Policy on Protection of Policyholders Interests Max Bupa Health Insurance Company Limited Version: 1 Created in: October 2017 Policy Owner: Head - Customer Service and Operations Reviewed by: Chief Operating Officer Page 1 of 18
Table of contents 1. Introduction... 3 2. Ownership of the Policy... 3 3. Definitions... 4 4. Scope... 4 5. Insurance awareness... 4 6. Services parameters and turn-around-time... 5 7. Procedure for expeditious resolution of Grievances and Complaints... 6 8. Strengthening market conduct... 8 9. Governance... 10 Page 2 of 18
1. Introduction 1.1 At Max Bupa Health Insurance Co. Ltd. ( Company, Max Bupa ), our vision is To become India s most admired health Insurance Company. Our mission is To help customer s live healthier, more successful lives. We are committed to treating our customers fairly by providing them with exemplary service. 1.2 Towards this objective, we have adopted the principle of Treating Customers Fairly (TCF). To achieve our TCF goal, our Management philosophy, processes and systems are developed in a manner that: Our customers can be confident that they are dealing with a company where the fair treatment of its customers is central to its corporate culture. Our products and services are designed to meet the needs of identified consumer groups and are targeted accordingly. Our customers are provided with clear information and are kept appropriately informed before, during, and after the point of sale. Our customers receive advice from the company and its representatives which is appropriate for them and takes into account their circumstances. Our products perform as the company led its customers to expect and its customer service is both of an acceptable standard and also as its customers have been led to expect. Our customers do not face post-sale barriers to cancel (under free look provision), submit a claim, or make a complaint. 1.3 The IRDAI (Protection of Policyholders Interests) Regulations, 2002 and clarifications/guidelines issued there under have been superseded by the recent IRDAI (Protection of Policyholders Interests) Regulations, 2017 dated June 22nd, 2017 ( Regulation, 2017 ). Regulation 2017 requires Insurers to have a board approved policy for the Protection of Interests of Policyholders. 2. Ownership of the Policy The said policy shall be owned by the Director & Chief Operating Officer of Max Bupa Health Insurance Company, supported by the Senior Vice President & Head Operations and Customer Service. Page 3 of 18
3. Definitions Board means the Board of directors of the Company. Bank Rate means Bank rate fixed by the Reserve Bank of India (RBI) at the beginning of the financial year in which claim has fallen due ; Complainant means a policyholder or prospect or any beneficiary of an insurance policy who has filed a Complaint or Grievance. Complaint or Grievance means written expression (includes communication in the form of electronic mail or other electronic scripts), of dissatisfaction by a Complainant with the Company, distribution channels, intermediaries, insurance intermediaries or other regulated entities involved in insurance sales & services about an action or lack of action about the standard of service or deficiency of service of the Company or its distribution channels, intermediaries, insurance intermediaries or other regulated entities. Explanation: An inquiry or request would not fall within the definition of Complaint or Grievance. Policyholder Protection Committee (PPC) means the Company s board appointed committee to oversee the various compliance requirements in relation to the protection of policyholders interests. 4. Scope The scope of this policy shall include the following: Steps taken by the Company for enhancing insurance awareness so as to educate prospects and policyholders about insurance products, benefits and their rights and responsibilities (Section 5 below). Service parameters for various services rendered by the company (Section 6 below). Procedure for expeditious resolution of complaints/grievances (Section 7 below). Steps taken by Max Bupa to prevent mis-selling and unfair trade practices at point of sale and service (Section 8 A below). Steps taken to ensure that during a policy solicitation and sale, the prospects are fully informed and made aware of the benefits of the product being sold vis-a-vis the product features attached thereto and the terms and conditions of the product so that the benefits / returns of the policy are not mis-stated / mis-represented (Section 8 E below). The supporting policies and practices to meet the above requirements have been detailed in the ensuing sections. 5. Insurance awareness Insurance Awareness has been an area of focus for Max Bupa since inception and special attention has been given to this initiative. Page 4 of 18
Max Bupa insurance awareness policy was formulated in April 2014 and was renewed in May 2017, with the aim to improve awareness and understanding of health insurance for its customers, distribution intermediaries, employees and amongst people in general. The awareness policy includes campaigns and new initiatives to be taken by Max Bupa to spread awareness amongst prospects and policyholders about insurance products, benefits and their rights and responsibilities. Such activities and their effectiveness shall be reviewed quarterly by the PPC. The policy not only aims to educate consumers on the health insurance category and its increasing relevance in modern unhealthy lifestyle, but also focuses on educating them on the importance of having adequate coverage for them and their families. The company is committed to being customer-focused, equitable and fair in dealing with its stakeholders. It believes in continuously educating consumers on the importance of leading healthier and hence more successful lives and at the same time understand health insurance need basis their life stage. The policy includes the steps taken for raising awareness about health insurance product benefits to the customers and the insurance awareness schedule that the company will follow all through the year. 6. Services parameters and turn-around-time Max Bupa adheres to the following policyholder servicing turnaround times which are in line with regulatory requirements. These turnaround times are displayed on the corporate website as well as every branch office of Max Bupa. All these turnaround times are monitored on a regular basis, outages if any, are tracked by management on a monthly basis. Policyholder Service turnaround time General Processing of proposal and communication of decisions including requirements/issuance of policy and/or cancellations Obtaining copy of the proposal form post acceptance of proposal Post policy issuance service requests concerning mistakes/refund of proposal deposit and also non-claim related service requests Proposal refund in case of cancellation Request for policy cancellation with freelook period Health Insurance Claims - Reimbursement Turnaround Time (Calendar Days) 15 days 30 days 10 days 15 days 15 days Turn Around time to be calculated from Date of receipt of the proposal or any requirement called for, whichever is later Date of acceptance of the proposal Date of identification of error/receipt of request, whichever is later Date of underwriting decision/receipt of request for cancellation of proposal, whichever is later Date of receipt of request/last necessary document, whichever is later Page 5 of 18
From the date of receipt of last necessary document (no investigation) From the date of receipt of last necessary document (with investigation) Grievances 30 days 45 days Date of receipt of all relevant papers and clarifications under death claim Date of receipt of last necessary document Acknowledge a grievance 3 days Date of receipt of Grievance Resolve a grievance 15 days Date of receipt of Grievance In case the request does not get processed within the above mentioned timelines, a policyholder can escalate to priority.services@maxbupa.com The Company shall display the above service parameters and turnaround times in its website and keep the same updated as and when the service parameters are revised. Servicing parameters and corresponding turnaround times not defined above shall be decided and approved by the Chief Operating Officer. Interest shall be paid by the Company in case of delays as mentioned in the Regulations 2017, more specifically in the case of delay in the payment of a claim beyond the stipulated regulatory 45 days, the insurer shall be liable to pay interest from the date of receipt of last necessary document to the date of payment of claim at a rate 2% above the bank rate. 7. Procedure for expeditious resolution of Grievances and Complaints The Company shall have in place an effective grievance redressal procedure to address complaints of policyholders efficiently and with speed and communicate the action taken by the Company on the complaint to the complainant along with the information in respect of Insurance Ombudsman as may be necessary. Grievance organization structure: The Company has nominated the Chief Operating Officer of the Company as its Designated Grievance Redressal Officer at Corporate Office, supported by the Senior Vice President & Head Customer Service & Operations. The Grievance Redressal Officer at the corporate office will be the contact person for the Authority. In order to effectively address customer grievances, the Company has nominated the office head in each of its branch offices as the designated Grievance Officer for their respective office. The office heads are responsible for receiving and managing grievances originating from their office. The Grievance Redressal Officer at the Company s Head Office shall have the overall responsibility to ensure that the grievance redressal procedure is adhered to, along with the reporting of grievances to the management on monthly and quarterly basis. The details of the Grievance Redressal Officer and designated Grievance Officer along with the contact details in full shall be published in the website of the Company. The name and contact details of designated Grievance Officer of respective office and the other Grievance Officers in Page 6 of 18
hierarchy up to Grievance Redressal Officer at corporate office shall also be displayed in the notice board of respective offices. Every office of the Company shall also display in prominent place, the name, address and other contact details of the insurance ombudsman within whose jurisdiction the office falls. The Company shall publicize its grievance redressal procedure and ensure that it is specifically made available on its website. Process of receiving grievances: The head office and each branch office of the Company have a well-defined process of receiving and registering grievances. We encourage our customers to report to us any grievance or issue that they face regarding their policies or dealings with us. Customers can use the following avenues to report grievances to the Company: Branch office: Contact the customer service executive or write to the Grievance Officer at our branch offices, explaining the details of the issue concerned. Company website & email contact: Visit us at www.maxbupa.comor write to us at customercare@maxbupa.com Customers portal: Log on to our policy holder portal at www.maxbupa.com Email id for senior citizens: To ensure that our customers which fall into the category of senior citizens have a separate platform to register their grievances with us, we have created an exclusive email id for them: seniorcitizensupport@maxbupa.com Head office: Customers can also address their grievance at the below mentioned address: Grievance Redressal Unit Max Bupa Health Insurance Co. Ltd. B-1/I-2, Mohan Cooperative Industrial Estate Mathura Road, New Delhi - 110044 In case either grievance redressal officer of the Company does not respond or the resolution provided by him/her is not to the satisfaction of the complainant, the complainant may register a complaint in the grievance redressal management system of the Authority. Grievance Redressal System: Max Bupa registers and resolves all grievances with the help of a robust Customer Relationship Management (CRM) System. Each grievance registered in the system generates a unique reference number which is also shared with the complainant. As per IRDAI s requirement and direction, the CRM is integrated with the IRDAI s Integrated Grievance System. Management System (IGMS) where grievances are received by Max Bupa are reported to IRDAI on a real time basis, along with the generation of an IRDAI token number for each grievance. Page 7 of 18
Process and resolution times for grievance: Grievance acknowledgement: On receipt of a grievance, the Company first assesses it on the basis of its merits and nature of grievance. Max Bupa sends a written acknowledgement through SMS or email to the customer within 3 working days of the receipt of the grievance. Grievance resolution: Max Bupa shall endeavor to resolve the grievances within 2 weeks of its receipt and each resolution is conveyed vide a final resolution letter/email. This final resolution letter/email offers redressal or rejection of the issue, along with reasons. The resolution letter also informs the complainant about how the customer can pursue the grievance, if dissatisfied. Max Bupa endeavors to resolve all grievances to the satisfaction of the policyholders. In order to ensure fair resolution for the customer, a grievance shall be considered as disposed off and closed when: Max Bupa has acceded to the request of the complainant fully. Or Where the complainant has indicated in writing, acceptance of the response of the insurer. Or Where the complainant has not responded to the insurer within 8 weeks of the company s written response. Process of escalation: In case a policyholder does not receive a response within the prescribed timeline by the Company, he / she may escalate their grievance to the following: Name Designation Contact Details Gargi Sahu General Manager &Grievance Redressal Officer grievanceredressal@maxbupa.com Navin Sahni SVP &Grievance Redressal Officer priority.services@maxbupa.com Vikas Gujral Director & COO - Designated Grievance officer GRO@maxbupa.com Where the grievance is not resolved in favor of the policyholder or partially resolved in favor of the policyholder, the Company shall inform the complainant of the option to take up the matter before insurance ombudsman giving details of the name and address of the Ombudsman of competent jurisdiction. The detailed addresses of all the Insurance Ombudsman shall be as mentioned in the policy document and on the Company s corporate website. All the changes mentioned above have also been incorporated in the Board Approved Grievance Redressal Policy. The revised Policy is attached as Addendum I. 8. Strengthening market conduct A. Curbing mis-selling and explaining benefits of products: To reduce and eventually curb mis-selling of insurance policies, Max Bupa shall take the following Page 8 of 18
steps, as applicable: All Agents shall be trained on market conduct during on-boarding to help them understand diligence norms to be followed during policy solicitation. Welcome calling shall be done to the policyholders with a view to ensure that the key features, terms & conditions of the proposed policy have been disclosed to the prospects. Intermediaries and agents are being trained to recommend need based product solutions to customers. In future, a tool which would recommend solutions basis customer life stage is being evaluated for digital platform sales. To help customers understand the key features of product purchased by them, a Key Feature Document hall be shared with them during policy solicitation and their consent in the form of signature will be mandatory for policy issuance. Insurance advisor s report shall be a part of proposal form to further enhance the quality standards of policy solicitation and advice given to prospects. These mechanisms shall undergo continuous evolution and modifications against the changing backdrop of sales practices, customer on-boarding processes and mis-selling related grievances. As per the Regulations 2017, the Company shall revise their policy documents and submit a certificate of compliance to the IRDAI by 31 December 2017. The Company shall place in its website the terms and conditions of every insurance product that is offered for sale as it was approved by the Authority under File and Use procedure or filed with the Authority under Use and File procedure, including products modified or products withdrawn. The UIN allotted by the Authority to every insurance product shall also be mentioned against each product. B. Steps in case of mis-selling complaint and consequence management: A process for investigation of a mis-selling allegation shall include the following: There is an independent team within Max Bupa named as Institutional Fraud Risk Control which investigates the concerns reported; Where ever applicable, policyholder is contacted to check if he/she has evidence to support the Mis-selling complaint; Discussions are undertaken with the distributor, where applicable, to understand their perspective on the complaint; Once the investigation is complete, there is a consequence management grid along with the severity levels which is used to decide on all such cases; Page 9 of 18
Post investigation, the findings are presented to the Company s Code and Ethics Committee which takes decision on the disciplinary action to be taken basis predefined disciplinary action matrix Max Bupa also conducts mystery shopping from time to time on the solicitation process to identify improvement areas in its significant channels of distribution. C. Implementation of Internal controls: Max Bupa shall take continuous measures to spread awareness amongst sellers and distributors by: Doing awareness campaigns over emails and SMS on right selling practices & on the code of conduct of the Company. Conducting trainings on regular basis for the agents, intermediaries. Conducting regular snap audits on adherence to the code of conduct of the Company. Launching compliance guide containing code of conduct for agents in selected regional languages. D. Corrective steps / actions against errant employees / agents A consequence management grid shall be put in place for distribution channels, defining the action to be taken on errant employees / agents, who are involved in any mis-selling of policies or any other malpractices at the time of policy solicitation. The action could include issuance of warning letters or the termination of the errant employees / agents. The Employee Disciplinary Action Plan (EDAP) is owned by the HR function of the Company and Agent Disciplinary Action Plan (ADAP) is owned by the Distribution Compliance function of the Company. E. Steps taken to ensure full disclosure during policy solicitation: Prospectus and policy document (Terms and Conditions) are readily available on Max Bupa s website. All the product features, benefits, waiting periods, exclusions and claim related requirements are explained in these documents. Brochures are also prepared in simple & petite formats so that prospects can quickly read and understand the key benefits, waiting periods and exclusions in the product before concluding a sale. At the time of policy solicitation, a Key Feature Document is shared with prospect and is duly signed by him/her and also forms part of the policy document. 9. Governance To protect the interests of policyholders and in-line with the prescribed guidelines, Max Bupa has set up a Policyholder Protection Committee (PPC), reporting to the Board. The PPC would review trends on all these aspects as per frequency below and recommend improvements in processes and controls to address policyholders protection. The Committee is also responsible for ensuring compliance to statutory requirements as laid down in the regulatory framework and adequacy of disclosing of material information to the policy holders. Page 10 of 18
Item Insurance awareness activities Services parameters and turn-around-time and any exceptions to these parameters with root cause analysis Grievance resolution trends Strengthening market conduct Frequency of review and noting Quarterly Half Yearly Quarterly Quarterly Management shall also conduct Customer Council meetings, chaired by the CEO focusing on issues impacting policyholders interests. The objective of this council shall be to define the architecture of customer experience management, explore disruptive innovation to build customer experience as a competitive advantage, define the purpose and behavioral building blocks for related functions, oversee effective employee engagement and equip and empower employees. The charter of this council shall include a formal monthly review of strategic treating customers fairly initiatives supporting the six pillars of the Company TCF framework, including aspects pertaining to need based sales, suitable advice, transparent communication and allied business practices that may impact the quality of sale. The executive leadership team of Max Bupa, including the CEO and the company s Grievance Officer, shall review grievance details (e.g. number, nature of grievance and resolution) every month. This shall also be reviewed quarterly by the Board appointed Policyholder Protection Committee. Page 11 of 18
Addendum I: Proposed Grievance Redressal Policy Page 12 of 18
Grievance Redressal Policy Max Bupa Health Insurance Co. Ltd. Distribution: IRDAI submission, Max Bupa corporate website and internal circulation Version: 1.7 Last approved by Board of Directors: 2, February 2017 Grievance Redressal Officer: Chief Operating Officer Reviewed by: Director & Head Legal, Compliance & Regulatory Affairs Page 13 of 18
Contents 1. Introduction... 15 2. Definitions... 15 3. Grievance organization structure... 16 4. Process of receiving grievances... 16 5. Grievance software... 16 6. Categorisation of complaints... 17 7. Process and resolution times for grievance... 17 8. Resolution of Grievance... 17 9. Process of escalation... 17 10. Grievance review mechanism... 18 11. Assurance... 18 12. Policy ownership... 18 13. Review... 18 Page 14 of 18
1. Introduction 1.1 At Max Bupa Health Insurance Co. Ltd. (referred to as the Company, Max Bupa in this document), our vision is To become India s most admired health Insurance Company. Our mission is To help customers live healthier, more successful lives. We are committed to servicing our customers with excellence. 1.2 Towards this objective, we have adopted the principle of Treating Customers Fairly (TCF). To achieve our TCF goal, our Management philosophy, processes and systems are developed in a manner that: Our customers can be confident that they are dealing with a company where the fair treatment of its customers is central to its corporate culture. Our products and services are designed to meet the needs of identified consumer groups and are targeted accordingly. Our customers are provided with clear information and are kept appropriately informed before, during, and after the point of sale. Our customers receive advice from the company and its representatives which is appropriate for them and takes into account their circumstances. Our products perform as the company led its customers to expect and its customer service is both of an acceptable standard and also as its customers have been led to expect. Our customers do not face post-sale barriers to cancel (under free look provision), submit a claim, or make a complaint. 1.3 In line with our overall objective of service excellence and as per Regulation 5 of IRDAI (Protection of Policy Holder s Interest, 2002) and IRDA circular dated July 27, 2010 bearing reference number 3/CA/GRV/YPB/10-11, a comprehensive Board approved Grievance Redressal Policy has been put in place by the Company for which the details are set out in the following sections. 2. Definitions 2.1 Grievance/Complaint - A Complaint or Grievance means written expression (includes communication in the form of electronic mail or other electronic scripts), of dissatisfaction by a complainant with insurer, distribution channels, intermediaries, insurance intermediaries or other regulated entities about an action or lack of action about the standard of service or deficiency of service of such insurer, distribution channels, intermediaries, insurance intermediaries or other regulated entities. 2.2 Inquiry - An Inquiry is defined as any communication from a customer for the primary purpose of requesting information about a company and/or its services. 2.3 Request - A Request is defined as any communication from a customer soliciting a service such as a change or modification in the policy. 2.4 Redressal is defined as the resolution or disposal of the grievance and communication to the complainant. In the event of non-redressal or delay in redressal, the company is to communicate the reasons to the complainant. 2.5 IGMS stands for the integrated grievance management system created by the IRDAI to centrally track grievances for all health insurance companies. 2.6 CRM system stands for Max Bupa customer relationship management system currently in use to manage and resolve all customer grievances. 2.7 IVR refers to the interactive voice response system which enables self-help for the customers at the customer contact center. Page 15 of 18
3. Grievance organization structure 3.1 In terms of Clause 3 of IRDA Circular dated July 27, 2010 bearing reference number 3/CA/GRV/YPB/10-11, Company has nominated the Chief Operating Officer of the Company as its Designated Grievance Redressal Officer at Corporate Office, supported by the Senior Vice President & Head Customer Service & Operations. 3.2 In order to effectively address customer grievances, the Company has nominated the Office Heads in each of its branch office as the Grievance Officer for their respective office. Office Heads are responsible for receiving and managing grievances originating from their office. 3.3 The company has also appointed Grievance Redressal Officers at head office who have the overall responsibility to ensure that the grievance redressal guidelines are adhered to, along with the reporting of grievances to the Management on monthly and quarterly basis. 4. Process of receiving grievances 4.1 The head office and each branch office of the Company have a well-defined process of receiving and registering grievances. We encourage our customers to report to us any grievance or issue that they face regarding their policies or dealings with us. 4.2 Customers can use the following avenues to report grievances to the Company: Branch office: Contact the customer service executive or write to the Grievance Officer at our branch offices, explaining the details of the issue concerned. Company website & email contact: Visit us at www.maxbupa.com or write to us at customercare@maxbupa.com Customers portal: Log on to our policy holder portal at www.maxbupa.com Email id for senior citizens: To ensure that our customers which fall into the category of senior citizens have a separate platform to register their grievances with us; we have created an exclusive email id for them: seniorcitizensupport@maxbupa.com Head office: Customers can also address their grievance at the below mentioned address: Grievance Redressal Unit Max Bupa Health Insurance Co. Ltd. B-1/I-2, Mohan Cooperative Industrial Estate Mathura Road, New Delhi - 110044 5. Grievance software 5.1 Max Bupa registers and resolves all grievances with the help of a robust Customer Relationship Management (CRM) System. 5.2 Each grievance registered in the system generates a unique reference number which is also shared with the complainant. 5.3 As per IRDAI s requirement and direction, the CRM is integrated with the IRDAI s Integrated Grievance Management System (IGMS) where grievances received by Max Bupa are reported to IRDAI on a real time basis, along with the generation of an IRDAI token number for each grievance. Page 16 of 18
6. Categorisation of complaints The Company shall adopt the categorisation of complaints and associated turnaround times as prescribed by IRDA from time to time and shall incorporate in the system. 7. Process and resolution times for grievance 7.1 Grievance acknowledgement: On receipt of a grievance, the Company first assesses it on the basis of its merits and nature of grievance. Max Bupa sends a written acknowledgement to the customer within 3 working days of the receipt of the grievance. The grievance acknowledgement contains the name and designation of the officer who will deal with the grievance. It also contains details of Max Bupa s grievance redressal procedure and the timeline for resolution of the grievances. 7.2 Grievance resolution: Grievance is to be resolved within 2 weeks of its receipt and each resolution is conveyed vide a final resolution letter. This final resolution letter offers redressal or rejection of the issue, along with reasons. The resolution letter also informs the complainant about how the customer can pursue the grievance, if dissatisfied. 7.3 If the grievance is resolved within 3 working days, the grievance resolution is communicated along with the grievance acknowledgement. 8. Resolution of Grievance 8.1 Max Bupa endeavors to resolve all grievances to the satisfaction of the customers. In order to ensure fair resolution for the customer, the Regulator has set conditions for treating the grievances as closed. 8.2 As per IRDAI regulations, a grievance shall be considered as disposed off and resolved: When Max Bupa has acceded to the request of the complainant fully. Where the complainant has indicated in writing, acceptance of the response of the insurer. Where the complainant has not responded to the insurer within 8 weeks of the Company s written response. 8.3 Max Bupa s Grievance Redressal Policy follows the above definitions. 9. Process of escalation 9.1 The customers can write to Gargi Sahu at grievanceredressal@maxbupa.com 9.2 In case customers do not receive a response within the prescribed timeline by the Company, they may escalate their grievance to Navin Sahni at priority.services@maxbupa.com 9.3 In case a complainant is not satisfied with the resolution from the above escalation, they can escalate their grievance to the Grievance Redressal Officer of the company Vikas Gujral at GRO@maxbupa.com Name Designation Contact Details Gargi Sahu General Manager &Grievance Redressal Officer grievanceredressal@maxbupa.com Navin Sahni SVP &Grievance Redressal Officer priority.services@maxbupa.com Vikas Gujral Director & COO - Designated Grievance officer GRO@maxbupa.com 9.4 In case a complainant is not satisfied with the resolution from the above escalation authority, they can Page 17 of 18
contact the Insurance Ombudsman. The detailed addresses of all the Insurance Ombudsman are mentioned in the policy document and on our corporate website. 10. Grievance review mechanism The Chief Executive Officer & Managing Director, Chief Operating Officer, and the Head of Customer Service reviews grievance details (e.g. number, nature of grievance and resolution) on a monthly basis. This is also reviewed quarterly by the Board appointed Policyholder Protection Committee. 11. Assurance 11.1 The Board of Directors of Max Bupa has constituted a Policyholder Protection Committee to assist the Board in fulfilling its statutory and fiduciary responsibility to oversee the various compliance issues in relation to the protection of policyholder s interests, including the need to keep the policyholders well informed of and educated about insurance products and complaint-handling procedures. In addition, on behalf of the Board, the Committee is responsible to oversee the elements of the company s Treating Customers Fairly (TCF) program. 11.2 It is also to be noted that the overall system of grievance management within the Company is an auditable area with periodic reviews reflected in its annual audit plans. Significant audit observations are discussed by the Committee with management to ensure an effective closure. 12. Policy ownership This Policy is owned by Chief Operating Officer (COO). COO will have the responsibility to implement and ensure compliance to this Policy. Any deviation to this Policy is to be reported to the Board via Policyholders Protection Committee of the Company by the Chief Compliance Officer. 13. Review This policy will be reviewed every two years or as and when required. Page 18 of 18