Complaints Procedure – Bolster B.V.
1. Purpose and status
This document sets out the internal complaints handling procedure of Bolster B.V. (hereafter: “Bolster”) and applies to all complaints relating to the services provided by Bolster.
The objective of this procedure is to ensure that complaints are handled in a consistent, transparent, timely and impartial manner, and that appropriate corrective and preventive actions are taken where necessary.
The submission and handling of complaints is free of charge.
2. Definition of a complaint
A complaint is any expression of dissatisfaction, whether oral or written, relating to:
> the provision of services by Bolster
> the administration or handling of an insurance policy
> communication, conduct or service delivery
3. Scope
This procedure applies to:
> all clients of Bolster, including consumers
> all services provided by Bolster in its capacity as intermediary and administrator
4. Role of Bolster
Bolster supports insurance distribution activities and acts as an administrator in relation to insurance products. These activities are performed under the licence and regulatory framework of Howden Nederland B.V..
This means that Bolster is involved in the coordination, administration and communication surrounding insurance placements, while the insurance itself is underwritten by the relevant insurer.
Where a complaint relates to underwriting decisions, policy coverage, or claims handling by the insurer, Bolster may involve the relevant insurer and/or Howden Nederland B.V. in the assessment.
Where appropriate, the complaint may be shared with such parties to ensure it is properly reviewed. Bolster will remain the primary point of contact and will coordinate the process on behalf of the client.
5. Submission of complaints
Complaints can be submitted by email to complaints@bolsterinsurance.com, through your usual contact person at Bolster, or in writing to:
Bolster B.V.
Stationsweg 6
5211 TW ‘s-Hertogenbosch
The Netherlands
To help us review your complaint efficiently, we kindly ask that you include your name and contact details, a clear description of the complaint, any relevant policy or reference details, and supporting documentation where available.
6. Registration and acknowledgement
All complaints are recorded in a central complaints register. The register is maintained in accordance with applicable regulatory requirements and is used for monitoring, reporting and audit purposes.
7. Handling principles
Complaints are handled:
> impartially and objectively
> with due care and attention
> based on relevant facts, documentation and contractual terms
> in line with applicable laws and regulations
The handling of complaints falls under the responsibility of the management of Bolster.
8. Investigation and assessment
Upon receipt, the complaint is assessed and investigated. This may include an internal review of the file and correspondence, consultation with involved employees, involvement of insurers or partners where relevant, and a review of applicable policy conditions and the legal framework.
Where possible, Bolster will seek direct contact with the client to clarify the issue and explore a practical resolution.
9. Timelines
Receipt of a complaint is acknowledged promptly, and Bolster aims to provide a substantive response within 10 working days. If additional time is required due to the nature or complexity of the matter, the client will be informed accordingly and provided with an updated timeline.
A final written response will be issued within 6 weeks of receipt of the complaint. If this is not feasible, Bolster will explain the reasons for the delay and indicate when a final response can be expected, with a maximum timeframe of 10 weeks.
10. Final response
The final response will include a summary of the complaint, a clear assessment and reasoning, and reference to relevant contractual and legal considerations where applicable. It will set out the outcome of the review and, where appropriate, include a proposed resolution.
The final response is provided on a durable medium, such as email or letter.
11. Escalation to Kifid
If the complainant is not satisfied with the outcome, the complaint may be referred to the Kifid, provided the complainant qualifies as a consumer or eligible party.
Kifid (Klachteninstituut Financiële Dienstverlening, website www.kifid.nl) is the independent Dutch institute for out-of-court dispute resolution in the financial services sector.
Before Kifid can consider a complaint, it must first have been submitted to Bolster, and either a final response must have been issued or at least 8 weeks must have passed since the complaint was first raised.
In general, complaints must be submitted to Kifid within 3 months after receipt of the final response, if this timeframe has been communicated, or otherwise within 1 year after the complaint was first submitted to Bolster.
Kifid will initially seek to resolve the matter through mediation and may, if necessary, proceed to a formal decision.
12. Record-keeping and reporting
Bolster maintains a central complaints register in which all complaints are recorded, including the date of receipt, the nature of the complaint, the actions taken, and the outcome and resolution time.
Complaints are periodically reviewed and analysed to identify recurring issues, assess underlying causes, and improve internal processes. Where relevant, findings are escalated to management.
13. Continuous improvement
Insights derived from complaints are used to improve service delivery, enhance product and process design, and strengthen compliance and risk controls.
14. Governance
This procedure is owned by the management of Bolster and is reviewed periodically to ensure continued alignment with regulatory requirements, internal processes, and market best practices.
15. Final provision
Bolster is committed to handling complaints with professionalism, transparency and care. Where concerns arise, clients are encouraged to contact Bolster directly so that the matter can be reviewed and, where possible, resolved in a constructive manner.