UNISON Insurance Broking Services Pvt. Ltd.

Customer Grievance Redressal

1. Purpose

International Financial Services Centres Authority (Insurance Intermediary) Regulations, 2021, Regulation 17 requires that every insurance broker should have Board approved policy for comparison and distribution of insurance products and Complaint Handling and Grievance Redressal mechanism. Further, this policy needs to be reviewed at least once in three years.
The policy also define Complaint Handling and Grievance Redressal Process pursuant to the requirement of Circular No. IFSCA-LPRA/3/2024-Legal and Regulatory Affairs dated December 02, 2024 and January 13, 2025 of the International Financial Services Centres Authority (IFSCA) (hereinafter called as the “Circular”), wherein a Regulated Entity shall have a policy on handling of complaints and grievance redressal, duly approved by its governing body or its Board of Directors, as applicable.
This Policy shall also lay down the factors that need to be considered for doing Insurance Broking Business as envisaged in IFSCA (Insurance Intermediary) Regulations, 2021 dated 18TH October 2021. This will be in line with the mission, vision and business strategy of Unison Insurance Broking Services Private Limited (hereinafter referred to as Company).

2. Insurance Arrangements

Unison Insurance Broking is into Composite Broking business i.e. transacting Non-life (General), Health, Life and Re-insurance business.
While direct business is serviced by the Company though Branch offices across India, re-insurance is transacted by team of experts through Mumbai and GIFT city (Gujarat) Offices. Over 100 broker qualified persons (BQPs) are responsible for soliciting the insurance business for the Company.

Main points are:

Manner of soliciting insurance policies
Approach to be followed by the insurance broker in having multiple tie- ups/ types of products sold/ mode of solicitation.
Grievance redressal mechanism and reporting requirements
Unison has arrangements with insurance Companies in all the categories of insurance business i.e. life, general and health to leverage its relationship as a platform for cross-selling insurance products etc.

Insurance arrangements would be finalized based on following factors:

Insurers specializing in different segments of products and catering to the needs of the wide customer base would be ideal for partnership.
Brand value and market reputation of the insurance companies
Experience in designing and managing products catering to the needs of Unison Insurance Broking Services Private Limited customer base.
Penetration levels and geographical presence of the insurer across the country, number of points of presence.

3. Product Mix

Unison would sell below listed categories of insurance products to its customers.

The insurance products shall only be offered based on need of the client. No prospect/customer shall be compelled to buy an insurance product.

4. Reinsurance

We have laid down SOP on our reinsurance business operations and same is being followed rigorously. RI team is having regular liaison meetings with various insurers within India.

Emphasis is given on IFSCA regulations more particularly for compliance on maintaining ‘insurance premium accounts’, Anti Money laundering guidelines and timely remittance of premium to reinsurance company / brokers as the case may be.

TOBA and KYC compliance is must for all business.

5. Authority

The designated Principal Officer shall have the responsibility to control, manage, and supervise all insurance business related activities.

a) Responsibilities of the Principal Officer shall include following:
- • Complete practical training and examination as required under the Regulations
- • Supervise the Corporate activities
- • Ensure that Marketing employees and other employees are trained and certified, in accordance with the Regulations
- • Ensuring correct and timely submission of periodic returns to IFSCA in the prescribed format.
- • Submission of application to IFSCA for issuance/renewal of certificate to act as Composite Insurance Broker, in accordance with the Regulation.
- • Define adequate steps for redressal of grievances
- • Maintenance of records as prescribed under the Regulations
- • Co-ordination with IFSCA and insurance/ Reinsurance companies in day-to-day matters
- • Any such other duties or obligations as may be prescribed by IFSCA from time to time.
b) Responsibilities of Broker Qualified Person/other employees shall include following:
- • To complete practical training and examination as required under the Regulation and as well as completing renewal training before expiry of 3 years term after passing the exam or date of last renewal training.
- • Ensure compliance with the Code of Conduct prescribed under the Regulations.
- • Avoid conflict of interest.
- • Obtain necessary documents required under KYC norms and share with insurance company.
- • To provide due support and guidance to policyholders at the time of procuring/solicitation of policies and in policy servicing, claims and grievance related matters
- • Ensure adequate and timely support to Principal Officer/ Directors/ Management in order to fulfil the obligations under the Regulations
- • Ensure that the policy proposed is suitable to the needs of the prospective client;
- • Not make inaccurate or unfair criticisms of any insurer or member of such body of insurance brokers as approved by the Authority;
- • State the period of cover for which the quotation remains valid if the proposed cover is not effective immediately;
- • Explain the procedures to follow in the event of a loss.
- • Not indulge in any sort of money laundering activities.
- • Any such other duties or obligations as may be prescribed by IFSCA from time to time.
c) Responsibilities of Insurance/Reinsurance Broker at the time of Renewal of Policy.
- The necessity to advise changes affecting the policy, which have occurred since the policy inception or the last renewal date;
- The prerogative of selecting the Insurer/Reinsurer will be always with the client.
- Depending upon type and size of risk, Unison will critically analyse the premium quotes / terms and who will share the risk with lead insurers.

6. Servicing

Unison Insurance is committed to service its customers during the entire period of the contract in accordance with the procedure defined and implemented by the Principal Officer and as required under the Regulations. Servicing of policies would include aspects like:

• providing necessary assistance and guidance in the event of a claim,
• providing all other services and guidance on issues which arise during the course of an insurance contract,
• handling of customer requests, complaints and queries
All information and documents examined and relied upon while processing of the complaints;

Under no circumstances, any employee including Principal Officer will act in a manner which will not be in the interest of the policyholder or the Company or the insurer. Broker Qualified Persons, Principal Officer and any other specified persons will be responsible to ensure compliance with servicing standards specified by the IFSCA, insurers and the Company, but other employees dealing with the customers will also be responsible to ensure adherence to the prescribed servicing standards.

Unison Insurance Broker will also make efforts at all times to impart knowledge and enhance the level of quality of the employees dealing with customers so that they can meet the trust and expectation of customers. Unison Insurance will define and document the processes towards each of the aspects specified above which will be kept updated from time to time.

6. Servicing

• providing necessary assistance and guidance in the event of a claim,
• providing all other services and guidance on issues which arise during the course of an insurance contract,
• handling of customer requests, complaints and queries
All information and documents examined and relied upon while processing of the complaints;