Complaints Policy

AS/NZS 10002:2014 sets out the following definition of ‘complaint’ at p. 6:

[An expression] of dissatisfaction made to or about an organization, related to its products, services, staff or the handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required.

Under this guide, the following expressions of dissatisfaction are complaints:
(a) posts (that meet the definition of ‘complaint’ set out in RG 271.27) on a social media channel or account owned or controlled by the financial firm that is the subject of the post, where the author is both identifiable and contactable;
(b) complaints about a matter that is the subject of an existing remediation program or about the remediation program itself (e.g. delays, lack of communication);
(c) complaints about the handling of an insurance claim (e.g. excessive delays or unreasonable information requests).”


This policy implements three fundamental principles of business that are mission critical to vrsANA. They are:

  1. Our clients (insurers and claimants) have a right to receive the best service possible that achieves resolution via a fair outcome. They have a right to complain if they do not believe we have delivered on this and they have a right to prompt and appropriate action by us in response to their Complaint.
  2. The practice of understanding and resolving Complaints, including documenting and analysing them, is fundamental to continuous business improvement. It is the most effective form of product and service development that vrsANA pursues
  3. Effective resolution of Complaints is the most effective promotional activity that vrsANA can pursue, on its own behalf in relation to insurers and on behalf of insurers in relation to their clients.

In addition, vrsANA Complaints procedures observe two firm rules:

  1. All Complaints shall be fully documented, whether they are formally lodged or not.
  2. All Complaints will be promptly acknowledged appropriately to the complainant and notified within 24 hours to the insurer, with a description of planned actions to resolve the Complaint. This information shall be updated regularly.


The purposes of this policy are to:

  • Encourage clients (insurers and claimants) to report any aspect of the handling of their claim that could have been better managed.
  • Use that information to produce better outcomes both for the immediate complainant and in the future.
  • Ensure full documentation, so that situations do not “fall through the cracks” and so that vrsANA can learn from systematic study of Complaint patterns.
  • Provide rapid escalation through vrsANA management when Complaints are not promptly resolved, with enhanced action to achieve a timely outcome.

The opportunity

An insurance policy only fully becomes a service when a claim is made: handling a claim is the most important part of the insurer–customer relationship that vrsANA are entrusted with.

  • A good claims experience can cement a customer relationship and create a brand evangelist.
  • Dealing effectively with a Complaint can avoid a costly process and reputational damage.
  • A Complaint well-handled can create the strongest customer bond.

Conflict resolution and mutual benefit

In most cultures people avoid conflict where possible and this includes the making of Complaints, which is often seen as an emotionally charged confrontation between competing goals.

vrsANA sees the process of making Complaints as mutually beneficial, with common goals in customer satisfaction (that leads to repeat business and word-of-mouth endorsement) via a process of identifying and improving weak systems, to reduce future incidents.

Reframing “Complaints” as mutually beneficial process of exploration and rectification will defuse emotional stress and reduce the risk of a Complaint escalating unnecessarily or otherwise going off the rails.

Claimant viewpoint

Essential to customer satisfaction is to listen closely to what people are saying and what they are not saying.

vrsANA staff will make a deliberate effort to shift their viewpoint to the claimant’s perspective, to identify the factors that are important to them.

Claimant’s identified as vulnerable or potentially vulnerable shall in addition be treated according to the General Insurance Code of Practice 2020 and the vrsANA training program Understanding and complying with the General Insurance Code of Practice 2020.

Checklist of actions

  • Let claimants know that it is OK to complain and that vrsANA welcomes complaints as an essential tool for improving service.
  • Reassure them that their Complaint will be actioned promptly by senior management, and that it will be treated with respect.
  • Ask for clarification and details. Ensure we understand and document the Complaint fully and showing the claimant’s point of view.
  • Ask the claimant and document what outcomes they would regard as acceptable, and their preferences.
  • Advise claimants that they may lodge a Complaint with vrsANA, either via adjusters or directly via the website, and that Complaints will also be notified to the insurer.
  • Document the Complaint as soon as practical, even if adjusters are are able to resolve it immediately.
  • Advise vrsANA management and the insurer as soon as practical and within one business day of any Complaint, with full details and recommendations for resolution.
  • vrsANA management to respond within one business day, including:
    • Phone or email acknowledgement and reassurance that the Complaint will be treated seriously and dealt with promptly.
    • Further information gathering as necessary involving as appropriate the insured, the insurer, the vrsANA representative and other parties connected to the issue.
  • vrsANA management to follow up within two business day, including:
    • Offering the complainant at least one and as appropriate a range of resolution options.
    • Full report to the insurer.
  • vrsANA management to continue business daily actions including contact with the claimant and reporting to the insurer.