Grievances Redressal Policy

FOR INTERNAL CIRCULATION Grievances Redressal Policy Birla Sun Life Insurance Aaft^

Complaints are an opportunity for an organization to understand or identify gaps in the process, product or communication and work towards process improvements and cement the Company's relationship with dissatisfied customers. Complaint handling process is part of the customer care initiative:, Regulation 5 of the Insurance Regulatory and Development Authority (Protection of Policyholders' Interests ) Regulations, 2002 prescribes that every insurer shall have in place proper procedures and effective mechanism to address complaints /grievances of policyholders efficiently and with speed. The purpose of this Grievance Redressal Policy (hereafter referred to as the 'Policy') is to set forth the policies and procedures to be followed in receiving, handling and responding to any complaint against BSLI ("the Company"). This process encompasses complaints relating to all products issued by the Company and/or solicited by its agents or independent brokers. Products in this Policy will be referred to as "policies", which encompasses all life insurance policies sold by the Company. Further, it is the Company's guiding principle to provide prompt and fair resolution of customer complaints in accordance with all legal and regulatory guidelines. It is imperative that the policies and procedures outlined in this Policy be fully understood and diligently followed by all employees, agents, independent brokers, and managerial personnel engaged in the Company's customer complaint handling process. Phis Policy will be updated periodically. directed to: Any questions concerning this Policy should be Compliance Birla Sun Life Insurance Company One India Bulls Centre, Tower 1, 15th Floor, Jupiter Mill Compound, Elphinstone Road, Mumbai - 400 013.Uarclr 2010 Prepared by BSLI I er.cirur,i /

BSLI Grievances Rcdlressal I'olirv DUINIT1ONS Complaint Includes any documented verbal or written statement (including a-mails and faxes) from a client or any person acting on behalf of a client which alleges a grievance involving the design, performance, underwriting, administration, claim settlement of a BSLI product or the activities of any employee/agent/broker of the Company in connection with their solicitation or execution of any transaction or disposition of a client's funds. A complaint is an unpleasant customer experience with any of BSLI's touch points leading to dissatisfaction. Complaints can be classified as: 1. Functional : Direct Sales Force, Group Business, Third Party Distribution, Underwriting, Client Services, Actuarial, Finance and Planning, etc. 2. Internal: Complaints received from o Insurance Advisor (IA) o Corporate Agent (CA) o Broker The complaint could be regarding some dissatisfaction about sales practice(s) of the Company, delay/wrong commission received by the IA/CA/Broker, alleged rebating by another IA/CA/Broker, misconduct or fraudulent act by the medical examiner/laboratories/any sales intermediary and/or any other market misconduct 3. External: Complaints received from: o Prospects/ policyholders o Regulatory/ statutory body / Ombudsman o Media/ advertising forum/ policyholder forum Includes cases pertaining to any delay in delivery/ non-receipt of policy documents, delay in resolving queries/ complaints, delays/ repudiation of claims, non-adherence to service standards, misconduct of IA/CA/Broker, etc. Insurance advisor As per Section 2(10) of the Insurance Act, 1938, an "Insurance Advisor" means any person licensed under Section 42 of the said Act to solicit and procure insurance business, including business relating to the continuance, renewal or revival of policies of insurance, and receives remuneration by way of commission or other remuneration for the business thus solicited or procured March 20/0 Prepared by BSLI 3 I'ersion.,/

Intermediary and Insurance Intermediary Section 2(1013) of the Insurance Act, 1938, read with Section 2(1)(f) of the Insurance Regulatory & Development Authority Act, 1999, states that "intermediary and insurance intermediary" includes insurance brokers, reinsurance brokers, insurance consultants, surveyors and loss assessors Corporate Agent Regulation 2(t) read with Regulation 2(k) of the Insurance Regulatory and Development Authority (Licensing of Corporate Agents) Regulations, 2002, defines a "Corporate Agent" as any person licensed to act as such; "Person" means a: Firm; or Company formed under the Companies Act, 1956, and includes a banking company as defined in Section 2(4A) of the above Act; or Corresponding new bank as defined under Clause 5(1)(d)(a) of the Banking Regulation Act, 1949 (X of 1949); or Regional Rural Bank established under the Regional Rural Bank Act, 1976; or Cooperative society, including a cooperative bank or a co-operative federation, registered under the Co-operative Societies Act, 1912, or under the laws applicable in the respective State; or Panchayat or local authority Corporate Insurance Executive As per Regulation 2(g) of the Insurance Regulatory and Development Authority (Licensing of Corporate Agents) Regulations, 2002, a "Corporate Insurance Advisor" in case of a company or a partnership firm means any director or a partner or one or more of its officers/employees so designated by it, and, in case of any other person, the chief executive (by any name called) or any of the employee(s) designated by him who have the requisite knowledge & training & have passed the exam as required under Section 42 of the Insurance Act, 1938 Brokers As per Regulation 2(1)(i) of Insurance Regulatory and Development Authority (Insurance Brokers) Regulations, 2002, "Insurance brokers" means a person who for a remuneration arranges insurance contracts with insurance/ reinsurance companies on behalf of clients and to whom a license has been granted by the Authority under Regulation 11 of the said Regulations to act as an insurance broker Ilu, r!, 'n l u Prepared by BSLI 4

There is a thin line between a customer complaint and an inquiry/request. 'Inquiry' is defined as any communication from a customer for the primary purpose of requesting for information. 'Request' is any communication from a customer soliciting a change/ modification in the policy. rj& 'Complaint' Is a communication or expression of dissatisfaction May be received either verbally or in writing Expresses a grievance from or on behalf of a customer Could be against any business practice followed by the Company or sales conduct of its agents/representatives/insurance intermediaries Is reviewed and dealt with at least one level 'higher' than the level which routinely handles and makes operational decisions about the subject matter of a complaint Can encompass anything that does not fall in either Inquiry or Request 'Complaint' versus 'Inquiry'/'Request' A 'complaint' needs to be clearly differentiated from 'inquirv'/'request'. Not every contact by a customer/ policyholder questioning an action of the Company will constitute a complaint. Differentiating a complaint from an inquiry/request involves a reasonable application of judgment. The distinguishing factor should be the tone of the communication and it reasonable interpretation of it. If the tone is critical and the customer sounds unhappy or displeased about something, the communication should be treated as a'complaint'. A complaint includes allegations of some form of mis-selling, non-delivery of the policy, churning/twisting, failure to properly advise, misrepresentation or unsuitability of the product, delays in processing any client request like address change/premium payment/change in policy features, etc. or, The various types of complaints are - 1. Reportable complaints 2. Multiple complaints 3. Creeping complaints ;Ilarclt 2010 Prepared by BSI.I I crsiotr ri /

BSLI Grievances Redressal I'olicv 3. 'Creeping complaint' Means a complaint repeatedly reported by the same complainant and where the primary issue remains unchanged Complaints re-lodged by the same complainant for a matter that has been resolved and closed can also be termed as a creeping complaint I'hese complaints are to be reported only once in the complaints database As, COUftA 7'S CAN U R.'DRDID AT W 1. Call Centre 2. Customer can call at 1-800-270-7000 between 9:00am to 9:00pm (Monday to Friday) and register their complaints. The call centre executive are also trained to resolve complaints over the phone by themselves 3. Website 4. BSLI website www.birlasunlife.com provides an option to the customer to log his Grievance on the internet 5. Branch 6. BSLI has 600 plus branches spread across pan India. The customer can visit and register his complaint at any of these branches 7. Advisor 8. Customer gives his complaint to his servicing Advisor for resolution 9. Corporate Agents 10. Customer registers his complaint with his Corporate Agent for resolution 11. Regulatory Bodies (Ombudsman/ IRDA) 12. In-case if the customer does not receive a satisfactory or a timely response from BSLI; customer has the option to report his complaint with the Regulators The above list is only illustrative and not comprehensive MODEOF R TS 3 Letters. 3 Emails, 3 Telephonic Calls 3 Facsimile (Fax) 3 Walk-ins 11arch 20/0 I *ersian / Prepared by BSLI

SCOPE, OF GRIEVANCE REDR I Ic 1) Complaints that would be required to be immediately reported to Compliance are as follows: Complaints pertaining to the sales conduct of agents, brokers and other sales intermediaries such as - o Misselling o Misrepresentation o Rebating o Misappropriation of funds o Fraud o Forgery o Lack of service o Theft o Commission schemes/sharing o Fictitious policies Employee fraud Vendor fraud Administration, control, coordination and reporting of customer complaints received through Regulatory agencies Allegations of financial irregularities by any person who has a responsibility within the Company and that involves money, credit or any other property of the Company or its clients Any complaint where there is a stated or implied threat of litigation Any other matter as may be defined by Compliance from time to time 1`, 2) Compliance will also be responsible for the following: Ensuring the recording & maintenance of the above complaints Reporting of the above complaints to the Company's Management (Audit Committee/Regulatory Committee) and the JV partner Sun Life Maintenance of & responding to IRDA inquiries requesting information on brokers/sales practices Statistical customer complaint analysis Please Note: 1) Compliance function should be sent a copy of all complaints involving any sales intermediary (like Agent, Broker, etc.) as well as an employee 2) The BSLI Compliance team investigates fraud and irregularities by any associate, agent or independent broker that falls within the above points Alarch 2(1I0 Prepared by BSLI l'er.vion r^ I

Complaints which are handled by Customer Service are primarily where the customer has expressed his dissatisfaction towards the services provided by BSLI Listed are a few complaints which are received by Customer Service (below is not an exhaustive list). Changes in not affected in the policy contract Policy contract not received Error in policy contract Surrender amount not received Revival of policy not affected Nomination not affected TT'T`LbS INVOLVED Resolution of complaints requires involvement of each function, branch and corporate agent to support with investigations & follow-ups for complaints received against them and provide satisfactory and timely resolution to the customer Resolution of the complaints are informed to the customer by means of written (letter or e- mail) Alarch 1010 Prepared by BSLI I "erstoo r / 9

SINCIFIC GUlDIEUNES 1) Media In the event or any probability of a complaint being reported in the media, the FCC or the Functional I lead (Marketing & Communication) as well as Compliance should be informed by the concerned FCC/person within 1 day 2) Complaints to Senior Company Officials Complaints alleging theft and complaints directly addressed to the senior company officials have to be directly sent to the Compliance Function The Compliance Function would decide on the appropriate course of action i.e. either an investigation or handing over the responsibility of resolving the complaint to the respective function 0., I 3) Market Conduct issues Complaints alleging theft, fraud or any other type of market misconduct should be investigated from a market conduct perspective and under utmost confidentiality Such complaints should be intimated to Compliance Function within 1 day of receiving the same Compliance Function shall ensure that the alleged misconduct of IA/CA/ Broker is investigated fully through the concerned function 4) Regulatory/Forum complaints Complaints received from regulatory/ statutory authority(ies) or from any media/ advertising/ policyholder forums should be forwarded to Compliance within one working day of receiving the same, as given under the 'Workflow of Complaints' mentioned above. 5) Policyholder Grievance Redressal Committee (PGRC) l'grc is a Committee (chaired by an independent consultant) formed to address the grievances of policyholders in the following scenarios: o Misselling/ Misrepresentation o Lapse in BSLI process(es) o Out of Free Look Cases o Alleged fraud/ forgery/misappropriation / rebating complaints on a case to case basis o Anv other case at the discretion of Compliance Please refer to the latest version of the PGRC Process Note for more details Alurch 21110 Prepared by BSLI /0 1 'ersion '^ /

6) Policyholder's Protection Committee (I'PC) As per Corporate Governance Guidelines, dated 05th August 2009, issued by the Insurance Regulatory and Development Authority [IRDA] constitution of "Policyholders' Protection Committee" (PI'C) is mandatory. Hence, BSI.I has constituted the PPC vide the Secretarial Department's PPC Charter. The Compliance team may contribute to the Agenda of the 1'PC meetings as & when required. Similarly, the Compliance team will also have access to the PPC minutes. REVIEW OF GRIEVANCE RFURR AL MUCY The review of the Grievance Redressal policy will be conducted: Atleast annually As & when necessitated due to requirements under any regulatory/ governmental authority or JV partners or BSLI Management. OTHER REMEAIEAE ARSE AVAILAItLE UNDER THE LAW 1) Redressal of Public Grievances Rules, 1998 : Insurance Ombudsman Every complainant has the right to complain/appeal against any recommendation/ resolution of BSLI to a higher external authority hereinafter referred to as the 'ombudsman'. Any person who has a grievance against an insurer may himself or through his legal heirs make a complaint in writing to the Ombudsman within whose jurisdiction the branch or office of the insurer complained against is located or to the Ombudsman within whose jurisdiction the complainant resides, at the option of the complainant. Activities of the Ombudsman are governed by the Redressal of Public Grievances Rules, 1998 and modifications made thereto from time to time. A list of Offices of Insurance Ombudsman, as specified by the Governing Body of Insurance Council (GBIC) in December 2009 attached herewith as Annexure 2. No complaint to the Ombudsman shall lie unless: The complainant had before making a complaint to the Ombudsman made a written representation to the insurer named in the complaint and the insurer had: o Rejected the complaint, or o Complainant had not received any reply within one month after the insurer concerned received his representation; or o The complainant is not satisfied with the reply given to him by the insurer The complaint is made not later than one year after the Insurer had rejected the representation or sent his final reply on the representation of the complainant; I Larch 2010 Prepared by BSLI I I I 'rrsiot :11

The complaint is not on the same subject matter for which any proceedings before any Court or Consumer Forum or Arbitrator is pending or was so earlier. The Ombudsman has the power to hear the following type of complaints: 1) Any partial/ total repudiation of claims by an insurer 2) Dispute pertaining to the premium paid/ payable in terms of the policy 3) Disputes concerning the legal construction of polities in claims related cases 4) Delay in claim settlement 5) Non- issuance of policy document to clients after receipt of premiums 2) The Consumer Protection Act, 1986 The Consumer Protection Act, 1986, is also applicable to the insurance sector. A consumer or any beneficiary of insurance can file a 'complaint' under The Consumer Protection Act, 1986, in case the service provided to him by the insurance advisor/ corporate agents/broker/ insurer suffers from deficiencies in any respect. Consumer Disputes Redressal Agencies: 1) District Forum: Established by the respective State Government in each district of the State Jurisdiction: complaints where value of services and compensation, if any, claimed does not exceed rupees twenty lakhs 2) State Commission: Established in each state Jurisdiction: o Complaints where value of services and compensation, if any, claimed exceeds rupees twenty lakhs but does not exceed rupees one crore; o Appeals against the orders of any District Forum within the State; and o Where it appears to the State Commission that any District Forum within the State has exercised its jurisdiction illegally or with material irregularity in any consumer dispute which is pending or has been decided by that District Forum 3) National Commission: Established at the national level Jurisdiction: o Complaints where value of services and compensation, if any, claimed exceeds rupees one crore; o Appeals against the orders of any State Commission o Where it appears to the National Commission that any State Commission has exercised its jurisdiction illegally or with material irregularity in any consumer dispute which is pending or has been decided by that State Commission Please Note: All appeals against the orders of the National Commission to be filed with the Supreme Court I/arch 20/0 Prepared by BS1.1 12 'crsion 71 /

BSLI Grievances Redress al Policy The client or his legal heirs need to follow the hierarchy of escalations for complaints as given below: Consumer Disputes Redressal Agencies State Commission March 2010 I'cr.ciun --/ Prepared by BSLI 13

BSLI Grievances Redressal I'olicv LAT NDU Any Complaint received by BSLI follows an escalation level matrix if not resolved as per the defined Turn-Around-Time. The Matrix is designed to escalate complaints uptil the Functional Head. Levels Level 1 Level 2 Level 3 Level 4 Responsibility Team Leader Asst. Mgr/Mgr Sr.Mgr Functional Head TAT Department wise Department Level 1 New Business Policy Admin Underwritin Authority concerned Level 2 Authority concerned Day 1 Asst.Mgr Day 2 Sr.Mgr Day 1 Asst.Mgr Day 2 Sr.Mgr Day I Asst.Mgrs Day 2 Sr.Mgr $_ Claims Day 1 Asst.Mgrs Day 2 Sr.Mgr Level 3 Authority concerned Level 4 Authority concerned Day 3 Chief Mana ger Da y 5 Function Head Day3 Chief Mana ger Da y 5 Function I lead _ Day 3 Chief Mana ger Da y 5 Function Head Day 3 Chief Manager Day 5 Function I lead Alarch 2010 I ersion +:1 Prepared by 13SLI 14