Opinion

Insurance Customer Protection

Those who play a key role in ensuring the protection of insurance customers are any person involved in the application, sale or administration of insurance policies, insurance agents or brokers or agents employing or surveying, or any person or institution providing services to the insurance customer, the insurance company or any service provider appointed by the Insurance Development and Regulatory Authority.
According to the ‘Corporate Governance Guidelines for Insurers, 2023’, the members of the “Customer Protection and Grievance Redressal Committee” formed by the Board of Directors must play a role in ensuring timely resolution of insurance claim-related complaints and ensuring appropriate processes and effective measures to protect the interests of customers. In addition, the said committee will have to take necessary steps to ensure the protection of the customers as mentioned in the Insurance Act and other prevailing laws of Bangladesh. Moreover, the Committee will have to formulate some essential policies for the speedy resolution of customer complaints.
In order to take effective measures for resolving complaints under the Customer Protection and Grievance Redressal Committee, the management authority should form a three-member committee for resolving complaints and facilitate the way for resolving. Effective measures and procedures for receiving, recording and resolving complaints, including information technology-based systems, should be followed at the head office of the insurer. All insurers should publicize their respective complaint resolution processes and the activities taken in this regard in a readable printed booklet or acceptable medium for the information of the public including the insurance customers and it should be displayed specifically on the website. All concerned, including the insurance customers, should be sincerely received and resolved by using phone calls, e-mails or any other method. Any complaint should be resolved within a maximum of thirty days without delay.
An insurance complaint shall be deemed to have been settled or closed by the insurer only when the insurer has been able to take action in response to all the complaints of the complainant or the insurer has not received any response from the complainant within eight weeks after sending a written reply to the complainant. If the insurer fails to settle the complaint of an insurance customer, the concerned insurance customer may apply or complain to the authority or the dispute resolution committee formed by the authority in accordance with the law for the purpose of settling the complaint. A customer cannot be prevented from applying to the authority or the dispute resolution committee.
An insurer or agent or broker or agent appointer or surveyor must ensure appropriate security measures to preserve all customer information. However, they may provide necessary information in the context of a court order or legal request from the competent authority.
If the insured deviates from any of the matters stated in the insurance contract, the insured shall be entitled to protection in respect of the remaining part except for the said deviation. However, if there is no material change in the basic terms of the contract due to minor clerical errors, the insured shall be entitled to this protection. If any information changes or disclosure is necessary or obligatory after the conclusion of the insurance contract, the insured shall be required to inform the insurer in writing. The insured shall be required to understand and preserve the receipts related to the insurance plan or policy and other ancillary documents.
The insurance plan or policy must be approved by the authority and no deviation from the approved plan/policy can be made in the sale and the actual benefits and terms of the available plan or policy must be clearly communicated to the customer in understandable and simple language. The insurance plan or policy cannot be sold under any other name or under any other product, it must be sold as the approved insurance plan or policy. The insurance plan or policy document must contain the name and registration certificate number of the insurer, the contact details and physical address of the insurer, the name, class and necessary description of the policy and the name and address of the authority. No such idea or assurance can be given to the customer verbally or in writing or in any other way which is not in the insurance plan. The appropriate insurance plan or policy shall be presented to the customer in view of the customer’s needs or demands and no insurance plan or policy shall be sold to the customer by influencing or persuading him. Under no circumstances shall false or forged information or documents be presented and no form of change in the insurance contract shall be made without the written consent of the insurance customer. If there are any restrictions or penalties on the maturity or withdrawal of the policy or any other risks related to any investment or insurance policy, the insurance customer shall be informed of them before the sale of the insurance plan. The procedure for filing insurance-related complaints, including insurance claims, with both the insurer and the Insurance Development and Regulatory Authority shall be mentioned in detail. If any insurance plan or policy is to be invested, no guarantee of return can be given.
The insurer or agent or broker or surveyor or agent employing institutions shall always provide services with honesty, fairness, due skill, professionalism, care and diligence. The prospective customer shall be provided with clear, legible, printed booklets, insurance plan marketing proposals and prospectuses, in which all necessary information including the benefits or coverage of the proposed insurance, the extent of limitations, disclaimers and explanations shall be accurately and clearly mentioned. In addition, all necessary information shall be provided to make a decision about the proposed or existing policy. The insurer shall create and maintain a database of all information of the insured and shall later provide any information requested in writing by the concerned customer as per the demand.
In addition to using plain language, communication and transactions with the insured should be carried out in a specific manner and written information provided by the insurer to a customer, including marketing policy-agreement and testimonials, forms, statements, should be in Bangla or both Bangla and English. The financial benefits received and paid for the policy, any fees and charges or specific conditions or impositions or specific financial terms should be clearly and accurately described. The insured should be thoroughly informed about the matters to be complied with according to the insurance contract. The money receipt of the said policy sold should be issued and stored by the insurer in electronic or digital mode within fifteen days of the sale of the insurance plan in the manual mode and the said money receipt should be ensured to be sent to the insured. However, no one other than the insurer can issue money receipt in electronic or digital mode.
No person shall be required to sign a blank or partially-filled Form for the purpose of applying for a policy or effecting a transaction. An insurance customer shall not be induced to change, add or cancel an insurance policy and shall not resort to any fraud or deceit with a prospective customer or insured. In the event of any complaint or misconduct related to the policy or investigation in legal proceedings, the opportunity to defend himself, including the customer, shall be ensured. In this case, the customer shall not be harassed or unnecessarily delayed in paying the insurance claim.
Insurers should provide necessary booklets, flyers etc. to increase awareness about insurance and publish them in electronic media. Insurers should organize seminars, conferences, workshops etc. to promote the development of the insurance industry throughout the country. All proposed schemes or updated lists of policies should be displayed on their respective websites and arrangements should be made to promote them on social media.
In order to ensure the protection of the interests of insurance customers, the following contents have been compiled for the purpose of promoting and expanding the insurance industry in the country as per the guidelines issued by the Insurance Development and Regulatory Authority.

Writer: Sarfaraz Hossain FCS
Company Secretary
People’s Insurance Company Limited