Customer complaint Management Policy

CUSTOMER COMPLAINT MANAGEMENT

POLICY (VERSION 1.0)

November 2022

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Document control

Policy Name Customer complaint Management Policy

Prepared by Resource Mobilization and Branch Banking Directorate

Approved by Chairman, Board of Directors

Signature of approver

Date of approval

Distribution list All functional units

Review schedule As required

Revision History

Reference
Date Revision Number Change
Section

Oct ......2022 Initial document Complete Whole section

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Table of Contents
Document control.................................................................................................................................. 1
Revision History..................................................................................................................................... 2
PREAMBLE............................................................................................................................................. 5
1 CORE STRATEGY ELEMENTS.........................................................................................................6
1.1 Vision....................................................................................................................................... 6
1.2 Mission.................................................................................................................................... 6
1.3 Core Values..............................................................................................................................6
1.3.1 Team work....................................................................................................................... 6
1.3.2 Integrity............................................................................................................................6
1.3.3 Innovation........................................................................................................................6
1.3.4 Responsiveness............................................................................................................... 6
2 SHORT TITLE.................................................................................................................................. 6
3 DEFINITION OF TERMS AND CONCEPTS.......................................................................................7
3.1 Definition of terms.................................................................................................................. 7
3.2 ACRONYMS............................................................................................................................. 8
4 PURPOSE OF THE POLICY............................................................................................................. 9
5 SCOPE OF THE POLICY.................................................................................................................. 9
6 GOVERNING RULES....................................................................................................................... 9
7 GENERAL PRINCIPLES..................................................................................................................10
8 GENERAL GUIDING PRINCIPLES AND COMPLAINT MANAGEMENT SYSTEM............................11
8.1 General Guiding principles..................................................................................................... 11
8.1.1 Facilitate complaints.......................................................................................................11
8.1.2 Respond to complaints.................................................................................................. 12
8.1.3 Manage the parties to a Complaint ..............................................................................14
8.2 Complaint Management System...........................................................................................15
8.2.1 Receipt of complaints.....................................................................................................15
8.2.2 Acknowledgement of complaints..................................................................................15
8.2.3 Initial assessment and addressing of complaints..........................................................15
8.2.4 Providing reasons for decisions.....................................................................................16
8.3 Alternative avenues for dealing with complaints.................................................................17
9 ACCOUNTABILITY AND LEARNING............................................................................................. 18
9.1 Analysis and evaluation of complaints.................................................................................18

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9.2 Monitoring of CCM ............................................................................................................... 18

9.3 Continual improvement........................................................................................................ 18
10 DUTIES AND RESPONSIBILITIES..................................................................................................19
10.1 Board of Directors..............................................................................................................19
10.2 The CEO.............................................................................................................................. 19
10.3 Chief Resource Mobilization and Digital Banking Officer.................................................19
10.4 Resource Mobilization and Branch Banking Directorate.................................................20
11 Exception /deviation....................................................................................................................20
12 EFFECTIVE DATE...........................................................................................................................20

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PREAMBLE

Whereas, the smooth functioning of the Customer complaint management enhances the
satisfaction of Wegagen Bank’s clients by enhancing the problem-solving capacity of the
Bank;
Whereas, maintaining effective and efficient communication enables the Bank to improve
the monitoring of its performance and thereby enhancing the realization of its vision, mission
and values;
Whereas, aligning the Center’s tasks with the objectives and strategies of the Bank is critical
to the improvement of the customers’ experience;
Whereas, it is necessary to put in place a clear guidance and direction regarding Customer
complaint management ;
Whereas, an operational procedure is crucial for the clarification of the duties and
responsibilities of parties involved in contacting and serving customers and for the effective
and efficient performance of their tasks;
Whereas, complying with the country’s law, regulations, NBE Directives and other regulators
regarding customer complaint management
Whereas, it is crucial to provide customer complaint management guidance for the Bank on
aligning it to the current Organizational Structure and corporate strategy;
Now, therefore, the Board, hereby issued this customer complaint management Policy
with due observance to the Bank’s Vision, Mission, Values and Objectives.

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1 CORE STRATEGY ELEMENTS

1.1 Vision
Aspiring to be the champion of excellence in banking business in Ethiopia

1.2 Mission
Maximize stakeholders’ value by providing diversified banking services through
Competent and motivated employees and up-to-date technology.

1.3 Core Values

1.3.1 Team work

I. Collaborate and work collectively to meet our common goals;

II. Promote and support a diverse, yet unified team.

1.3.2 Integrity
I. Do the right thing, even when no one is watching;
II. Keep your word and honor your commitment;
III. Maintain confidentiality and privacy of customers.

1.3.3 Innovation
I. Adapt and respond rapidly to changes;
II. Encourage creativity and new ideas.

1.3.4 Responsiveness
Provide prompt and convenient customer services

2 SHORT TITLE

This policy may be cited as “Customer complaint management policy”.

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3 DEFINITION OF TERMS AND CONCEPTS

3.1 Definition of terms

Unless the contextual meaning of the term assumes a different meaning otherwise, in this
Policy document:
i. Customer means any natural person or legal entity that purchases or uses financial
products or services offered or provided by the bank or used financial products or
services offered or provided by a the bank in the past or unambiguously attempts to
make a purchase or use of financial products or services offered or provided by the
bank;
ii. Agent means who has the responsibility of handling inbound and outbound calls and
responding to any kind of request which comes from the internal or external
customers of the Bank via telephone, e-mail, SMS and/or other means of
communication;
iii. Complaint means content of a call that expresses dissatisfaction in the process of
using the Bank’s products and services;
iv. CCM means a central point from which all customers enquiries and complaints are
managed;
v. Escalation means the transfer of a case to the pertinent sub-process for further
solution or support;
vi. First line support means the process of receiving, identifying and analyzing requests
and giving a proper solution to them upon the first time of contact;
vii. Inbound call means a call that the CCM receives through telephone number from
customers, employees and the society at large;

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viii.Incident means any system-related abnormality that affects the smooth functioning of
a system or service. Calls that report incidents express disruption of services or
creation of inconvenience;
ix. Outbound call means any call that is initiated by the CCM is made through various
electronic media to employees, Agents and customers of the Bank;
x. Procedure means the CCM Operations Procedure or its defining and prescriptive
content;
xi. Recommendation means ssuggestion of an idea, action, etc. as a good one;
xii. Suggestion: means an idea or proposal put forward by for consideration;
xiii. Complaint management system means all policies, procedures, practices, staff,
hardware and software used by us in the management of complaints;
xiv. Dispute means an unresolved complaint escalated either within or outside of our
organization;
xv. Grievance means a clear, formal written statement by an individual staff member
about another staff member or a work related problem;
xvi. Policy means a statement of instruction that sets out how we should fulfill our vision,
mission and goals;
xvii.Feedback means opinions, comments and expressions of interest or concern, made
directly or indirectly, explicitly or implicitly, to or about us, about our services,
products and/or complaint-handling where a response is not explicitly or implicitly
expected or legally required; and
xviii. Public interest disclosure means a disclosure about improper conduct by a public
official in the bank that meets the requirements of the Public Interest Disclosure Act.

3.2 ACRONYMS
i. The Bank - Wegagen Bank;

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ii. BOD - Board of directors of Wegagen Bank;

iii. CEO - Chief Executive Officer;
iv. NBE - National Bank of Ethiopia;
v. SMS - Short Message Service (text message);
vi. E-mail - Electronic Mail ;
vii. CCM - Customer Complaint Management;
viii. QCM - Quality Call Monitoring;
ix. QMM - Quality Mail Monitoring;
x. SDT - Service Delivery Time; and
xi. ATM - Automated Teller Machine.

4 PURPOSE OF THE POLICY

The purpose of this policy is to enable and facilitate a fair and transparent handling of
customer complaints. The primary objectives are to:
i. Ensure the standardization and quality of support services given by the CCM;
ii. Provide a single source of reference to CCM performers;
iii. Facilitate the provision of guidance and support to all employees under the CCM.

5 SCOPE OF THE POLICY

The policy encompasses customer complaints and Call Centre receiving and handling
activities, from receipt through various channels to resolution mechanisms.
Staff grievance, code of conduct complaints and public interest disclosures are dealt with
through separate mechanisms.

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6 GOVERNING RULES

In Customer complaint management complying the following internal and external regulatory
directives and instruments are obligatory.
i. Laws and regulation of the country including AML & CFT, ECX;
ii. National Bank of Ethiopia directives; and
iii. The Bank’s Policies.

7 GENERAL PRINCIPLES

This Policy is designed on the following general principles:

i. The bank has strong commitment to ensure professionalism in our work by keeping
confidentiality, respecting and responsibility for our work;
ii. The Bank will be socially responsible by committing ourselves for the public we serve;
iii. The Bank will maintain integrity by doing the right thing at all cost every time;
iv. The Bank is committed to provide prompt and convenient customer service with high
level of responsiveness;
v. The Bank will adopt and rapidly respond to changes with initiatives and innovative
ideas;
vi. The Bank is committed to promote teamwork and support a diverse, yet unified team;
vii. The Bank will ensure customer satisfaction;
viii. The Bank enhances maker-checker principle;
ix. The Bank enhances efficiency and cost effectiveness;
x. The Bank will ensure customer impartiality and transparency of service;
xi. The Bank will ensure that our systems to manage every aspect of our work are easily
understood and accessible to everyone, particularly people who may require
assistance; and

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xii. The Bank will ensure the implementation of best practice in all our work in the bank.

8 GENERAL GUIDING PRINCIPLES AND COMPLAINT MANAGEMENT

SYSTEM

8.1 General Guiding principles

8.1.1 Facilitate complaints

i. People focus
a. We are committed to seeking and receiving feedback and complaints about
our services, systems, practices, procedures, products and complaint-
handling;
b. Any concerns raised in feedback or complaints will be dealt with within a
reasonable time frame;
c. We will ask people what outcome they seek from a complaint as part of our
complaints processes. We will actively involve complainants in the
complaints process as far as practicable and appropriate in the
circumstances;
d. People making complaints will be:
I. provided with information about our complaint-handling process;
II. provided with multiple and accessible ways to make complaints;
III. listened to, treated with respect by staff and actively involved in the
complaint process where possible and appropriate; and
IV. Provided with reasons for our decision/s and any options for redress or
review.

ii. No detriment to people making complaints

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We will take all reasonable steps to ensure that people making complaints are not
adversely affected because a complaint has been made by them or on their behal f.

iii. Anonymous complaints

We accept anonymous complaints and will carry out an investigation of the issues
raised if there is enough information provided.

iv. Visibility and transparency

We will ensure that information about how and where complaints may be made to or
about us is well publicized.

v. Accessibility

a) We will ensure that our systems to manage complaints are easily understood
and accessible to everyone, particularly people who may require assistance;
b) If a person prefers or needs another person or organization to assist or
represent them in the making and/ or resolution of their complaint, we will
communicate with them through their representative if this is their wish; and
c) Anyone may represent a person wishing to make a complaint with their
consent (e.g. advocate, family member, legal or community representative,
member of Parliament, another organization).

vi. No charge

Complaining to the Bank is free.

8.1.2 Respond to complaints

i. Early resolution

Where possible, complaints will be resolved at first contact.

ii. Responsiveness

a. We will promptly acknowledge receipt of complaints;

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b. We will assess and prioritize complaints in accordance with the urgency and/or
seriousness of the issues raised. If a matter concerns an immediate risk to safety
or security the response will be immediate and will be escalated appropriately;
c. We are committed to managing people’s expectations, and will inform them as
soon as possible, of the following:
I. The complaints process;
II. The expected time frames for our actions;
III. The progress of the complaint and reasons for any delay;
IV. Their likely involvement in the process; and
V. The possible or likely outcome of their complaint.
d. We will advise people as soon as possible when we are unable to deal with any
part of their complaint and provide advice about where such issues and/or
complaints may be directed (if known and appropriate);
e. We will also advise people as soon as possible when we are unable to meet our
time frames for responding to their complaint and the reason for our delay.
iii. Objectivity and fairness
a. We will address each complaint with integrity and in an equitable, objective and
unbiased manner;
b. Conflicts of interests, whether actual or perceived, will be managed responsibly;
and
c. In particular, internal reviews of how a complaint was managed will be
conducted by a person other than the original decision maker.

iv. Responding flexibly

a. Our staffs are empowered to resolve complaints promptly and formally as
possible;

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b. We will adopt flexible approaches to service delivery and problem solving to

enhance accessibility for people making complaints and/or their
representatives;
c. We will assess each complaint on its merits and involve people making
complaints and/or their representative in the process as far as possible.
v. Confidentiality
a. We will protect the identity of people making complaints where this is practical
and appropriate; and
b. Personal information that identifies individuals will only be disclosed or used by
the bank as permitted under relevant privacy laws and secrecy provisions and
subject to ethical obligations.

8.1.3 Manage the parties to a Complaint

i. Complaints involving multiple agencies
a. Where a complaint involves multiple organizations, we will work with the
other organization/s where possible; to ensure that communication with the
person making a complaint and/or their representative is clear and
coordinated;
b. Subject to privacy and confidentiality considerations, communication and
information sharing between the parties will also be organized to facilitate a
timely response to the complaint;
c. Where a complaint involves multiple areas within our organization,
responsibility for communicating with the person making the complaint
and/or their representative will also be coordinated;
d. Where our services are contracted out, we expect contracted service
providers to have an accessible and comprehensive complaint management
system. We take complaints not only about the actions of our staff but also
the actions of service providers.
ii. Complaints involving multiple parties
When similar complaints are made by related parties we prefer to communicate
with a single representative of the group.
iii. Empowerment of staff

a. All staff managing complaints are empowered to implement our complaint

management system as relevant to their role and responsibilities;
b. Staffs are encouraged to provide feedback on the effectiveness and
efficiency of all aspects of our complaint management system.
iv. Managing unreasonable conduct by people making complaints

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a. We are committed to being accessible and responsive to all people who

approach us with feedback or Complaints. At the same time our success
depends on:
I. Our ability to do our work and perform our functions in the most
effective and efficient way possible;
II. The health, safety and security of our staff, and
III. Our ability to allocate our resources fairly across all the complaints we
receive.
b. When people behave unreasonably in their dealings with us, their conduct
can significantly affect the progress and efficiency of our work.
c. As a result, we will take proactive and decisive action to manage any conduct
that negatively and unreasonably affects us and will support our staff to do
the same in accordance with this policy.

8.2 Complaint Management System

i. When responding to complaints, staff should act in accordance with our complaint
handling policy and procedures as well as any other internal documents providing
guidance on the management of complaints;
ii. Staff should also consider any relevant legislation and/or regulations when
responding to complaints and feedback; and
iii. There are five key stages in our complaint management system:

8.2.1 Receipt of complaints

i. We will record each complaint and its supporting information.
ii. The record of the complaint will identify:
a. The contact information of the person making a complaint;
b. Issues raised by the person making a complaint;
c. The outcome/s sought;
d. Any other information required to properly respond to the matter, and
e. Any additional support the person making a complaint requires.

8.2.2 Acknowledgement of complaints

i. We will acknowledge receipt of each complaint promptly, and preferably within

(specify number) of working days; and
ii. Consideration will be given to the most appropriate medium for communicating
with the person making a complaint, taking into account our business needs and
their expressed views.

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8.2.3 Initial assessment and addressing of complaints

i. Initial assessment

a. After acknowledging receipt of the complaint, we will confirm whether the

issue/s raised in the complaint is/are within our control;
b. We will also consider the outcome/s sought by the person making a complaint
and, where there is more than one issue raised, determine whether each issue
needs to be separately addressed;
c. If a matter is clearly not within our control, a statement to this effect with any
suggested alternative avenues for complaint may be combined with
acknowledgement;
d. When determining how a complaint will be managed, we will assess the issues
raised against the following criteria:
I. Severity
II. Complexity
III. Health and safety implications
IV. Impact on the individual, the general public and/or us
V. Potential to escalate, and
VI. Whether another organization or area within our own organization needs to
be involved in the complaint resolution.
ii. Addressing complaints
After assessing the complaint, we will consider how to address the issue/s rose. This
may include:
a. Working with the person making the complaint to see how the issues can be
appropriately addressed;
b. Making inquiries with the person or area the subject of the complaint; and/or
c. Conducting an investigation into the issues raised in the complaint; and
d. We will actively communicate our progress to the person making the complaint,
particularly whereof the resolution of their complaint, including giving them an
opportunity to comment on any proposed outcome that varies from the
outcome they are seeking.

8.2.4 Providing reasons for decisions

i. Following consideration of the complaint and any investigation into the issues
raised, we will contact the person making the complaint and advise them:

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a. The outcome of the complaint and any action that was taken arising out of
the complaint;
b. The reasons for any decisions that have been made;
c. Any remedy or resolution that has been offered; and
d. Any options for review that may be available to the complainant, such as an
internal review, external review or appeal.
ii. If in the course of investigation, we make any adverse findings about a particular
individual, we will consider any applicable privacy obligations or legislation
before sharing our findings with the person making the complaint and/or their
representative.
10.2.5 Closing the complaint, record keeping, redress and review
i. At the time of closing the complaint, we will record the following:
a. Steps taken to address the complaint;
b. The outcome of the complaint; and
c. Any undertakings or follow up action required.
ii. We will ensure that outcomes are properly implemented, monitored and
reported to the complaint handling manager and/or senior management.

8.3 Alternative avenues for dealing with complaints

i. We will inform people who make complaints to or about us about any
internal or external review options available to them (including any
relevant Ombudsman or oversight bodies). The three levels of complaint
handling:

a. Frontline complaint handling and early resolution of complaints;

b. Back office (Internal) reviews of complaints and/or complaint handling
(may include further investigation of issues raised and use of Alternative
Dispute Resolution options); and
c. External reviews of complaints and/or complaint handling

ii. Where possible, complaints will be resolved by staff at the first level, the
frontline. Staff will be adequately equipped to respond to complaints, including
being given appropriate authority, training and supervision;
iii. Where early resolution of a complaint is not possible, however, due to the
complexity of the issues raised, dissatisfaction with the complaint outcome or
how the complaint was dealt with, we may decide to escalate the complaint to a
more senior officer within the bank;
iv. This second level of complaint handling will provide for the following internal
mechanisms:

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a. Assessment and possible investigation of the complaint and decision/s already

made; and/or
b. Facilitated resolution (where a person not connected with the complaint
reviews the matter and attempts to find an outcome acceptable to the relevant
parties).
v. Where a person making a complaint is dissatisfied with the outcome of the bank
review of their complaint, they may seek an external review of our decision (by
the Ombudsman for example).

9 ACCOUNTABILITY AND LEARNING

9.1 Analysis and evaluation of complaints

i. We will ensure that complaints are recorded in a systematic way so that
information can be easily retrieved for reporting and analysis;
ii. Regular reports will be run on:
a. The number of complaints received;
b. The outcome of complaints, including matters resolved at the frontline;
c. Issues arising from complaints;
d. Systemic issues identified; and
e. The number of requests we receive for internal and/or external review of our
complaint handling.
iii. Regular analysis of these reports will be undertaken to monitor trends, measure the
quality of our customer service and make improvements;
iv. Both reports and their analysis will be provided to the chief executive officer and
senior management for review.

9.2 Monitoring of CCM

We will continually monitor our CCM to:
i. Ensure its suitability for responding to and resolving complaints, and
ii. Identify and correct deficiencies in the operation of the system.
Monitoring may include the use of audits, complainant satisfaction surveys and online
listening tools and alerts.

9.3 Continual improvement

We are committed to improving the effectiveness and efficiency of our complaint
management system. To this end, the chief executive and senior executives will:
i. Maintain open and regular support for the making and appropriate resolution of
complaints;

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ii. Implement best practices in complaint handling;

iii. Recognize and reward exemplary complaint handling by staff;
iv. Regularly review the complaint management system and complaints data;, and
v. Implement appropriate system changes arising out of analysis of complaints data
and continual monitoring of the system.

10 DUTIES AND RESPONSIBILITIES

10.1 Board of Directors

i. Approve the CCM Handling Policy of the Bank;
ii. Delegate the CEO for managing CCM in the Bank;
iii. Oversee that CCM handling activities are performed in line with the NBE
requirements and other relevant rules, regulations and requirements; and
iv. Review reports of the management of the Bank periodically and ensure that CCM
Handling Policies are appropriately implemented.

10.2The CEO
i. Oversee that CCM handled by all staffs of the Bank;
ii. Oversee the efficiency and effectiveness of the CCM handling processes in the Bank;
iii. Oversee that the Bank’s CCM handling activities adhere to the Bank’s policies,
procedures and NBE Directives;
iv. Periodically receive reports about the performance of the CCM handling activities;
and
v. Report about the performance of the CCM handling activities of the Bank to the
BODs, as and when required.

10.3Chief Resource Mobilization and Digital Banking Officer

i. Ensure the alignment of the CCM activities with those of other divisions;
ii. Oversee the effective implementation of this Procedure; Ensure that the activities
of the CCM support the Bank’s business objectives and strategies; and

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iii. Oversee that the Bank’s CCM handling activities adhere to the Bank’s policies,
procedures and NBE Directives.

10.4 Resource Mobilization and Branch Banking Directorate

i. Approve the quality assurance checklist of the CCM;
ii. Ensure the proper implementation of the overall strategic matters of the CCM
Center;
iii. Oversee the overall service delivery process and operational issues of the CCM take
appropriate actions when deemed necessary;
iv. Prepare the business plan, scorecard and budget of the CCM facilitate their
approval; and ensure the proper allocation of the budget required;
v. Ensure that appropriate actions are taken based reports; and
vi. Initiate the review of this Procedure.

11 Exception /deviation

i. The Board has the authority to deal with deviations from this Policy.
ii. The CEO/Executive Management may deal with exceptions from the policy and
deviations from the procedure.

12 EFFECTIVE DATE

This Policy shall take effect from the date of approval by the Board of Directors.

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