Grievance Redressal & Fraud Monitoring Policy

1. Grievance Redressal Framework

A. Definitions

• •"Grievance/Complaint" — Any communication that expresses dissatisfaction about an action or lack of action, about the standard of service/deficiency of service on part of the company and/or asks for remedial action.
• •"Inquiry" — Any communication from the customer for the primary purpose of requesting information about the company and/or its services.
• •"Request" — Any communication from a customer soliciting a service such as a change or modification in the policy.
• •"Complainant" — Any policyholder (including legal heirs, assigns, or legal representative) who reports a grievance to the company.

B. Registration of Customer Grievances

The touch points and mode of receipt of customer grievances:

C. Grievance Redressal Procedure

D. Escalation Matrix

If you do not receive a response within the defined TAT, please follow the escalation matrix below:

E. Grievance Redressal Committee

The Company has formed a Grievance Redressal Committee which meets once a quarter to review the status of grievance disposal.

Responsibilities:

• •Putting in place proper procedures and effective mechanisms to address grievances including mis-selling, forgery, and document tampering.
• •Ensure compliance with statutory requirements as laid down in the regulatory framework.
• •Review of the mechanism at periodic intervals.
• •Provide details of grievances at periodic intervals as prescribed by the authority.

Composition:

• •Manager, Grievance Team
• •Grievance Officer
• •Director & Principal Officer

2. Classification of Grievances

3. Time Frame for Resolving Grievances

The company shall resolve all grievances within the time frame of 14 days or as prescribed by the Regulator from time to time.

4. Proactive Steps to Reduce Grievances

• •Continuous improvements of sales process by enhancing internal controls.
• •Steps towards timely & accurate servicing.
• •Further enhancement of the PIVC (Pre-Issuance Verification Call).

5. Fraud Monitoring Framework

Definitions

• •"Insurance Fraud" — An act or omission intended to gain advantage through dishonest or unlawful means, including misappropriating funds, deliberately misrepresenting/concealing material facts, or abusing a position of trust or fiduciary relationship.
• •"Red Flag Indicator (RFI)" — A possible warning sign that points to a potential fraud and may require further investigation.
• •"Cyber or New Age Fraud" — Any insurance fraud carried out using digital or new-age technologies.

Fraud Categorization

• 1.Internal Fraud: Fraud involving internal staff, including employees and/or senior management.
• 2.Policyholder/Claims Fraud: Fraud involving any person(s) in obtaining coverage or payment during the purchase, servicing, or claim of an insurance policy.
• 3.External Fraud: Fraud involving external parties/service providers/vendors.
• 4.Affinity/Complex Fraud: Fraud involving collusion among one or more fraud perpetrators across categories.

Fraud Monitoring Committee (FMC) & Unit (FMU)

A Fraud Monitoring Committee (FMC) is established to operationalize the fraud risk management framework and oversee activities to ensure fraud deterrence, prevention, detection, reporting, and remedying.

A Fraud Monitoring Unit (FMU), independent from internal audit, supports the FMC in discharging its functions.

FMC Powers & Responsibilities:

• •Power to control, deter, prevent, detect, report, and remedy frauds.
• •Follow regulatory policy/framework supplemented by additional controls specific to insurance business.
• •Impart education, awareness, and training to employees with proper investigation and internal reporting structure.
• •Procedure for reporting frauds to Law Enforcement Agencies (LEAs) and follow-up for final disposal.
• •Due diligence procedures for appointing employees/sales persons and a Whistle Blower reward.

Fraud Control Procedure

• •All fraud-related communications will be received at protect@hellovima.com or at the corporate office.
• •Written acknowledgement within 24 hours (not more than 48 hours in extreme circumstances).
• •FMU will provide resolution within 14 working days.
• •Detailed investigation with PIVC recording review and AAP (Assertive Action Plan) as applicable.

6. Actions Taken

A committee comprising the Grievance Officer, Head – HR, and Principal Officer will take appropriate action against employees found guilty. Punishment is decided based on severity and may range from verbal/written warning to termination.

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