The consistently high quality and rapid processing of complaints is of crucial importance to create a positive customer experience and thus emsure lasting customer loyalty.
We have a clearly defined set of core values in place to outline our expectations on staff conduct when dealing with clients and other stakeholders, including shareholders, regulators, and the communities where we operate. Those values should be reflected in the fair, prompt, and impartial handling of complaints, which includes a complaint handling policy framework to facilitate a consistent approach to complaint management, as well as oversight that satisfies regulatory requirements.
In order to support strong client relationships and client retention, our complaint handling policy and procedures is one method by which we demonstrate the following principles:
- Client satisfaction enhancement
- Reduction of mistakes and attributable costs
- Risk transparency enhancement
- Management information for quality optimization
During 2017, in order to meet enhanced regulatory expectations and obligations, our Group policy “Minimum Requirements for Handling and Recording of Complaints” which establishes a Group-wide framework, was revised and enhanced, including minimum requirements for the recording, handling, and reporting of complaints and measures to be taken for their resolution. The framework is in accordance with the European Securities and Markets Authority (ESMA) and MiFID II, and will allow for a number of improvements to existing processes:
Globally consistent minimum requirements for the recording, handling and reporting of complaints and measures to be taken for their resolution
Better qualitative analysis of complaints and complaints handling on a global, cross-divisional basis through a new centralized management information reporting process
- Improved reporting to Non-Financial Risk (NFR) committees and the Management Board (MB)
- The business divisions are responsible for developing and implementing procedures that incorporate the objectives and minimum requirements set out in this policy
- The approach described applies to all our businesses.
Private & Commercial Bank
For PCB, client complaints offer the opportunity to continuously improve services, products, and processes. The complaint management activities are focused on consulting services and enhanced investment advisory process.
PCC Germany, PCC International and Postbank
Within PCC Germany, the Head of Complaint Management reviews all serious complaints personally. He also provides the Bank with impartial advice on how best to develop and optimise our products and processes, ensuring that clients' interests are considered. He has no responsibility for profits in any way and is therefore a neutral decision-maker.
The guidance around complaint management applies to all employees. The ability to handle formal complaints professionally and transparently is an extremely important factor influencing client satisfaction. We aim to anticipate and avoid potential complaints before they arise. To this end, we pass on process faults to responsible areas for the purpose of achieving quality improvements for our customers.
The central PCC complaint management team in Germany reports directly to the Head of Client Concern. Following our internal processes, complaints expressed at our branches are dealt with locally. A significant number of complaints are solved during initial contact with the customer. We acknowledge receipt of each complaint immediately, stating the estimated processing time to the customer. If we are unable to process a complaint within the stated time, the client will be notified accordingly. We issue a client information sheet with each first receipt, which is also available for download from our website, offering a clear description of how we handle complaints.
Correspondence with our clients aims to be comprehensible. Quality criteria are defined and complaint managers are constantly trained in communication. Internal controls contribute to a sustainable quality assurance.
We have established a separate process for hardship cases, for example where clients get into financial difficulty for reasons beyond their control. In 2017, four cases were resolved accordingly.
In addition, our Head of Complaint Management personally contacts selected clients who have given serious complaints. This direct dialogue helps us to better understand the reasons for complaints and provides insight into how we are perceived by our clients.
We aim to rectify complaints as quickly as possible, without excess bureaucracy, and to settle any justified compensation claims directly. Whether or not a complaint is justified is assessed by the complaint processor on the basis of the bank's policies and procedures. The year 2017 saw a further drop in the number of complaints received by PCC Germany. Topics raised included media reports dealing with legal disputes, closed-end funds and branch closures, most of which we were able to resolve locally at the relevant branch. For PCC Germany, we report to the Management Board on a monthly basis. The PCC Global Complaint Report goes out quarterly.
For PCC International, there was a further decline in the number of complaints received, reflecting the previous year’s trend. Most were related to the implementation of new regulations and, in the case of Spain, legal provisions affecting such matters as mortgage incorporation costs and interest rate floor clauses.
Postbank applied the regulatory EU guidelines of the ESMA and the European Banking Authority (EBA) to optimize its complaints processes, making them more transparent for the customer and communicating them on its website. As a result, Postbank has seen a more timely integration of complaints management into planned sales activities and the placement of new products and services as a complaint prevention measure. In the challenging market environment, Postbank receives complaints about branch network and the adaptation of its product portfolio; nevertheless, the overall number of complaints was significantly lower than in the previous year.
Regional Wealth Management Chief Operating Offices (COO) define the complaint management process in order to make sure that regional aspects are considered sufficiently.
Customer complaints with regard to alleged unsuitable advice or lack of product suitability are a key indicator for the WM risk profile. The number of customer complaints is an indicator for potential upcoming litigations or out-of-court settlements with customers that claim unsuitable advice or lack of product suitability.
A complaint Key Risk Indicator (KRI) tracks suitability-related client complaints. The KRI uses the absolute number of customer complaints with regard to alleged unsuitable advice / lack of product suitability received in a particular location/unit during the reporting period. We see a positive trend versus 2016, in other words a smaller number of complaints.