Complainant – a person intending to conclude an insurance or reinsurance contract, the policyholder, the insured person, or a person entitled to claim insurance compensation under a concluded insurance contract, and the reinsurance policyholder.
Company – the limited liability company “Fortsuno”.
Complaint – a statement expressing dissatisfaction with the distribution of insurance or reinsurance carried out by the Company or an insurance ancillary service intermediary registered in the Company’s ancillary service intermediary register. A statement is not considered a complaint under these regulations if it lacks identifying details: for natural persons – name, surname, and identifiable information; for legal entities – name and registration number.
Employee – an individual directly involved in the distribution of insurance or reinsurance for the Company or an employee of a registered insurance ancillary service intermediary, against whom a Complaint has been submitted.
Complaint Handler – a person appointed by the Company’s Board, responsible at the management level for overseeing the Complaint handling process, including fact-checking, monitoring process efficiency, preventing conflicts of interest, and ensuring compliance with this document.
1.1. This document and any amendments are approved by the Company’s Board.
1.2. The Company reviews only complaints regarding the distribution of insurance conducted by its Employees.
1.3. The Company informs all persons involved in complaint handling of this document, which is available to all Employees directly involved in insurance and reinsurance distribution.
1.4. At all business locations and on all websites, the Company ensures clear, accurate, up-to-date, and freely accessible information about:
1.4.1. Required information to be included in a Complaint (Section 2.4);
1.4.2. Complaint handling is free of charge;
1.4.3. Complaints should be addressed to the person listed in Section 2.2;
1.4.4. Complaints can be submitted as outlined in Section 2.3;
1.4.5. The Complaint will be reviewed by the person named in Section 2.2;
1.4.6. The Employee in question will not be involved in handling the Complaint (Section 4.9);
1.4.7. A response to the Complaint will be provided within the deadline specified in Section 4.2;
1.4.8. The Company’s supervisory authority is the Bank of Latvia, address: K. Valdemāra iela 2A, Rīga, LV-1050, email: info@bank.lv, website: www.bank.lv;
1.4.9. The Complainant may also submit the Complaint to the institutions referred to in Section 2.6.
1.5. If the Complaint concerns another market participant outside the scope of the Company’s competence as defined in Section 1.2, the Company shall forward the Complaint to the relevant market participant within seven days from the date of receipt and inform the Complainant accordingly.
1.6. The Company ensures that the Complaint Handler is familiar with this document and that it is accessible to all employees involved in the distribution of insurance or reinsurance within the Company’s office and electronic systems.
2.1. Any person is entitled to submit a Complaint to the Company.
2.2. The Complaint Handler is Gints Gžibovskis, to whom all Complaints must be addressed.
2.3. Complaints may be submitted electronically by email to info@fortsuno.lv or in person.
2.4. A Complaint must include at least the following information:
2.4.1. For a natural person – full name and identifiable information; for a legal entity – name and registration number;
2.4.2. The specific Employee whose conduct is the subject of the Complaint;
2.4.3. Justification of the dissatisfaction, providing a detailed account of the factual circumstances and motivation for the Complaint, with supporting documents attached;
2.4.4. For written Complaints, a handwritten signature of the Complainant (natural person) or of the legal representative of the legal entity, including name, surname, and position. If signed by an authorized representative, the original power of attorney must be attached.
2.5. The Complainant may request compensation for damages directly and causally resulting from the Employee’s intentional, maliciously unlawful behavior or gross negligence.
2.6. In the event of a dispute, the Complainant may also submit the Complaint to the Ombudsman established by the Latvian Insurance Brokers Association (information available at www.brokers.lv) or to the supervisory authority – the Bank of Latvia.
3.1. The Complaint Handler is obligated to accept any Complaint that is properly formatted according to the requirements of this document. If a Complaint is submitted orally, the Complaint Handler may request the Complainant to submit it in writing or may document it in writing and request the Complainant to sign it.
3.2. Only Complaints that meet the requirements of this document shall be reviewed. A statement that lacks identifying information for a natural or legal person shall not be considered a Complaint.
3.3. The Company and the Complaint Handler may request additional information regarding the circumstances referred to in the Complaint, if necessary.
3.4. Upon request by the Complainant, the Company shall provide written information on the status of the Complaint process, either in physical or electronic form, depending on the method of the request.
3.5. If a Complaint is received by a registered insurance ancillary service intermediary, they must forward it to the Company within seven days.
3.6. The Company ensures the protection of the Complainant’s personal data and information in accordance with the General Data Protection Regulation (GDPR) and the Company’s information security procedures.
4.1. Within the scope of their competence and legal authority, the Complaint Handler must verify all evidence and information related to the Complaint and shall undertake at least the following actions:
4.1.1. Request explanations from the Employee involved and verify the information provided;
4.1.2. If applicable, review the information held by the Company or the relevant intermediary, including documents, emails, and electronically stored information;
4.1.3. If necessary, obtain additional information from public registers and sources;
4.1.4. Request explanations or additional information from other employees of the Company or the intermediary;
4.1.5. Request information from other individuals if needed, even if they are not employees of the Company or its registered intermediaries.
4.2. The Complaint Handler must respond to the Complaint within 20 days from the date of receipt. If it is not possible to respond within this period due to objective reasons, the Complainant must be informed of the delay, with an explanation and an indication of when a response will be provided.
4.3. The response must be justified, objective, and based on all verified information and evidence. It must be written in clear and understandable language.
4.4. The response must state whether the Company agrees or disagrees with the Complaint and include justification.
4.5. If the Complaint is upheld, the response shall include whether and how compensation will be provided for any damages caused directly and causally by the conduct of the Employee.
4.6. If the Complaint is rejected, the response must include the facts, circumstances, and documents justifying the rejection.
4.7. If the Company determines that the Complaint concerns activities outside its operations or not involving an Employee, the Complainant will be informed in writing.
4.8. Responses are provided in Latvian. If the Complaint was submitted in another language, the Company may respond in that language if it does not incur additional administrative costs.
4.9. If the Complaint concerns the Complaint Handler themselves, the duties set out in this document will be fulfilled by another person appointed by the Company’s Board. If the Complaint concerns a member of the Board, that person will not participate in any decisions related to the Complaint. If the Complaint concerns the sole Board member who is also the Complaint Handler, the Board member shall appoint another person to review the Complaint, and this will be stated in the response. If the Complaint concerns the sole Board member who is also the only employee, the Complaint Handler themselves will review the Complaint, and this fact will be stated in the response.
4.10. After concluding the Complaint process and preparing the response, the Complaint Handler will analyze the root cause of the Complaint and determine the necessary measures to prevent recurrence.
5.1. The Company registers all received Complaints no later than the next business day after receipt, and registers the response on the day it is prepared. The register shall include at least:
5.1.1. Information about the Complainant (name and surname for natural persons; name and registration number for legal entities) and contact information;
5.1.2. Date of receipt;
5.1.3. Reason for the Complaint;
5.1.4. Type of insurance involved;
5.1.5. Date of response;
5.1.6. Result of the Complaint review;
5.1.7. Country where the insurance/reinsurance distribution occurred.
5.2. The Company retains Complaint records and related responses for a minimum of 10 years and 6 months from the date of the response. These may be submitted to the Financial and Capital Market Commission upon request.
6.1. The Complaint Handler prepares an annual report by March 31st of each year reviewing the previous calendar year’s Complaint process and evaluating its compliance and effectiveness. The report must include an analysis of Complaint causes and necessary corrective measures. If no Complaints were processed, this report is not required.
6.2. Within one month of receiving the report, the Company’s Board reviews and determines whether corrective measures are necessary and sets deadlines if required. The Complaint Handler monitors the implementation and reports back on completion, delays, obstacles, and recommendations.