The purpose of this Treatment Policy is to comply with the provisions of Art. 154 of Law
147/2015 of 9 September with regard to its relations with policyholders, insured parties, beneficiaries and injured third parties, in accordance with the principles set out in ASF Regulatory Standard 10/2009 of 10/2009,
Insured parties, Beneficiaries and injured Third Parties, in accordance with the principles set out in ASF Regulatory Standard 10/2009 of 25 June, republished by Regulatory Standard 10/2009-R of 10 January.
On the other hand, as stated in the above-mentioned ASF regulations, this Handling Policy
must include the principles relating to the management of complaints, for which reason it was decided to incorporate in the CARAVELA Handling Policy the Regulation of operation applicable to Complaints Management, referred to in paragraph 4 of Article 157 of Law 147/2015 referred to above.
The Handling Policy and Regulations for Handling Complaints must be made known to
of all CARAVELA's employees, distribution channels and other partners, and
made available to the public through appropriate means, namely through the CARAVELA
3. FINAL PROVISIONS
CARAVELA will ensure the necessary dissemination of the rules contained in the Handling Policy and the Regulations for Handling Complaints, so that their contents are totally accepted by those to whom they are addressed, as a set of regulations that bind everyone, and any violation of the provisions contained therein may be subject to disciplinary action under the terms of the legislation in force.
The current Handling Policy, as well as the Complaints Management Regulation are revoked on this date.
The Policy for Handling Policyholders, Insured Persons, Beneficiaries or injured Third Parties is now part of the Claims Management Regulations, documents that appear on the following pages.
POLICY ON THE TREATMENT OF POLICYHOLDERS, INSURED PERSONS, BENEFICIARIES OR INJURED THIRD PARTIESE COMPLAINT MANAGEMENT REGULATION
CHAPTER 1 TREATMENT POLICY
1. This Policy sets out the principles adopted by Caravela - Companhia de Seguros, S.A., hereinafter referred to as CARAVELA, in its relations with policyholders, insured parties, beneficiaries or injured third parties.
2. The principles contained in this Policy reflect the vision and values of CARAVELA, translating the behaviour expected of all its collaborators, including the collaborators of the distribution channels used and all partners who, in the name of CARAVELA, provide services to policyholders, insured parties, beneficiaries or injured third parties.
3. CARAVELA will disclose this Policy to the public on its website and internally to its employees, distribution channels and other partners, with a view to ensuring that the principles contained in it are respected.
Article 2 Equity, Diligence and Transparency
Employees must contribute to ensuring that all policyholders, insured persons, beneficiaries or injured third parties are treated fairly, diligently and transparently, with respect for their rights.
Article 3º Information and clarification
1. In the exercise of their functions, employees shall ensure that policyholders, insured parties, beneficiaries or injured third parties are provided with the information required by law and that adequate clarification is given so that a reasoned decision can be taken, in view of the nature and complexity of the situation, avoiding the marketing of insurance contracts that are not suited to their profile.
2. Communications with all policyholders, insured persons, beneficiaries and injured
third parties, whatever the respective medium, must be written in a clear and easily intelligible manner, reducing doubts of interpretation to a minimum. This principle applies to all supporting material for the sale and formalisation of insurance contracts, including Insurance Proposals and Information Notes, General Conditions, Leaflets, Brochures and other promotional or advertising material.
Article 4º Personal Data
1. The processing, whether carried out with or without automated means, of the personal data of policyholders, insured parties, beneficiaries or injured third parties shall be carried out in strict compliance with the applicable legal standards and with the security rules of a technical and organisational nature, appropriate to the risk presented by the processing of the data.
2. The policyholder, insured party, beneficiary or injured third party may have access to the information that concerns them, requesting their correction, addition or removal, by contacting the CARAVELA offices directly or in writing.
3. Furthermore, CARAVELA's employees are obliged to maintain strict confidentiality regarding all facts and/or information relating to the details of the policyholders, insured parties, beneficiaries or injured third parties, which they learn while carrying out their respective functions.
4. The duty of secrecy ceases only in the situations provided for by law.
Article 5º Preventing and managing conflicts of interest
1. The collaborators must disclose to CARAVELA all situations that could generate conflicts of interest, abstaining from intervening in such situations
2. Conflicts of interest are considered to exist whenever employees are directly or
indirectly interested in the situation or in the process underway, or are their spouses, relatives or kin to the 2nd degree, or even companies or other collective entities in which they directly or indirectly participate. Degree, or even companies or other collective entities in which they directly or indirectly participate.
Article 6º Celerity and efficiency
Employees must perform the functions or tasks incumbent upon them with rigour and
quality, with a view to the swift and efficient management of the processes concerning policyholders
insured persons, beneficiaries or injured third parties, namely in matters of claims and complaints.
Article 7º Suitable qualification
CARAVELA will ensure that its employees are suitably qualified, namely those who
who have direct contact with policyholders, insured parties, beneficiaries or injured third parties, with a view to guaranteeing the quality of customer service, both face-to-face and
Article 8º Antifraud policy
1. CARAVELA has implemented a policy of prevention, detection and reporting of insurance fraud practices, and will provide policyholders, insured parties, beneficiaries or injured
injured third parties, when requested, with the generic information that it considers relevant.
2. CARAVELA may adopt co-operation mechanisms with other Insurance companies,
namely within the Portuguese Insurers Association, with a view to the prevention, detection or reporting of suspected fraud.
Article 9º Internal Reporting on Treatment Policy
CARAVELA, through the risk management and internal control system, ensures the mechanisms for reporting and monitoring compliance with the treatment policy.
Article 10º Disclosure of Treatment Policy
CARAVELA will make this Policy available to the public on its web site and internally to its
internally with its employees, distribution channels and other partners, with a view to ensuring that the principles contained in it are respected.
CHAPTER 2 COMPLAINT MANAGEMENT REGULATION
Artigo 11º Claims Management
1. Policyholders, insured parties, beneficiaries or injured third parties can present complaints to
complaints to CARAVELA or to the respective Ombudsman, under the terms and through the means established in this
Policy, which is published on the Insurer's website.
2. The management of the complaint process does not entail any cost or charge for the complainant.
3. These Claims Management Regulations form an integral part of the Policy for Handling Policyholders
Policyholders, Insured Persons, Beneficiaries or Injured Third Parties.
Article 12º Concept of complaint
1. A claim is understood to be any manifestation of disagreement regarding a position
taken by CARAVELA or of dissatisfaction with the services it provides, as well as any allegation of possible non-compliance presented by policyholders, insured parties or others.
2. The following are automatically excluded from the concept of complaint: statements made in a contractual negotiation
process of contractual negotiation, interpellations for the fulfilment of legal or contractual
contractual duties, the communications inherent to the process of regularisation of claims and eventual requests for information or
requests for information or clarification shall be automatically excluded from the concept of claim.
Article 13º Guidelines
1. Policyholders, insured parties and other beneficiaries must present their complaints to
complaints to CARAVELA, which will guarantee that they are dealt with quickly, efficiently and impartially and that measures are taken to prevent, identify and manage situations that could constitute conflicts of interest.
2. CARAVELA will guarantee that the units complained of will provide the necessary information
necessary for the proper exercise of the complaints management function.
3. CARAVELA guarantees that all complaints will be dealt with by qualified
with proven experience in this function.
4. The submission of the complaint does not incur any costs or charges for the complainant.
Article 14º Complaints submission and management
1. As part of the Audit and Quality Office, the Complaints Management Department
(DGR) has as its main functions to receive, register, process and respond to the complaints
2. Complaints must be submitted in writing in one of the following ways:
• E-mail: firstname.lastname@example.org
• Fax: +351 213 245 079;
• By letter addressed to CARAVELA - Gestão de Reclamações Av. Casal Ribeiro, 14 1000-092 Lisboa.
• Through registration in the Book of Complaints, which exists in all the CARAVELA Delegations
3. Additional information, related to the opening and progress of
complaints, may be requested by letter, e-mail or telephone, through the caravela Contact Centre
CONTACT CENTRE (217 958 690).
4. The RCD shall proceed to computerize the registration of all complaints for statistical purposes and
statistical purposes and for informing the entities that have a legitimate interest.
5. The computerised registration of complaints will be processed by the RCD, with the
periodicity as appropriate, with the aim of preventing future situations of complaints
based on the same assumptions (corrective actions).
6. Within the scope of its functions, the RCD will collaborate with the Customer Ombudsman, appointed by
Article 15º Requirements of the complaint
1. Complaints must be submitted by any means on which a written record is kept and must contain the following requirements:
a) Identification of the quality of the claimant, namely, policyholder, insured
beneficiary or person acting in its representation;
b) Full name of the claimant, in the case of a legal person, identification of the legal
representative and the quality in which it acts;
c) Identification document number of the claimant (FAT);
d) Complainant's address;
e) Contact details of the person lodging the complaint (e-mail preferably, for a quicker response)
f) Basis and description that motivated the complaint, with identification of the intervenient and the dates in which the facts occurred, except if it is manifestly
g) Number of the insurance policy or claim file, when the claim is related to one of these objects;
h) Date and place of the complaint.
2.When the complaint presented does not contain the essential elements for its handling, CARAVELA will notify the
CARAVELA will notify the complainant, provided that they are duly identified, inviting them to complete the
3. Communications will not be considered complaints, and will not be treated as such, if:
a) They do not contain the essential data to enable them to be managed as a claim;
b) They aim at presenting a complaint regarding a matter that falls within the competence of arbitration or judicial bodies or when the matter object of the complaint has already been settled by such bodies
arbitral or judicial bodies or when the matter object of the claim has already been solved by those
c) They repeat claims that have been presented previously by the same claimant and in relation to the same
same situation and that have already received a response from CARAVELA under the terms of the present regulations;
d) They show bad faith or have a content qualified as vexatious.
e) CARAVELA will inform the complainants, by any means that leaves a written record
the grounds for the non-admission as a claim and will file the claim.
Article 16º Recourse to Judicial Authorities
1. The handling of a complaint under the terms of the present regulation does not prejudice the right of complainants to have recourse to the Courts or to mechanisms of extra-judicial resolution of disputes.
2. CARAVELA reserves itself the right to not continue with a claim when the matter in question is being considered by arbitration or judicial bodies.
Article 17º Deadlines for reply
1. The complaint will be examined and will receive a response from CARAVELA within 10 days, counting from the date it is received.
2. In relation to claims that are particularly complex, the time limit set out in the previous number may be extended for a further 20 days, counting from the date they are received.
3. If it is impossible to comply with the stated deadlines, CARAVELA will inform the
Complainant, indicating the reasons for the lack of response.
Artigo 18º Appeal to the Client's Ombudsman
1. Once the deadline for reply set in the previous article has passed without the CARAVELA expressing its opinion
complaint or, if it does make a statement, the complainant disagrees with the solution presented, the complainant
request the intervention of the Client's Ombudsman.
2. For the effect foreseen in the previous number, the complainant may activate the services of the
Ombudsman's Office, by letterby addressing your dissatisfaction to:
Rua do Infante D. Henrique, nº. 73, Piso 1
4050 – 297 Porto
Tel.: 226 069 910 (national landline calls)
Fax: 226 094 110
Article 20º Disclosure of the Complaints Management Regulation
CARAVELA will make these regulations available to the public on its web site and internally,
its employees, distribution channels and other partners, with a view to ensuring respect for the principles
principles enshrined in it.
PLT - POLICY 02- 00 / 2017
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