1. Introduction

This Policy covers various aspects stipulated as per IRDAI (Protection of Policyholders’ Interests, Operations and Allied Matters of Insurers) Regulations, 2024 (‘Regulations’), on March 22, 2024, bearing F. No. IRDAI/Reg/11/205/2024, Master Circular on Protection of Interest of Policyholders dated 5th September 2024 (IRDAI/PP&GR/CIR/MISC/117/9/2024) and Master Circular on Operations and Allied Matters of Insurers dated 19th June 2024 (IRDAI/PPGR/CIR/MISC/97/06/2024). The objective of these regulatory requirements is to ensure the following:

1. Fair treatment of prospect at the stage of solicitation and sale of insurance policies.
2. The interest of policyholders is protected. 
3. Insurers, distribution channels and other regulated entities fulfil their obligations towards policyholders and have in place standard procedures and best practices in the sale and service of insurance policies. 
4. Policyholder-centric governance by insurers with emphasis on grievance redressal.

Therefore, in light of the above, this policy on Protection of Interests of Policyholders is formulated. Customer Service and Insurance Awareness being integral part in protection of policyholders’ interests, the Company has formulated a consolidated policy covering below aspects:

 

Part A - CUSTOMER SERVICE POLICY

Part B - POLICY ON INSURANCE AWARENESS

 

2. Definitions 

Following terms for the purpose of this policy shall carry the meaning as mentioned hereinbelow:

 

3. Applicability 

This policy shall be applicable to all policyholders or prospects or nominees or assignees or any beneficiaries of any insurance policy of the Company. This policy shall also govern the conduct of employees, distribution channels and other stakeholders of the Company. 

 

4. Principles 

The Company shall ensure: 

1. Prospects or the Policyholders have equitable and inclusive access to insurance products and services either directly or through the distribution channel.
2. The solicitation process is transparent and has built-in practices to enable fair and equitable treatment of the prospect or the policyholder at all points of time and provide all necessary information about the products to enable them to take informed decision about purchasing insurance policies.
3. Appropriate framework is put in place to ensure that the features, benefits along with terms and conditions of the products being sold are represented correctly and fully and that the products are not mis-stated or misrepresented to prospects or policyholders.
4. It facilitates inclusivity and accessibility of insurance cover to persons with disabilities.
5. To adopt Suitable service and process efficiency is established, including implementing technology solutions for grievance redressal.
6. Measures are taken to prevent mis-selling and unfair business practices, by building suitable conduct measures including appropriate grievance redressal framework.
7. Setting up reasonable turnaround times for various activities and services to provide timely completion and resolution; and to publish the same on the website prominently.
8. Establishment of appropriate mechanism for Insurance Awareness on an ongoing basis so as to educate prospects and policyholders about insurance products, benefits and their rights and responsibilities.
9. Establish systems and processes for expeditious settlement of claims.

 

5. Mis-Selling and Unfair Trade Practices

Following are the steps that the Company shall undertake to address mis-selling and unfair trade Practices: 

1. The Company shall adopt a framework which shall ensure that the features, benefits along with the terms and conditions of the products are represented correctly by Distribution Channels to the prospect at the time of solicitation. 
2. The Company shall ensure that the products that are being offered for sale and those that are withdrawn are published prominently on its website along with the benefits, features, applicable terms and conditions, premium, prospectus, its Unique Identification Number, benefit illustration, as applicable, and is updated regularly.
3. The Company shall ensure that each distribution channel of the Company provides a link prominently on its website, if maintained, to directly access the website of the Company, wherein products on offer are displayed. 
4. The below measures shall be taken to ensure there are no incidences of mis-selling:
   1. Training to all intermediaries at regular intervals.
   2. Creating awareness among employees and intermediaries on the consequences of mis-selling.
   3. Communications to policy holders post issuance of policies would include a statement to check the Terms and Conditions of the policy and revert in case there are any differences.
   4. Any complaint about mis-selling would be referred to the Disciplinary Committee for necessary action.

 

6. Servicing of Policyholders

1. The Company shall ensure that the prospect or the policyholders are provided with necessary information about various services and shall widely disseminate information about all the services that may be availed, along with the procedure for availing such services including the turnaround times.
2. The Company shall deliver the services requested within a reasonable time not exceeding the specified turnaround time, with speed and efficiency and establish a mechanism to obtain feedback for continuous improvements.
3. The Company in servicing of the policyholders shall ensure that all the dealings with policyholders are conducted in a manner such that it achieves the following outcomes:
   1. Policyholders are
      1. treated with fairness and impartiality;
      2. provided with clear and prompt information in relation to their policies at all times;
      3. not faced with unreasonable pressure or advice to change products or switch providers; and
      4. not barred from submitting claims or making complaints.
   2. Post-sale servicing of policyholders to be complemented with technological solutions to provide prompt and efficient services.
   3. Policyholders’ reasonable expectations are met on servicing standards.
4. The Company shall comply with the prevalent prescriptions of the Authority on Mis-selling, Unfair trade practice, fair treatment, compliance and oversight, mitigation of conflicts of interests, guidance to prospect on product suitability and suitability assessment and Unclaimed amount.
5. Company shall ensure that every policyholder of new health insurance policies, except for those with tenure of less than a year, is provided a free look period of 30 days from the date of receipt of the policy document to review the terms and conditions.
6. Company shall ensure that policyholders are clearly and explicitly informed about the availability of the free look period.
7. Company shall ensure that if a policyholder disagrees with any policy terms or conditions and has not made any claim, they have the option to return the policy for cancellation, after stating the reasons for the same.
8. In case of free look cancellation, Company shall ensure that policyholders are entitled to a refund of the premium paid, subject to deductions for a proportionate risk premium for the cover period and expenses incurred on medical examinations and stamp duty charges
9. Company shall ensure that a request for cancellation of the policy during the free look period is processed and the premium refunded within 7 days of receipt of the request.
10. The Company shall adhere to the Turnaround times (TATs) as prescribed by the Authority from time to time.

 

 

7. Cancellation of policies issued and Refund of Premium (under Retail General Insurance business and in case of Indemnity based Health Insurance Policies:

1. Company shall refund proportionate premium for unexpired policy period, if the term of policy upto one year and there is no claim (s) made during the policy period.
2. Company shall refund premium for the unexpired policy period, in respect of policies with term more than 1 year and risk coverage for such policy years has not commenced.

 

8. Prospectus of Insurance Products and Services

1. Company shall ensure that the information given to the prospect or the policyholder about the product offerings reflects a true and correct picture of the features, benefits, exclusions, risks, options, exit options, and grievance redressal in clear and simple terms.
2. Company shall ensure the development and maintenance of a prospectus for every retail insurance product and services that the Company has on offer at a particular time, including riders or add-ons, the company shall also make sure that such prospectus are available on its website.
3. Company shall ensure the following regarding the contents of the prospectus:
   1. Company shall ensure that no sale of insurance product is made without a prospectus that explains all the benefits, features, terms, and conditions of the product, and provides a benefit illustration to the prospect, wherever applicable. The benefits and features of the product shall be explained in clear and concise terms, including illustrations, and the prospectus shall include the grievance redressal policy, ensuring no misleading or false information is provided.
   2. Company shall ensure that all necessary information, including any material information about the proposed cover(s), is provided to the prospect to enable them to decide on the best cover(s).
   3. Company shall ensure that policy terms and conditions are written in simple and clear terms, avoiding jargon and coercive, unfair, or one-sided clauses.

 

9. Sales Obligations 

The company shall ensure that:

1. the policy terms and conditions are written in simple and clear terms to understand, avoid jargon and avoid coercive, unfair and one-sided clauses;
2. the insurance policies issued to the policyholders contain such minimum details as may be specified.

 

10. Privacy 

The Company values the privacy and confidentiality of its Policyholders; accordingly, it shall adhere to the following: 

1. Company shall ensure compliance with statutes and regulations on data protection and shall make sure that it maintains all private information and documents collected during solicitation or subsequently with utmost confidentiality, privacy, and protection.
2. Company shall ensure that information collected from the proposal form during solicitation or issuance of an insurance policy is not shared with any third party without the explicit consent of the policyholder, except for, statutory authorities in accordance with existing statutory laws, for the purpose of underwriting the policy or settling a claim under the policy, or as required by any other institution as authorized by the Authority.
3. Company shall ensure that no clause or condition in the proposal form allows, by default, the insurer to share the information of any policyholder with any third party.

 

11. Claims 

1. In the view to protect Policyholder’s interest with regards to aspects of claims, the Company shall adhere to the following: 
2. Company shall ensure that necessary specific documentation required to support a claim is listed in the policy document and prominently placed on their website.
3. Company shall ensure that claims registered are settled in a timely manner, not exceeding the turnaround times for settlement of claims as provided in this Policy.
4. Company shall ensure that all distribution channels comply with the specified code of conduct concerning services related to the settlement of claims.
5. Company shall ensure that policyholders and claimants are provided with necessary support and guidance for registering claims, fair treatment during claim processing, information at various stages of claim settlement, and that all necessary documents are called for at once to avoid piecemeal requests.
6. Company shall ensure that claims are settled with speed and efficiency within a reasonable time.

12. Review of the Policy

1. The PPGR&CM Committee and the Board shall review the Policy:
   1. At least once in every financial year, or 
   2. As and when the PPGR&CM and/or the Board considers it appropriate, or 
   3. As and when the underlying laws governing this Framework undergo any change.
2. Notwithstanding the foregoing, this Policy may be modified during the year by CEO and COO jointly prior to any such annual review and such modifications shall be reported to the PPGR & CM Committee for ratification. Any changes in the applicable regulatory provisions shall automatically be treated as part of this Policy.

 

Part A – CUSTOMER SERVICE POLICY

 

1. Introduction

Go Digit General Insurance Limited places utmost importance on customer service, safeguarding customer interests, and ensuring effective grievance redressal. The commitment of the Company towards customer service is unwavering and integral to its operational ethos. The Company strives to provide its policyholders with prompt, transparent, and efficient services, ensuring that their needs are met with the highest standards of professionalism and care.

The Insurance Regulatory and Development Authority of India (IRDAI), through its IRDAI (Protection of Policyholders’ Interests, Operations and Allied Matters of Insurers) Regulations, 2024, and the IRDAI Master Circular on Operations and Allied Matters of Insurers, 2024, has established various obligations and duties for insurers regarding customer service and protection of customer interests. These regulations also mandate insurers to have in place a customer service policy approved by the Board or the Policyholder Protection and Grievance Redressal Committee (PPGRC).

Therefore, in alignment with the values of the Company and statutory requirements, this Policy on Customer Service has been formulated.

 

2. Applicability 

This Policy shall apply to all the customers of the Company as defined in the Definition clause. 

 

3. Obligations of the Company 

1. The Company shall ensure the fair treatment of prospects during the solicitation and sale of insurance policies. This shall include providing clear, accurate, and comprehensive information about the policies, benefits, terms, and conditions, thereby enabling prospects to make informed decisions. 
2. The Company shall ensure that all communications are conducted ethically and transparently, avoiding any form of misleading or deceptive practices.
3. The Company shall ensure that the interests of policyholders are always protected. This obligation includes ensuring that the conduct of the Company and its distribution channels is not prejudicial to the interests of policyholders. The Company shall enforce strict compliance with regulatory standards and ethical guidelines to uphold the trust and confidence of its policyholders.
4. The Company shall ensure the timely and efficient handling of all claims. This includes establishing and adhering to clear timelines and turnaround times for processing claims, communicating with claimants promptly, and providing comprehensive support throughout the claims process. 
5. The Company shall ensure the confidentiality and security of personal information of policyholders. This shall include implementing robust data protection measures, ensuring compliance with all relevant data privacy regulations, and preventing unauthorized access or misuse of policyholders' information. 
6. The Company shall ensure the availability and accessibility of customer support services. This shall include maintaining a responsive and well-trained customer support team that is available to address inquiries, resolve issues, and provide assistance to policyholders at all times. The Company shall ensure that customer support services are accessible through multiple channels, including phone, email, and online platforms, to cater to the diverse needs of policyholders.

 

4. Turnaround Time

This detailed turnaround table is in reference to timelines specified in this policy and grievance redressal policy and to ensure timely and efficient service delivery in line with our commitment to customer satisfaction and regulatory compliance:

Part B – Insurance Awareness Policy

 

1. Introduction

1. Insurance Literacy plays a key role in Insurance inclusion as well as in increasing Insurance penetration. Lack of awareness on basic understanding of insurance has proved to be one of the impediments in insurance not becoming popular. 
2. In order to promote insurance literacy and awareness amongst the masses, the Insurance and Regulatory Development Authority of India (IRDAI) has mandated all insurance companies to form an Insurance Awareness Policy duly approved by the Board. The policy shall incorporate the yearlong action plan and calendar for initiating insurance literacy and awareness campaigns across the country.   
3. Go Digit General Insurance Limited (Company) has always been at the forefront to promote the insurance concept through creating insurance awareness and educating the masses about the benefits of general insurance. 
4. The Company has undertaken various initiatives in the recent past to spread awareness about insurance benefits. This Insurance Awareness policy aims to chalk out a framework in line with the National Strategy for Financial Education (NSFE) and describe broad initiatives that it plans to undertake to spread Insurance awareness going forward. 
5. Further, this policy includes a calendar of the various initiatives and activities that the company would be organizing through the year. The policy is subject to periodical review based on the changes in the regulatory and business environment. The changes to the policy, if any, and as approved by the Managing Director would be placed at the board meeting held subsequent to the changes made.

 

 

2. Applicability

1. The policy shall apply to all activities like printing and distribution of pamphlets / brochures etc spreading Insurance Literacy through public forums / seminars / workshops etc., classroom training in education institutions, mass contact programs, TV / Radio / Newspaper / Internet advertisements, company website, social media platforms like Facebook, Twitter, Instagram etc.
2. The above activities can be undertaken by the employees of the Company or its intermediaries, business associates, vendors, customers. The Company may also engage the services of NGOs / other institutions to offer these services. The Company may use its own resources or associate with the institutions to impart such Insurance Literacy as described above. The Company may also sponsor such initiatives being organized by other organizations / NGOs / Consumer Associations / IRDAI and other entities etc. 
3. Such Insurance Awareness initiatives can also be delivered through outbound calling or SMS or e-mailers or physical letter or social media campaigns.
4. This “Insurance Awareness Policy” applies to the whole of the company which includes all the state, regional, branch offices, to all the departments and functions of THE COMPANY including the corporate office.
5. This policy is applicable to the insurance awareness activities that are required to be undertaken by the Company from time to time upon the directions of IRDAI or any other applicable statutory authority.

 

3. Insurance Awareness

1. Insurance Awareness refers to a state of consciousness where the individual is imparted with the basic knowledge about different types of General Insurances like Health, Personal Accident, Motor 3rd Party, Motor Own Damage, Property, Cattle and Crop etc. Further he/she understands the broad coverage of risks offered under different policies, major exclusions under each policy. Further, the individual also understands the generic claims procedure and the type of documents required to support a claim. 
2. Awareness in the insurance industry can generally be broken down into the following categories:
   • Meaning of Insurance and Need for it
   • Meaning of General Insurance
   • Different types of General Insurance policies 
   • Types of coverage available
   • Major exclusions under General Insurance
   • Basic Claim Process and Documents required
   • The Company’s information strategy will focus on educating individuals and customers on:
   • Need for insurance and its benefits
   • Company’s products, along with an appreciation of risk and loss and ways that insurance products can help to mitigate the same
   • Process of obtaining and renewing an insurance policy 
   • Processes on reporting claims and follow-up on settlement
3. The channels planned to be used for the purpose of information dissemination may be as follows:
   • Mass media including print (newspapers and magazines) and electronic (television and radio)
   • Digital channels of communication
   • Social media including various popular sites on the Internet
   • Distribution channels and branch offices which will carry detailed sales literature about the products
   • Vernacular language dailies catering to specific understanding needs owing to geographic and cultural diversity
   • Rural focused events such as street plays, region al workshops and awareness camps amongst others
   • Outdoor promotions in the form of hoardings and bill-boards
   • Website providing a detailed description of all the products and their features, customer service support, grievance redressal guidance, claims procedures and guidance on claims tracking
   • Locally recruited consultants
   • Bima Vahaks as per the Guidelines/Directions that the Authority may prescribe
4. The Company’s plan for Insurance awareness may include the following: 
   • Insurance awareness day at various locations – where the entire day is spent in creating insurance awareness amongst the public through media campaigns, insurance mela, advertisements, road shows etc.
   • Specific advertisements through various media to create Insurance Awareness.
   • Press Meets and Press Releases highlighting Insurance Awareness Initiatives.
   • Distribution of insurance education literature in various languages.
   • Social Media Campaign
   • Various virtual games on the Company’s website.
   • Dedicated web page giving information about the basics of insurance. (Product neutral)
   • To impart financial education through workshops to various target segments, namely, school and college students, working executives, middle income group, home makers, retired personnel, self-help groups, etc.,
   • Creating awareness amongst the policyholders about their rights and duties and the channels available for grievance/dispute redressal, etc.
   • Education material on insurance covering the basic concepts related to insurance sector, insurance including need for adequate cover, need to regularly pay premium, etc. in context to policy holder.
   • Engaging with local government bodies like Panchayat Raj Institutions and Civil society bodies, Teachers of High School, NGOs, SHGs and Educated youth in villages for spreading insurance awareness.  
   • Use of mix of channels and tools – E.g. Technology/ field agents/ print/media, etc.  Serves different purpose and meet various learning needs. Tools used will be customized to serve needs of particular region/ target customer base and on-the ground partners will be best placed to customize such initiatives.
   • The Company shall have special focus on the State allocated by the Authority i.e. Jharkhand for insurance awareness activities.
   • The Company has also noted various measures taken by the Authority viz., observing April 19 as Insurance Awareness Day. The Company would endeavour to re-iterate such initiatives of the Authority and carry the baton of spreading insurance awareness.

 

4. Insurance Awareness Governance Framework

1. Insurance Awareness Governance Framework is in line with the National Strategy for Financial Education (NFSE). The theme of Insurance Literacy initiatives conforms to the following broad objectives.
2. Creating Inclusive Growth, Financial Inclusion & Financial Education
3. Imparting necessary knowledge and skills to choose the right insurance   products.
4. Enabling freedom from exploitation through miss-selling / laid down
5. Leading to behaviour change.