COMPLAINTS management
General
Application
This procedure is applicable to all Marine & Offshore Product Line Activities, whether locally in the Network or in Head Office.
Definitions
Complaint: A complaint is a written expression of dissatisfaction from a client, customer, public authority, accreditation body, certification body, scheme owner, regulator or other interested party relating to a Recognised Organisation (RO) activity or contractual obligation for which a response is expected.
A complaint shall be distinguished from a legal claim or litigation which are dealt with in accordance with Recognised Organisation (RO) M&O Legal Risk and Compliance handbook.
Where a complaint is received verbally, the complainant shall be requested to submit the complaint in writing for further processing.
Complaint Status:
NEW: This is the initial processing step. This status is to be used as long as all the elements allowing the processing to be initiated have not yet been gathered
ON HOLD: This status must be assigned by the person receiving the action / task to do for the complaint
ESCALATED: This status is limited to cases where the task entrusted to the staff assigned did not address a satisfactory answer to the customer’s complaint. This case should be analysed with involvement of the management.
CLOSED: This status is achieved as soon as the complaint has been completely processed and answer has been sent to the client.
Case Module: Module within Recognised Organisation (RO)’s internal tool “Salesforce” to record any customer complaint
Case Owner: Person responsible for handling the complaint from receipt to closure
Case Team: Team involving all employees in charge of handling the complaint, from receipt to closure
Response: Formal communication sent to the complainant providing a complete answer to the complaint.
Roles and Responsibilities
Receiver of a complaint
Immediately forward the complaint email/document to the Country Manager or relevant Head Office Department.
If verbal complaint received: Request complainant put it in writing.
Country Manager or Delegate
Initial assessment of complaint
Receive and review complaints
Conduct investigation to identify the contractually concerned Recognised Organisation (RO) Unit
Determine if complaints should be processed locally or escalated
Recording and grading of complaints
Designate the Case Owner
Ensure complaints are recorded in Sales Force case module
Assign severity grade “High” vs. “Low priority” (see criteria in Section 2.2.2.4)
Ensure minimum required documentation is captured
Oversight & Follow-up
Oversee the implementation of corrective actions
Keep the Case Owner informed of significant steps
Follow-up on closure of all complaints
Report High priority complaints to Zone Vice President and Head Office Quality Department
Decide whether to report "Low" priority complaints to the Regional Chief Executive and the Region Senior Vice President
Ensure annual review of complaints is part of quality system review
Special Requirements for ISO 17065 Floating Wind & Offshore Activities
Ensure decision-maker resolving complaint is NOT involved in original certification activities
Verify there is no conflict of interest (see Note in 2.2.2.1)
Complaint Case Owner
Customer Communication
Acknowledge receipt of complaint within 2 working days of receipt (see example ANNEX A1 template)
Maintain dialogue with claimant throughout resolution process
Provide a formal response to the complainant with resolution of complaint within 30 days of receipt
Keep customer informed of progress and sustainability checks
Provide significant complaint-related correspondence to the Country Manager or delegated manager as required.
Investigation & Root Cause Analysis
Coordinate the complaint investigation and resolution process
Identify root cause
Propose corrective action plan and initiate implementation
Monitor implementation effectiveness
Verify sustainability of results
Resolution & Closure
Develop and implement corrective actions within 30 days. In case the complaints are more complex they can be escalated and the duration may exceptionally be longer than the 30 day rule in which case QHSSE Dpt should be advised (ex. complaints having legal implications or Recognised Organisation (RO) rule change implications).
Maintain records and traceability of complaint activities
Close complaint when fully resolved
Ensure all evidence is attached in Salesforce CASE module before closure
Keep management informed of progress and significant developments.
M&O Head Office Quality Department
Support compliant investigation and allocation where required.
Participate in escalation and review of significant complaints.
Monitor monthly and supervise the execution.
Support the Network as Salesforce Administrator
References
Internal
Group QHSE PO-004 Complaints & Appeals Management
Group QHSSE 107-PR Root Cause Analysis
the related management procedure Management System Review
External:
IACS Quality Management System Requirements (IQMSR)
ISO 9001:2015 - Quality management systems Requirements
process
Key Principles
Recording and Processing
Complaints must be recorded and the details transmitted to the relevant managers for processing.
Non-client Complaints
In case a complaint is received from a “party” which is not a Recognised Organisation (RO) client, due consideration must be given whether or not it is permitted to answer, taking into account breach of confidentiality; in such case the content of the answer must be coordinated with HO.
Complaints which are not related to a specific service are immediately rejected in writing.
The Country Manager or delegate shall determine whether a complaint is outside the scope of this procedure. Any rejection shall be documented, justified, communicated in writing to the complainant and retained within Salesforce.
Independence, Impartiality and Confidentiality
Complaints shall be investigated, reviewed and resolved in an impartial manner. They shall also be handled confidentially and information only shared with personnel involved in investigation, reviewing or approving the complaint resolution. Personnel directly involved in the activity, service delivery, assessment, audit, inspection, certification decision, or other work that is the subject of the complaint shall not approve the final complaint resolution.Where necessary, an independent reviewer shall be appointed to review and approve the proposed resolution to ensure objectivity and avoid conflicts of interest.The identity of personnel involved in the investigation and review of complaints shall not be disclosed to the complainant.
Processing complaints
Receipt of a complaint
Whenever a staff member or Business Unit receives a complaint, they shall immediately notify their management and forward the complaint email or document received from the complainant to the Country Manager or relevant Head Office Department to which they report to. This notification constitutes escalation to the appropriate management level for further processing in accordance with this procedure.
A staff member who receives a similar verbal statement shall request the complaint be communicated in writing.
Complaints which are addressed to Recognised Organisation (RO) Executive Management, or are received at the Head Office without a specified address shall be forwarded to the Quality Department for appropriate redirection.
Allocating and initial assessment of a complaint
Assignment of a complaint
Upon receipt of a complaint, the Country Manager or relevant Head Office Department shall appoint a Complaint Owner responsible for coordinating the investigation, communications and resolution process. Support from the Head Office QHSSE may be sought where necessary to identify the contractually responsible Business Unit and facilitate effective complain management.
NOTE: For complaints related to the M&O Floating Wind & Offshore activities - all persons involved shall take necessary measures to preserve the confidentiality, independence and impartiality obtained during all stages of the processes. The decision resolving the complaint shall be made by, or reviewed and approved by, person(s) not involved in the certification activities related to the complaint. To ensure that there is no conflict of interest, personnel who have provided consultancy for a client, or been employed by a client, shall not be used to review, or approve the resolution of a complaint in subject.
Complaint investigation and processing
The Country Manager or designated Complaint Owner shall coordinate the investigation of the complaint, gather relevant information and evidence, communicate with the complainant as appropriate, and oversee the implementation of actions necessary to achieve resolution.
Complaint recording
All complaints shall be registered and managed within Salesforce CASE module within 2 working days of receipt.
The Complaint Owner shall ensure that sufficient information, supporting evidence, and records are maintained within Sales Force throughout the complaint management process to demonstrate effective handling and resolution.
As a minimum, the following records shall be maintained:
Original written complaint received from the complainant
Evidence of the acknowledge sent to the complainant by Recognised Organisation (RO) within 2 working days of receipt
Details of the investigation and any corrective actions
All correspondence and communications relating to the complaint
The final response issued to the complainant
Evidence confirming closure of the complaint
To record all above elements the "CASE COMMENT" and "ATTACHED FILES" sections in Sales Force shall be used to maintain a complete and auditable record of complaints.
Complaint classification and escalation
Complaints shall be initially classified according to their potential impact and severity to ensure an appropriate level of management oversight and response.
A complaint shall be classified as High priority where it is likely to:
have a significant impact on the accreditation or certification granted to the M&O Product Line;
result in legal, contractual, regulatory, or financial consequences for Recognised Organisation (RO);
present a significant reputational risk to Recognised Organisation (RO);
require immediate management attention due to the nature or potential consequences of the issue;
Complaints may be classified as High priority in circumstances including, but not limited to, the following:
A complaint shall be classified as High priority where it is likely to:
the claimant is a Flag Administration;
the claimant is an accreditation or a certification body;
the claimant is a major or a strategically important client;
dissatisfaction is expressed in strong, threatening terms, such as legal notice, claim for compensation, threat of blacklisting, or threatened litigation;
the complaint identifies a significant weakness within Recognised Organisation (RO) operations or relates to recurring or repeated incidents
Complaint that do not meet the above criteria shall be classified as Low Priority.The Country Manager or delegated management representative may determine whether a Low Priority complaint should be escalated to additional management levels based on the nature, complexity, or potential impact of the complaint.
Complaint management and Resolution
Complaint investigation and resolution
The Complaint Owner shall ensure that the complaint is investigated and resolved in a systematic and traceable manner. This shall include:
determining the nature and extent of the complaint;
identifying the root cause(s) where applicable;
developing and implementing corrective actions to address the identified causes;
monitoring the implementation and effectiveness of corrective actions;
maintaining records and evidence demonstrating investigation, decision-making and actions taken;
monitoring the implementation and effectiveness of corrective actions;
verifying that the complaint has been satisfactorily resolved;
ensuring all relevant records are retained within Sales Force.
Response and closure
The final response to the complainant including the resolution of the complaint shall normally be provided within 30 days of receipt of the complaint. Where complaints are more complex, they can be escalated and the duration may exceptionally be longer than the 30 day rule in which case QHSSE Department should be advised (ex. complaints having legal implications or Recognised Organisation (RO) rule change implications).
A complaint shall only be closed once:
the investigation has been completed;
corrective actions have been implemented, where required;
monitoring the implementation and effectiveness of corrective actions;
the effectiveness of actions has been verified;
the complainant has received a response;
all relevantt records and supporting evidence have been uploaded to Sales Force.
Annual review of complaints
As part of the quality system review process defined in the related management procedure, each Business Unit and Business Line shall conduct an annual review of complaints to evaluate complaint performance, identify trends, assess the effectiveness of corrective actions, and identify opportunities for continual improvement.
The annual review shall include, as a minimum, an analysis of:complaint shall only be closed once:
complaint volumes;
recurring complaints themes and trends;
complaint root causes;
Business Unit and Product Lines trends;
complainant acknowledgment performance;
the effectiveness of corrective actions implemented;
opportunities for improvement;
any systemic issues requiring management attention.
Appendix — Guidance for acknowledge receipt of a complaint
Purpose
The primary purpose of the acknowledgment is to:
confirm to the complainant that their complaint has been received and is being addressed;
establish an appropriate channel of communication throughout the complaint management process;
provide Recognised Organisation (RO) with sufficient time to conduct an impartial investigation of the complaint;
ensure that the complaint is managed in a consistent, professional, and legally appropriate manner.
Acknowledgment
Upon receipt of a complaint, the Complaint Case Owner shall acknowledge receipt to the complainant within two working days in accordance with this procedure.
The acknowledgment shall:
confirm receipt of the complaint;
identify the Recognised Organisation (RO) representative responsible for coordinating the complaint;
provide Recognised Organisation (RO) with sufficient time to conduct an impartial investigation of the complaint;
confirm that the complaint is under review;
explain the next steps in the complaint management process;
provide an indication of the expected time frame for further communication.
The acknowledgment may be adapted as necessary, taking into consideration:
the severity classification of the complaint;
the information available at the time of acknowledgment;
any legal or regulatory considerations;
confirm that the complaint is under review;
applicable local requirement;
The acknowledgment may be in the form of a letter or an email correspondence. An example is shown in A1.3 below.
Example Acknowledgement by Letter
The following model text may be used as a basis:
“Dear [Complainant Name],
Thank you for your correspondence dated [date], which was received by Recognised Organisation (RO) on [date received].
We acknowledge receipt of your complaint and confirm that it is currently under review.
I have been appointed as the Complaint Case Owner and will act as your primary point of contact throughout the complaint management process.
Recognised Organisation (RO) is currently gathering and reviewing the information relevant to the matters raised in your complaint. An investigation will be conducted in accordance with our complaint management process.
We will keep you informed of progress as appropriate and aim to provide a response within 30 days. Should additional time be required due to the complexity of the matter, an interim update will be provided.If you have any additional information that may assist our review, please forward it to the contact details provided below.
Yours sincerely,
[Name]
Complaint Case Owner