objectively and independently.

Step 3: Complain to the Ombudsman

If you are unhappy with the outcome of the OIA’s decision, you may send your complaint to the following ombuds, depending on the nature of the complaint:

  • FAIS Ombudsman (“FAIS Ombud”): If you have a complaint about how this policy was sold to you and your complaint is not resolved to your satisfaction by Hollard or Naked, you may contact the FAIS Ombud. You must do so within six months after receipt of the final response to your complaint from Hollard or Naked, and the complaint must not constitute a monetary claim in excess of R800 000.00.

  • National Financial Ombudsman Scheme South Africa (“NFO”): if you have a complaint relating to anything other than how this policy was sold to you, and your complaint is not resolved to your satisfaction by Hollard or Naked, you may contact the NFO.

Step 4: Take legal action

You may take legal action against us within 270 days of the date that you received our claims decision. To take legal action, summons must be served on us. If this is not done in time, you will lose your right to claim and we will no longer be responsible for that claim. You may also choose to take legal action against us without first asking us to review our claims decision or contacting the NFO. If you take legal action against us before contacting the NFO, you can only approach the NFO for assistance after you have withdrawn the summons against us.

Information required for the submission of a complaint

When submitting a complaint through one of the above avenues, please ensure that the below is included:

  • Claim number.
  • Details of the policyholder.
  • Indication that you would like to submit a complaint.
  • Details of the events that prompted you to submit the complaint.

Procedure

Once Naked receives your written complaint, you may expect an acknowledgement of receipt within 24 hours of receipt. You will be provided with details of the person who will be considering your complaint and how your complaint will be handled.

You may expect a resolution to the complaint within 7 working days of receipt of your complaint. In the unlikely event that your complaint is not resolved within 7 working days, you will receive feedback on the progress of your complaint every 5 working days until resolution.

Rejected claims and cancelled policies

If we do not accept a claim made in terms of this policy, cancel this policy or if you dispute the amount of the claim, you may request us to review our decision. We will only review our decision if you send us a written request to review within 90 days (the “representation period”) of the date that we rejected your claim or cancelled your policy. If you wish to lodge a complaint direct with the insurer, you may do so by sending an email to hollardinsurecomplaints@hollard.co.za.

Conclusion

Naked will, on an ongoing basis, investigate the nature of complaints received and ensure that preventative measures are put in place, to avoid future occurrence of similar and other complaints.

Date of last update: 20/06/2024