Coöperatieve Centrale Raiffeisen-Boerenleenbank B.A. U GRIEVANCE REDRESSAL POLICY & PROCEDURE 1
Contents Para No. Particulars 1 Introduction 2 2 Complaint handling procedure 2 2.1 Internal mechanism to handle customer complaints/ grievances 2 3 Responsibility of nodal officer 3 3.1 Resolution of grievances 3.2 Closure Of complaints 3.3. Monitoring the IBA Code of Banking Practice 3.4 Sensitizing operating staff on handling complaints 3 3 4 4 4 5 6. Interaction with customers Privacy related complaints from customers/representatives of customers Review of grievance redressal mechanism Page No. 4 4 5 Annexures Annexure 1 Annexure 2 Annexure 3 Grievance Redressal Form Banking Ombudsman Scheme, 2006 Banking Ombudsman Complaint Form Rabobank Grievance Redressal Policy & Procedure 1
1. Introduction Coöperatieve Centrale Raiffeisen-Boerenleenbank B.A., Mumbai branch (herein under called the Bank ) has a core philosophy of providing prompt and efficient customer service. The Bank believes excellence in customer service is the most important tool for sustained business growth. This policy document aims at minimizing instances of customer complaints and grievances through proper service delivery and review mechanism and to ensure prompt redressal of customer complaints and grievances. This policy is drawn up in compliance with the Reserve Bank of India master circular on customer service in banks. The Bank s policy on grievance redressal follows the under noted principles : Customer should be treated fairly at all times. Complaints received from customers must be dealt with promptly. Customers should be informed of avenues available to redress their complaints/grievances within the organization and their rights to alternative remedy, if they are not fully satisfied with the response of the Bank to their complaints. The Bank employees must work in good faith and without prejudice to the interests of the customer. How the Bank deals with every complaint including the findings associated, should reflect Rabobank Group s standard of ethic and professional integrity. In addition to this policy, the Bank will also be guided by the Code of Conduct and the Worldwide Compliance Standards of the Rabobank Group. 2. Complaints Handling Procedure At the first instance, the complaint will be attended to at the May I Help you desk, where the counter staff should make all efforts to resolve the complaint immediately. If not satisfied, the customer can escalate the complaint as per the mechanism laid down in this policy. Customers will be given information regarding the following: Process for filing written complaint in the prescribed format. The Complaint Form is available in the Complaint Book at the May I Help you desk. Process for escalation of complaint to a higher authority in the Bank in case of delayed or unsatisfactory response. Their rights to approach the Banking Ombudsman in case of dissatisfaction with Bank s response to their complaint. The Bank has appointed a Nodal Officer who will be responsible for the implementation of customer service and complaint handling for the entire bank. 2.1 Internal mechanism to handle customer complaints/ grievances : In order to make the Bank s redressal mechanism more meaningful and effective, a structured system has been put in place. Level 1 : Customers can contact The Chief Operations & Information Technology Officer, who has been designated as the Nodal Officer of the Bank, personally or in writing, for resolution of their issues, explaining the details of the issue involved. Customers can also register their grievances by submitting a duly filed in Complaint Form as specified in ANNEXURE 1 to this policy. The Complaint Form is also available in the Complaint Book at the May I help you Desk. Rabobank Grievance Redressal Policy & Procedure 2
Alternately, customers can also write to the Bank at Rabobank International (Coöperatieve Centrale Raiffeisen-Boerenleenbank B.A.), 20/F, Tower A, Peninsula Business Park, Lower Parel, Mumbai 400 013 or call on (91 22) 2481 700 or send a fax on (91 22) 2481 7979 Every complaint received will be acknowledged and an acknowledgement will be given to the customer immediately at the time of noting the complaint. All efforts will be made by the concerned Bank official to sort out the matter at the Level 1 within 15 working days. If the matter is not resolved at Level 1 then the customer has access to Level 2. Level 2 : If the customer is not satisfied with the response from Level 1, then the customer can escalate the complaint in writing to the Chief Executive Officer at Rabobank International (Coöperatieve Centrale Raiffeisen-Boerenleenbank B.A.), 20/F, Tower A, Peninsula Business Park, Lower Parel, Mumbai 400 013, India. All attempts will be made to resolve / address the complaint within 15 working days after receiving a complaint in writing. Level 3 : In the event that the customer is not satisfied with the grievance redressal or does not receive any response within 30 days from the date the Bank received the representation, then the customer may write to the Banking Ombudsman, a statutory body appointed by the Reserve Bank of India under its Banking Ombudsman Scheme 2006 as per ANNEXURE 2, to look into the provision of satisfactory service by banks. The complaint to the Banking Ombudsman can be done at Banking Ombudsman situated at C/o Reserve Bank of India, Garment House, Ground Floor, Dr Annie Beasant Road, Worli, Mumbai 400 018 in the prescribed format given in ANNEXURE 3. The Bank will prominently display : the above mechanism for receiving complaints and the contact details of the Nodal Officer designated by the Bank and the Banking Ombudsman of the area. 3. Responsibility of Nodal Officer 3.1 Resolution of complaints /Grievances Resolution of complaints/grievances in respect of customer service by the Bank and for ensuring closure of all complaints received at the Bank. It is the foremost duty of the Nodal Officer to see that the complaint should be resolved completely to the customer s satisfaction and if the customer is not satisfied, then the customer should be provided with alternate avenues to escalate the issue. If the Nodal Officer feels that it is not possible at his level to solve the problem, he can refer the case to the CEO. The Bank has set the maximum period of 30 days for redressal of all types of complaints. However, in certain cases, where the redressal requires information / co-ordination with other agencies (delay due to feedback from external entities) the time period could be extended and the same would be intimated to the customer, well in advance. 3.2 Closure Of Complaints A complaint will be closed only if the grievance is redressed. If no deficiency in service is found, the complaint will be closed and the customer will be advised the reasons for not treating the matter as grievance. Where the complaint has been Rabobank Grievance Redressal Policy & Procedure 3
made to the Banking Ombudsman, the redressal of the complaint will be on the basis of decision/award given by Banking Ombudsman. Decision to prefer appeal against the award by Banking Ombudsman will be taken on case to case basis. If decided to honour the award, it will be implemented within the time frame as stipulated by Banking Ombudsman Scheme 2006. 3.3. IBA Code of Banking Practice Monitoring the IBA Code of Banking Practice and to ensure the observance /compliance of the code by the Bank. 3.4 Sensitizing operating staff on handling complaints The Nodal Officer has the responsibility to ensure that the internal mechanism for handling complaints/grievances operates smoothly and efficiently at all levels. The Nodal Officer is also responsible for giving feedback on training needs of staff at various levels to the HR Department. 4. Interaction with Customers The Bank recognizes that customer s expectation/requirement/grievances can be better appreciated through personal interaction with customers by the Relationship Managers of the Bank. The Relationship Managers contact with customers have been structured to provide an interactive communication system between the customer and the Bank to facilitate feedback on products and services provided by the Bank on a regular basis. As for the Bank, the feedback from customers would be valuable input for revising / improving its product and services to meet customer requirements. 5. Privacy related complaints from customers/representatives of customers Customer has the right to complain if they think that the Bank does not comply with the requirements of the Privacy Code, or otherwise infringes their rights to privacy A customer can lodge a privacy complaints by filling and sending across the Privacy Complaint Form (As per Annexure 4). Any privacy complaint received from a customer should be immediately informed to Head of Compliance, who is the Local Privacy Officer (LPO) for the Bank. Within four weeks of receiving such a complaint, the LPO will respond to the concerned customer in writing, the step taken by the Bank to suitably redress the complaints. The Bank endeavors to notify its stance on the complaint to the customer, within 4 weeks of receiving such complaints. On exceptional circumstances, if more time is required to handle a specific complaint, the concerned customer will be notified about the same within 4 weeks of receiving the initial complaint and the ultimate timeline will not be more than additional 4 weeks (i.e. within 8 weeks of receiving the initial complaint). Escalation Procedure The escalation procedure, as applicable to any other complaint (including the escalation to relevant Banking Ombudsman), will be applicable to privacy complaints. Additionally, customer will have an additional escalation level to the Rabobank Chief Privacy Officer, after he/she has exhausted all local escalation options available. However, this escalation level will be used as a last option and customers will be asked to confirm that they have exhausted all available local escalation level and hence want to approach the CPO level. Reporting Procedure LPO will keep the bank s CPO informed of the summary of the privacy complaints received and the responses provided for each. Further, the Rabobank Grievance Redressal Policy & Procedure 4
details of the complaints and related answers provided to customers, will be shared with CPO, upon receiving a specific request for the same. Additionally, LPO will provide quarterly statistics on privacy complaints to local management and the CPO by mean of the quarterly reporting. 5. Review of Grievance Redressal Mechanism Disputes/concerns/complaints will be addressed in accordance with the Bank s Customer Grievance Redressal Policy. Recurring problems or issues will be discussed with the Management and specific preventive/corrective actions will be taken. A review of compliance in respect of the functioning of the grievance redressal mechanism would be conducted by the Bank once a year. Rabobank Grievance Redressal Policy & Procedure 5
Annexure 1 - Complaint Form Complaint Form (Complainant s / Nodal Office / Branch copy) To Date : Coöperatieve Centrale Raiffeisen- Boerenleenbank B.A. 20/F, Tower A, Peninsula Business Park, Lower Parel, Mumbai 400013 Dear Sir, Account No. Name of the complainant :... Address :.. Nature of Account :... (Please state nature of account viz. Savings Bank/Current/CC/Term Deposit/Loan Account etc. related to the complaint matter). Telephone / Mobile No. :. Detailed description of the complaint: Event Date :. List of documents enclosed : Rabobank Grievance Redressal Policy & Procedure 6
I/We the complainant/s herein declare that the information furnished herein above is true and correct and that I/we have not concealed or misrepresented any fact stated in aforesaid columns and the documents submitted herewith. Yours faithfully, Signature of complainant Note :-Please note that the first point for redressal of the complaint is the bank itself and if complaint is not settled/redressed within a period of one month from the receipt of the complaint by our Bank, the complainant may approach the Banking Ombudsman under whose aegis/jurisdiction our Bank s branch falls under. (For Bank use) Complaint Resolution Date :. Steps Taken : Annexure 2 Banking Ombudsman Scheme ANNEXURE 2 - Banking Ombudsman S Rabobank Grievance Redressal Policy & Procedure 7
Annexure 3 Banking Ombudsman Complaint Form FORM OF COMPLAINT (TO BE LODGED) WITH THE BANKING OMBUDSMAN Complaint No of year Date (TO BE FILLED UP BY THE COMPLAINANT) To The Banking Ombudsman C/o Reserve Bank of India, Garment House, Ground Floor, Dr Annie Beasant Road, Worli, Mumbai 400 018. Dear Sir, Sub: Complaint against (Name of the bank s branch) (Name of the Bank) Being aggrieved the complainant named herein has submitted a complaint with the above referred bank. Details of the complaint are as under: Name of the Complainant Address Pin Code Phone no / Fax No 3. COMPLAINT AGAINST (NAME AND FULL ADDRESS OF THE BRANCH/ BANK) Bank name & branch Address Pin Code Phone no / Fax No 4. PARTICULARS OF BANK ACCOUNT (Please state nature of account viz. Savings bank/current/cash credit/term deposit/loan account etc. related to the subject matter of the complaint being made) (1) Rabobank Grievance Redressal Policy & Procedure 8
5. (a) DATE OF REPRESENTATION BY THE COMPLAINANT TO THE BANK (Please enclose three copies of the representation) D D M M Y Y (b) Whether any reminder was sent by the complainant? (If yes, please enclose three copies of the reminder) 6. SUBJECT MATTER OF THE COMPLAINT (Please refer to Clause 8 of the Scheme) 7. DETAILS OF THE COMPLAINT (If space is not sufficient Please enclose separate sheet) YES NO 8. (a) Whether any reply (Within a period of one month after the bank concerned received the representation) has been received? (If yes, please enclose 'three copies' of the bank's reply) YES NO (b) Whether the representation has been rejected? (If yes, please enclose 'three copies' of the bank's letter) YES NO (c) Whether the complainant has received any other final decision of the bank? (If yes, please enclose 'three copies' of the bank's letter conveying its final decision) YES 9 NATURE OF RELIEF SOUGHT FROM THE BANKING OMBUDSMAN (Please enclose 'three copies' of documentary proof, if any, in support of your claim) NO 10. NATURE AND EXTENT OF MONETARY LOSS, IF ANY, CLAIMED BY THE COMPLAINANT BY WAY OF COMPENSATION Rs.. (Please enclose documentary proof if any, to show that such loss is actual loss caused as a direct consequence of alleged omission or commission of the bank) 11. LIST OF DOCUMENTS ENCLOSED (Please enclose 'three copies' of all the documents) (2) Rabobank Grievance Redressal Policy & Procedure 9
12. DECLARATION 1. I/ We, the complainant/s herein declare that: The information furnished herein above is true and correct; and I/ We have not concealed or misrepresented any fact stated in aforesaid columns and the documents submitted herewith. 2. The complaint is filed before expiry of period of one year reckoned in accordance with the provisions of Clause 9(3) (a) and (b) of the Scheme. 3. (a) The subject matter of the present complaint has never been brought before the Office of the Banking Ombudsman by me/ or by anyone of us or by any of the parties concerned with the subject matter to the best of my/ our knowledge. (b) The subject matter of the present complaint is not in respect of the same which was settled through the Office of the Banking Ombudsman in any previous proceedings. (c) The subject matter of the present complaint has not been decided by any forum/court/arbitrator. 4. l/we authorise the bank to disclose any such information/ documents furnished by us to the Banking Ombudsman and disclosure whereof in the opinion of the Banking Ombudsman is necessary and is required for redressal of any other complaint or our complaint. 5.l/We have noted the contents of the Banking Ombudsman Scheme,2006 Yours faithfully, (Signature of Complainant) (3) Rabobank Grievance Redressal Policy & Procedure 10
NOMINATION -(If the complainant wants to nominate his representative to appear and make submissions on his behalf before the Banking Ombudsman or to the Office of the Banking Ombudsman, the following declaration should be submitted.) l/we the above named complainant/s hereby nominate Shri/Smt who is not an Advocate and Whose address is as my/our REPRESENTATIVE in all proceedings of this complaint and confirm that any statement, acceptance or rejection made by him/her shall be binding on me/us. He/She has signed below in my presence. ACCEPTED (Signature of Representative) (Signature of Complainant) (4) Rabobank Grievance Redressal Policy & Procedure 11
Annexure 4 Privacy Complaint Form Form Privacy Complaint Clients (Privacy Code article 17) Through this form you may submit a complaint in respect of the handling of your personal data by Rabobank. Contact details complainant (to be filled in by complainant) Sur name Names Department Telephone number E-mail (Rabobank) Personnel number Subject: Complaint in respect of the handling of my personal data by Rabobank <specify><department> Question / Remark / Complaint: Procedure Please send the Form by email to prakash.gupta@rabobank.com or to Rabobank International (Coöperatieve Centrale Raiffeisen-Boerenleenbank B.A.), 20/F, Tower A, Peninsula Business Park, Lower Parel, Mumbai 400 013, India. You will be informed within four weeks of receiving your complaint about how your complaint will be handled. Rabobank Grievance Redressal Policy & Procedure 12