Complaint Handling Manual
INTRODUCTION
Dominion Insurance Services, Inc. and First Dominion Corporation (hereinafter “Dominion”) is committed to the highest standards of customer service and professional conduct. This Complaint Handling Manual reflects our dedication to fairness, transparency, and timely resolution of complaints. It has been formally endorsed by our Board of Directors.
As Lloyd’s coverholders, we adhere to the complaint handling standards expected of all business written into Lloyd’s, ensuring compliance with applicable regulations and best practices.
This Manual is maintained by the designated Complaint Handling Officer (CHO), who is responsible for communicating its content to staff, ensuring proper training, and monitoring compliance.
DEFINITIONS
For the purposes of this Manual:
Complaint – A Formal or Informal Complaint as defined below.
Complaint Handling Officer (CHO) – The individual appointed by Dominion to oversee all complaint handling activities.
Formal Complaint – Any grievance, claim, or regulatory inquiry naming Dominion and/or an affiliated Trading Partner that:
is filed with a court of competent jurisdiction;
is reported to Dominion’s insurance carrier(s); or
is issued by a regulatory authority, including a department of insurance or equivalent body.
Informal Complaint – An expression of dissatisfaction regarding products or services provided by Dominion, which does not rise to the level of a Formal Complaint. Examples include:
accounting or billing disputes,
questions or complaints regarding surplus line filings,
account servicing issues raised by clients or Trading Partners.
General Counsel – The legal advisor designated by Dominion.
Trading Partner – Any insurance carrier, retail insurance agency, managing agent, or entity with whom Dominion places business or from whom it has delegated authority.
We / Us / Our – Dominion.
You – Any director, officer, employee, or person working on behalf of Dominion.
PURPOSE
The purpose of this Manual is to establish a clear framework for the efficient, consistent, and fair handling of complaints, and to ensure that all staff understand their roles and responsibilities in this process.
DESIGNATED COMPLAINT HANDLING OFFICER
The CHO is responsible for:
Establishing and maintaining complaint handling procedures.
Receiving and reviewing all Complaints.
Coordinating responses to Informal Complaints.
Referring Formal Complaints to General Counsel.
Ensuring staff receive training on complaint handling.
Reporting complaint activity to senior management and the Board at least annually, or sooner if a material issue arises.
Coordinating with Trading Partners regarding complaints relevant to their business.
Monitoring developments in complaint handling regulations and best practices.
The CHO has appropriate seniority, authority, and resources to carry out these responsibilities.bbAll employees are required to immediately notify the CHO of any complaint received.
COMPLAINT REPORTING AND RESPONSE
Informal Complaints – The CHO will coordinate a response within 5 business days of receipt.
Formal Complaints – The CHO will immediately refer the matter to General Counsel, who will coordinate the response in consultation with Dominion’s insurance carriers and Trading Partners as appropriate.
COMPLAINT RECORDKEEPING
All records shall be retained in accordance with Dominion’s document retention policies and regulatory requirements.
Formal Complaints – Records shall be maintained by General Counsel in a secure, centralized file (digital or physical), including the initial complaint, all correspondence, filings, and resolution documents.
Informal Complaints – The CHO shall maintain a complaint log including the date received, description of the complaint, actions taken, and resolution date.
COMPLAINT MONITORING AND CLOSURE
If a complainant or regulatory agency is dissatisfied with an initial response, the CHO may elevate the matter to a Formal Complaint for handling by General Counsel.
Except for lawsuits or ongoing regulatory matters, if no further correspondence is received within six (6) months of Dominion’s last response, the complaint will be considered closed.
INTERFACING WITH LLOYD’S OF LONDON
Where a complaint involves Lloyd’s business, Dominion will follow the procedures established by the Lloyd’s Underwriter and affiliated London Broker, as well as all applicable state-specific regulations.
This Manual has been initially approved by the Board of Directors and will be reviewed and reapproved annually on or before July 1st.
© 2025 Dominion Insurance Services, Inc. & First Dominion Corporation. All rights reserved.