Complaints Handling Policy

1.     Introduction

Juno Indemnity Limited (the “Firm”, “Juno”) is a Private Limited Company registered in England and Wales, with Company Number 16463130, incorporated on 20/05/2025. Juno is applying to the Financial Conduct Authority (“FCA”) to become an insurance intermediary.

This Complaints Policy is intended to ensure that Juno handles complaints fairly, efficiently and in compliance with the FCA rules and standards. This Policy sets the guidelines on how a customer can make a formal complaint and how Juno’s employees will handle complaints through the complaint management system according to the key principles and concepts set in the Policy.

The Policy is designed to uphold the principles of effective complaint handling, which serve to:

  • Demonstrate Juno’s dedication to delivering high-quality service to customers and stakeholders by taking concerns seriously and responding constructively;
  • Identify and rectify service or process failings, ensuring customers receive appropriate redress where required;
  • Drive continuous improvement by learning from complaints and implementing measures to prevent recurrence of the underlying issues.

1.1  Purpose

The purpose of this Policy is to:

  • provide a fair complaints procedure which is clear and easy to use for customers wishing to make a complaint;
  • publicise the existence of Juno’s complaints procedure so that any customer wishing to complain to the Firm knows and has easy access on how to contact the Firm to make a complaint;
  • ensure relevant Firm staff are trained and know what to do if a complaint is received;
  • ensure all complaints are investigated fairly and in a timely manner;
  • ensure that complaints are resolved, and customer relationships repaired; and
  • gather information that helps Juno improve its

This Policy will be reviewed at least annually by the Compliance Officer and amended as necessary.

1.2  Scope

This Policy applies to all complaints received from actual or potential customers of Juno and covers all services, and customer interactions, including those relating to service quality, conduct of staff and the Firm’s complaint handling procedures. All complaints will be investigated and resolved in line with this Policy, and at no cost to the complainant.

This Policy does not apply to internal grievances raised by Juno staff, unless the complaint relates to the individual in their capacity as a customer of Juno.

It is the responsibility of all Juno staff, including permanent staff, contractors and temporary personnel to understand and adhere to this Policy when receiving, responding to or managing complaints.

The Policy is accessible to all relevant personnel via secure internal systems to maintain awareness and consistent application across the Firm.

2.     FCA Industry Rules and Guidance

2.1  Definition of a complaint

A “complaint” is defined by the FCA (G197(2)) as any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of a customer or potential customer about the provision of, or failure to provide, a financial service which

  1. alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience; and
  2. relates to an activity of the Firm or any other organisation that the Firm has some connection to in marketing or providing financial services or products.

2.2  How to make a complaint

Juno aims to make the complaints process accessible and straightforward for all customers, in line with FCA expectations.

Customers can submit complaints through any of the following channels:

  • Email: support@junoindemnity.co.uk
  • Telephone: +44 20 3941 8919
  • Post: Juno Indemnity Ltd, 70 Gracechurch Street, London EC3V 0HR
  • Online Complaint Form: Accessible via Juno’s website, enabling customers to submit complaints securely and conveniently

All complaints should be directed to Mr. Patrick Bullen-Smith, Juno’s Compliance Officer, who is responsible for overseeing complaint handling in accordance with the FCA’s Dispute Resolution (DISP) rules.

Juno acknowledges all complaints within five business days of receipt, confirming the name and contact details of the person handling the case. Throughout the complaint investigation, the complainant will receive regular updates, particularly:

  • At or around the four-week mark, if a final response has not yet been issued, the complainant is informed of the progress and the reason for the delay;
  • By eight weeks, if a final response is still not ready, the complainant is notified of the delay and informed of their right to refer the complaint to the Financial Ombudsman Service.

Please see section 4.1 for a detailed breakdown of investigating, assessing and resolving complaint.

In line with Juno’s Vulnerable Customers Policy, and to ensure that customers can access the Firm’s complaints process and services in a way that meets their individual needs, Juno is committed to provide accessibility and fair treatment for all customers. Where a customer has a vulnerability or accessibility need, Juno offers reasonable adjustments upon request, including but not limited to:

  • Alternative communication formats;
  • Use of preferred communication channels (e.g. telephone, email;
  • Extended response times where appropriate; and
  • Assistance from a nominated third party, where authorised

To ensure that Juno addresses the needs of all customers including vulnerable customers and those with limited digital access, a postal complaint submission is offered as an alternative option by the Firm.

2.3  Identifying an Eligible Complainant

As defined by the FCA in DISP 2.7.3R, a person eligible to have a complaint considered under the Financial Ombudsman Service (“FOS”), is a person who is a:

  • “consumer”, being a natural person acting for purposes outside his trade, business or profession. An elective professional customer that is a natural person (an individual) would fall within the definition of consumer; or
  • “micro-enterprise”, being an enterprise that employs fewer than 10 persons and has a turnover or annual balance sheet that does not exceed €2 million;
  • “Small business”, being a small business that has an annual turnover that does not exceed £6.5 million and employs fewer than 50 persons or an annual balance sheet that does not exceed

£5 million; or

  • “Charity” which has an annual income of less than £1 million at the time the complaint is made; or
  • “Trustee of a trust” which has a net asset value of less than £1 million at the time the complaint is made; or
  • a “guarantor” who is not a consumer and has given a guarantee or security in respect of an obligation or liability of a person who was a micro-enterprise or small business as at the date that the guarantee or security was given.

Juno has established a dedicated complaints management function responsible for overseeing the investigation and resolution of all complaints. The Compliance Officer is accountable for monitoring the effectiveness of the complaints handling process, ensuring timely resolution and accurate recording of outcomes and adherence to FCA DISP rules.

As part of Juno’s compliance governance, the Executive Directors (SMF3), Mr Patrick Bullen-Smith and Mrs. Tanna Turnbull, receive regular oversight reports on complaint trends and root causes. A formal summary of complaints data and insights is submitted to the Board at least annually, enabling Senior

Management to monitor conduct risks, identify systemic issues and ensure continuous improvement in customer outcomes.

The FCA requires a twice-yearly report concerning complaints received from eligible complainants (and firms reporting 500 or more complaints must also publish a summary of the complaints data), in accordance with DISP 1.10 and DISP 1.10A.

Every six months, within 30 business days of the Firm’s accounting reference date (i.e. 31/05) and six months after the Firm’s accounting reference date, Juno will provide the FCA, via the RegData electronic reporting system, with a complete report concerning all complaints received, using the complaints return form at DISP 1 Annex 1R.

The Financial Services Compensation Scheme (FSCS) protects customers if a financial firm fails and cannot pay claims. To be eligible for compensation, the claimant must meet the FSCS’s definition of an eligible claimant and either meet the conditions set out for a valid claim or have a type of claim that is specifically protected under FSCS rules.

3.     Complaints Handling

Where Juno receives a complaint from an eligible complainant (see below for the treatment of a complaint from a complainant that is not an eligible complainant) it will be dealt with promptly in accordance with DISP 1.3.

As per the DISP rules, Juno ensures:

  • Effective and transparent procedures for the reasonable and prompt handling of complaints are in place;
  • The procedures outlined on this Policy, including any calls made to the complainant, are made free of charge;
  • The complaints handling procedure allows complaints to be made by any reasonable means (e.g. verbally, or via electronic communication);
  • All complaints are acknowledged as such and resolution and dealing with happens without undue delay;
  • The procedures consider the nature, scale and complexity of Juno;
  • Appropriate controls and steps are in place to ensure that in handling complaints, any recurring or systemic problems are resolved or mitigated;
  • The Compliance Officer is delegated with the responsibility of oversight of Juno’s compliance with complaints handling procedures under DISP 1.

In cases where Juno receives a complaint from a person who is not an eligible complainant under the FCA’s DISP rules, the Firm will nonetheless consider the complaint fairly and with due care, in line with its commitment to high standards of customer service and the Consumer Duty principle of acting in good faith.

Whilst there is no regulatory requirement to follow the DISP process in these cases, Juno will, where possible, seek to resolve the matter as a matter of best practice and ensure that any actions taken or outcomes reached are appropriately recorded within the Firms CRM system, Creatio.

All staff are expected to exercise sound judgement and diligence when handling any expression of dissatisfaction. It is vital that any potential risk indicators or emerging issues are promptly escalated to the Compliance Officer for review. Early identification and resolution of complaints or concerns help prevent harm, support good customer outcomes and reduce the risk of reputational or legal issues for the Firm.

4.     Complaints Resolution and Fair Treatment

4.1  Investigating, assessing and resolving complaints

Upon receiving a complaint, Juno will follow the below process:

1. Immediate Resolution (Verbal Complaint)

If a complaint is made verbally and can be resolved by the end of the third business day following the day of receipt, the Firm will do so promptly. This resolution must be communicated clearly to the complainant and recorded. Mr. Patrick Bullen-Smith as the Compliance Officer will be notified and will oversee the three-day complaint resolution process in line with DISP 1.5.

2. Complaints Requiring Further Investigation

If the complaint is made in writing or cannot be resolved immediately:

  • The matter will be escalated immediately to the Compliance Officer;
  • An acknowledgement will be issued within five business days of This will confirm receipt, outline the next steps and include a copy of Juno’s complaints handling process; and
  • The complainant will be kept regularly informed of progress, with updates provided at least every two weeks, via email or the customer portal.

3. Resolution Timescale

The Firm aims to resolve all complaints within eight weeks of receipt. If a final response cannot be provided by that time, Juno will:

  • Send a written update explaining the delay;
  • Inform the complainant of their right to refer the complaint to the FOS; and
  • Provide the FOS’s contact details in accordance with DISP 6.2R and 1.6.4R.

4. Investigation Standards

Complaints will be investigated competently, diligently and impartially. Additional information may be requested through the complainants preferred communication channels if needed, to understand the facts or context.

5. Assessment Criteria

Each complaint will be assessed fairly and consistently, considering:

  • The specific facts and circumstances;
  • The validity of the complaint and any harm caused;
  • Any appropriate remedial or redress measures; and
  • Whether any other party may share responsibility for the

6. Offering Redress

Where appropriate, suitable redress or remedial action will be offered promptly.

7.   Clear Communication

Following the Compliance Officer’s sign-off, final decisions and offers will be communicated to the complainant in a way that is clear, fair and not misleading, using the customer’s preferred communication channel.

8. Prompt Implementation

Any agreed remedial action or redress will be implemented without undue delay.

9.   Complaint Review Considerations

In reaching a decision, Juno will take into account:

  • All available evidence and relevant circumstances;
  • Patterns or trends from other complaints;
  • FCA and FOS guidance relevant to the case; and
  • Relevant decisions or insights from the FOS on similar

4.2  Summary of resolution

Juno follows the FCA’s simplified complaints handling process for complaints resolved by the end of the third business day following the day of receipt, as set out in DISP 1.5.

In such cases, the Firm is not required to issue a formal written acknowledgement or full final response. Instead, a Summary Resolution Communication is provided to the complainant in accordance with DISP 1.5.4R. This communication will include:

  • Confirmation that a complaint was received and has been resolved to the complainant’s satisfaction;
  • A statement informing the complainant that, if they remain dissatisfied with the outcome, they have the right to refer the complaint to the FOS;
  • The relevant FOS contact details, including postal address, telephone number and website address;
  • A reminder that referral to the FOS must be made within six months from the date of the

The Summary Resolution Communication is issued using the complainant’s preferred communication channel and is designed to be clear, fair and not misleading, in line with the FCA’s expectations under the Consumer Duty.

4.3  Complaints time limits

Juno is committed to resolving complaints as early as possible to deliver good customer outcomes and minimise the number of cases requiring referral to the FOS.

Where a complaint is resolved by close of business on the third business day following the day of receipt, Juno recognises that such complaints are still subject to the principles and expectations set out in DISP 1.5 and must be handled in a way that is fair, transparent and well-documented.

In accordance with DISP 2.8.2R, the FOS generally cannot consider a complaint referred more than:

  • Six months after the complainant receives a final response or summary resolution communication; or
  • Six years after the event complained about, or three years from when the complainant became aware (or ought reasonably to have become aware) of the issue.

Juno may, at its discretion, waive the six-month time limit if it considers it fair and reasonable to do so. Such decisions will be made on a case-by-case basis and communicated clearly to the complainant.

4.4  Final or other response within eight weeks

In accordance with DISP 1.6.2R, Juno will ensure that it issues a written final response to the complainant within eight weeks of receiving the complaint.

Final Response Requirements:

The final response will be a written communication that clearly states Juno’s position and includes the following, as required under DISP:

  • A clear summary of the complaint and the outcome of Juno’s investigation;
  • One of the following positions:
    • Acceptance of the complaint, with an offer of appropriate redress or remedial action;
    • An offer of redress or remedial action without accepting fault;
    • A rejection of the complaint, with a clear explanation and
  • Notification of the complainant’s right to refer the complaint to the FOS if dissatisfied;
  • A copy of the FOS standard explanatory leaflet;
  • The FOS website address and relevant contact details;
  • Confirmation of whether Juno is prepared to waive the six-month referral deadline to the FOS (Juno will not ordinarily do so).

If a Final Response Cannot Be Issued Within Eight Weeks

If Juno is unable to issue a final response within the eight-week timeframe, the Firm will send a holding response that includes:

  • A statement explaining the reason for the delay;
  • An estimated timeframe for resolution;
  • A reminder of the complainant’s right to refer the complaint to the FOS;
  • Confirmation of whether Juno will waive the six-month time limit (again, this will not usually be waived);
  • A copy of the FOS standard explanatory leaflet and contact

Wording used in final and holding responses will follow the guidance set out in DISP 1 Annex 3 to ensure clarity and consistency.

Internal Governance and Oversight

  • Approval from the Compliance Officer is required prior to settling any written complaint or offering redress; and
  • All decisions are documented in the complaints management system, including rationale and evidence considered.

Juno applies the same high standard of care and investigation to all complaints, regardless of whether the complainant is formally classified as an eligible complainant. The only difference is that only eligible complainants have the right to refer unresolved complaints to the FOS. All complainants receive a clear, timely and respectful response in line with Consumer Duty principles, which include acting in good faith, avoiding foreseeable harm and supporting customers in achieving fair outcomes.

Although it is disappointing to receive a complaint, it can present Juno with an opportunity to improve the quality of its services and staff performance. This also ensures the relevant failures that led to the complaint are looked at closely, in order to prevent any repetitions of customer dissatisfaction from occurring. Therefore, the resolution of any complaint will include a full-scope review of Juno’s customer journey, processes and procedures to identify opportunities for internal training or procedural improvements, scrutinise any processes, communications or service failures that contributed to the complaint and locate any systemic issues or trends that may require broader remedial action. Customer satisfaction is of utmost importance to Juno and is taken seriously.

4.5  Financial Ombudsman Service (“FOS”)

Any complaint made by an eligible complainant will follow the general Complaints Resolution procedure outlined in section 4.1. If the customer(s) is not satisfied with the outcome of the final Response Letter, which will include the FOS information leaflet, the customer will be eligible to take the complaint to the FOS.

FOS Contact Details

Website: www.financial-ombudsman.org.uk

Phone: 0800 023 4567 or 0300 123 9123 (or +44 20 7964 0500 if calling from abroad)

Email: complaint.info@financial-ombudsman.org.uk

Address: The Financial Ombudsman Service, Exchange Tower, London, E14 9SR

4.6  Lloyd’s Insurance Policy Holders

If the customer’s insurance is provided by underwriters at Lloyd’s, we will confirm this when acknowledging their complaint. If they are unhappy with our response to the complaint, they may be entitled to refer the matter to the complaints team at Lloyd’s. Lloyd’s will investigate the matter and provide a final response.

Full details of Lloyd’s complaints procedures are available at: www.lloyds.com/complaints.

5.     Transparency and accessibility of complaints information

Juno’s commitment is to ensure that all customers receive fair, clear and transparent communication on how to raise a complaint and what to expect from the Firm’s complaints handling process.

To that end:

  • A copy of this Complaints Handling Policy will be:
    • Published on Juno’s website in an accessible format;
    • Included within the Firm’s Terms and Conditions;
    • Provided upon request, free of charge, at any time;
    • Automatically sent to the customer whenever a complaint is acknowledged, to ensure full awareness of the process.

Juno will also make available a clear and concise summary of its internal complaints procedures, which will explain:

  • The steps the Firm takes to investigate and resolve complaints fairly and promptly;
  • The complainant’s right, if eligible, to escalate the complaint to FOS if they are dissatisfied with the outcome.

This summary (Appendix 1) will be provided:

  • Upon request by any customer;
  • When the Firm acknowledges a complaint;
  • Within the terms and conditions agreed to by the customer;
  • Via any customer-facing section of Juno’s

All complaint-related communications will be presented in plain, accessible language and adapted where necessary to accommodate vulnerable customers or those with specific communication needs.

5.1  Complaints record rule

Juno handles all complaint-related information with the highest standards of confidentiality and sensitivity. Information is only shared with individuals who are directly involved in the investigation or resolution of the complaint, and always in accordance with UK data protection laws, including the UK GDPR and Data Protection Act 2018.

To meet FCA obligations, Juno maintains a comprehensive and secure record of each complaint received within its CRM system, Risk Manager. This includes:

  • The nature of the complaint and all correspondence;
  • The steps taken during the investigation;
  • Final outcomes and any redress or remedial action

These records are retained for a minimum of three years from the date the complaint was received. Storage is managed via Juno’s secure digital CRM system, with appropriate access controls and data security protocols in place.

6.     Staff Training

Juno ensures that all staff involved in complaint handling, customer support and compliance receive mandatory training on effective and compliant complaints management.

Initial and annual refresher training is delivered through the London Governance and Compliance Academy (LGCA) and is compulsory for all team members in complaint-handling roles. This training includes practical, digital-first modules to help staff:

  • Understand the FCA’s definition of a complainant, and rules on complaints;
  • Successfully handle complaints during digital and hybrid complaints interactions, secure messages and email;
  • Apply Juno’s escalation protocols for complaints involving, including those of vulnerable customers;
  • Handle complaints with empathy, care and procedural fairness, especially where vulnerability may affect a customer’s ability to express dissatisfaction or understand available options;
  • Navigate data protection responsibilities when dealing with sensitive personal or health-related information.

In addition to formal LGCA modules, the Compliance Officer delivers scenario-based workshops with practical and real-world complaints examples. These cover:

  • Simulated role-plays of vulnerable customer complaints;
  • Appropriate tone and language in digital communications;
  • When and how to escalate a complaint for further review;
  • Ensuring fair and non-discriminatory resolution

Training content is reviewed and updated at least annually, or more frequently in response to changes in FCA guidance, internal MI or emerging risks by the Compliance Officer. Refresher training forms part of the annual attestation process for relevant staff.

Completion rates and training effectiveness are monitored by the Compliance Officer, who also provides targeted coaching where gaps in knowledge or practice are identified through complaints QA or customer feedback reviews.

7.     Preventing Customer Harm

Where Juno identifies the root causes of complaints and/or recurring or systemic issues in its provision of insurance intermediation services, the Firm will take into consideration the position of customers who may have suffered detriment or harm, or been potentially disadvantaged by such root causes, but have not complained.

Where such cases are identified, Juno will take the appropriate and proportionate measures to ensure that such customers are provided with the opportunity for appropriate redress.

To ensure this, Juno will:

  • Assess the scope and severity of consumer detriment that may have arisen; and
  • Consider whether it is fair and reasonable to take a proactive approach to redress and remediation, which may include contacting customers who have not complained.

7.1  Learning from Complaints

Juno will ensure that it has the appropriate management controls in place and take reasonable steps to identify and remedy recurring or systemic problems that arise from complaints by:

  • Identifying root causes common to individual complaint types;
  • Considering whether such root causes affect other processes or products and services, including those not mentioned in the complaint;
  • Take the appropriate corrective actions where reasonably practicable to do Juno will ensure its compliance with the controls through:
  • Collecting relevant management information on the causes of complaints and the products and/or services the complaints relate to;
  • A process to identify the root causes of complaints;
  • A process to prioritise dealing with the identified root causes of complaints;
  • A process to consider if the identified root causes of complaints affect other products and/or processes;
  • Regular reporting of the above findings to Senior Management;
  • Maintaining records of the final decisions and outcomes decided by Senior Management regarding Senior Management responses to the root causes of complaints.

Although it is disappointing to receive a complaint, it can present Juno with an opportunity for improvement. This also ensures the relevant failures that led to the complaint are looked at closely, to prevent any repetitions of customer dissatisfaction from occurring. Therefore, the resolution of any complaint will include a full-scope review of Juno’s processes and procedures to see what lessons may be learnt, the need for any internal training required etc.

Appendix 1 – Summary of Internal Complaints Handling Procedures

At Juno, we take all customer concerns seriously and are committed to resolving complaints fairly, promptly and transparently. We follow the complaint handling rules set out by the Financial Conduct Authority (FCA) to ensure you receive a consistent and high-quality service.

How to Make a Complaint

You can raise a complaint through any of the following methods:

  • By email to: support@junoindemnity.co.uk
  • By phone: +44 20 3941 8919
  • Through our website
  • By post: Juno Indemnity Ltd, 70 Gracechurch Street, London EC3V 0HR

What Happens Next?

  • We will acknowledge your complaint within five business days of receiving
  • If your complaint can be resolved by the end of the third business day, we will issue a summary resolution communication confirming the outcome and your rights.
  • If your complaint requires further investigation, we will keep you informed of our progress and aim to send you a final written response within eight weeks.
  • If we are unable to respond fully within eight weeks, we will explain why and let you know when you can expect a full response.

If You are Not Satisfied with the Response

If you are an eligible complainant and remain dissatisfied with our final response, or if eight weeks have passed and you haven’t received a final response, you may refer your complaint to the Financial Ombudsman Service (FOS):

 

You must refer your complaint to the FOS within six months of the date of our final response.