As the purchaser of the policy the master/group policyholder should not have authority to handle complaints because of the inherent conflict of interest. In addition, and on a practical level master/group policyholders are unlikely to be insurance professionals and are unlikely to have the requisite experience to handle insurance complaints.
However, due to the relationship with the Customers it is likely that master/group policyholders will sometimes be in initial receipt of complaints. It is therefore key that master/group policyholders know how to recognise a complaint, who to refer it to and the timescales for doing so. This should be set out in the master/group policy wording.
While master/group policyholders may sometimes receive complaints the Customer documentation should not identify the master/group policyholder as the first port of call for making complaints. Customers should be given the contact details of the managing agent or their coverholder or delegated claims administrator for reporting complaints.
Managing agents should treat complaints under master/group policies in the same way as all other complaints including monitoring numbers, compliance with timescales and performing root cause analysis. It would also be good practice to compare complaints under master/group policies to complaints from other distribution methods for the same product(s).
In some instances the master/group policyholder itself will be an eligible complainant and any complaints made by them will need to be handled accordingly. In some cases it may be necessary to determine whether the master/group policyholder is complaining on their own behalf or on behalf of a customer. Where they are complaining on behalf of a customer managing agents should handle the complaint in the same way as any other complaint received via a representative.