Handle Complaints and Misconduct Through Two Clear Routes, Fairly and on Record
Set up separate procedures for employee complaints and for conduct cases, with named people, defined steps and records that show what was decided and why. Our employee relations services help banks, NBFCs, insurers and advisory firms treat similar cases alike, including cases of mis-selling, misconduct with customers and manager behaviour. You make each decision, and we help you build a process that supports it.
Not sure what you need? Tell us about your business in six short steps and we will come to the first meeting prepared.
Share your requirementsThe starting point
Could You Show How Each Case Was Handled and Why?
Financial services businesses see a steady flow of employee issues: a collections executive complaining about a manager, a customer complaint about a seller, a dispute over incentive credit or an allegation of falsified paperwork. Without defined routes, cases are handled by whoever hears first, similar cases end differently and the record is thin when someone asks.
We help you build procedures that are understandable, consistent and recorded.
You may be experiencing:
- A complaint about a branch manager reaching the same branch manager, because there is no other route.
- Grievances and conduct cases mixed together, so a person raising a concern is treated as a suspect.
- Customer complaints against sellers handled by sales leadership alone, with no structured investigation.
- Similar allegations of mis-selling or falsified documents resulting in different outcomes by region.
- Investigations conducted with no notes, and decisions recorded as a single line.
- Warnings issued and not recorded, then disputed later.
- Case files kept by the manager, with no central record or period of retention.
What we can help with
Our Employee Relations Services for BFSI Businesses
Grievance Procedure
Define where an employee can take a concern, who receives it, who it goes to when it concerns the manager and how quickly it will be acknowledged and answered.
Disciplinary Procedure
Set the steps from allegation to decision: preliminary review, notice, hearing, decision and appeal, with who decides at each level.
Conduct Case Categories
List the types of conduct matter in your business, such as mis-selling, documentation errors, breach of confidentiality, gifts and conflicts of interest, and who handles each.
Investigation Format
Provide a structure for fact-finding with an investigator separate from the line, notes of interviews, evidence list and a reasoned finding.
Warning and Escalation Ladder
Set the range of outcomes available for a type of matter, so decisions are within a stated range and exceptions are explained.
Consistency Review
Compare outcomes across regions and case types and flag cases that depart from the pattern without reason.
Case Records and Retention
Keep a central case register with the file, decision and dates, with access limited to those who need it and a retention period you set.
Manager Briefing
Brief branch managers and regional heads on what to do and what not to do when a complaint or a suspected breach is reported to them.
The deliverables
What You Receive
The engagement can deliver:
- A grievance procedure with named receivers.
- A disciplinary procedure with decision levels.
- A list of conduct matters and who handles each.
- An investigation template.
- A warning and escalation guide.
- A case register format and retention note.
- A short manager briefing.
- A yearly consistency review calendar.
Step by step
How We Work
Understand Past Cases
We review, with care for confidentiality, how a sample of recent cases was handled and recorded.
Separate the Routes
We design the complaint route and the conduct route as distinct procedures, with an owner for each.
Draft the Documents
We write the procedures, templates and case register with your HR, legal and compliance leads.
Brief the Managers
We take branch and regional managers through the steps and the common mistakes.
Run and Review
We review the first cases handled. Before work starts we record where you stand, and we report against that baseline.
The difference
Cases Handled the Same Way, Every Time
Clear procedures help you:
We do not promise outcomes. We record a baseline before work starts, covering time to acknowledge and close cases, outcome differences between regions for similar conduct, and the share of cases with a written finding, and report against it, so you can see what changed and what did not.
- Give employees a route for concerns outside the reporting line.
- Keep complaints and conduct cases apart.
- Handle similar cases in similar ways across regions.
- Make findings and decisions traceable.
- Record warnings and outcomes centrally.
- Prepare managers for the first conversation.
Find your fit
Who This Service Is For
Banks and Branch Networks
Handle conduct and customer-complaint cases with consistent steps across many branches.
NBFCs and Microfinance Companies
Set routes for field and collections staff, including complaints about supervisors and about recovery conduct.
Insurance Companies and Agencies
Handle mis-selling and agent-conduct allegations with a structured, recorded process.
FinTech Companies
Put basic procedures in place as the first conduct and complaint cases appear.
Advisory and Wealth Firms
Handle suitability, conflict-of-interest and documentation matters with a clear record.
How it usually shows up in banking, financial services and insurance
Conduct, mis-selling allegations and incentive disputes are the main employee relations issues in BFSI. Complaints are often resolved at the branch with an apology and no investigation record, so the company cannot show what it did. A second complaint about the same officer is treated as a new matter. An officer who leaves before an investigation ends takes the question with them. Complaints are handled as customer matters and seldom seen as a sign that targets or incentives are pushing conduct.
Common challenges
Where it goes wrong in banking, financial services and insurance
Complaints are closed at the branch
The branch resolves the customer's complaint and nobody asks whether the officer has a pattern.
Investigations are not recorded
Conversations and apologies are not a record, and the company cannot show what it did.
Departing staff are not followed up
An officer who leaves before an investigation ends takes the question with him.
Sales pressure and misconduct are treated apart
Complaints are handled as a customer matter and never as a sign that targets or incentives are pushing conduct.
A better process
What a working version looks like
- 01
Log every conduct complaint centrally
Each complaint about how a sale was made is recorded with the officer, the branch and the outcome, so repeats are seen. The grievance and disciplinary process provides the route.
- 02
Investigate properly
A named investigator, a short written finding and the action taken, held on file.
- 03
Complete cases before exit
Investigations are finished, or noted as open, before a person's exit is processed.
- 04
Look for the cause
Where complaints cluster, review the target and the incentive that may be behind them.
What to check this week
- Look at the last complaint about how a sale was made. Is there a written record of what was done?
- Check whether a repeat complaint about the same officer would be seen.
- Find out whether open investigations are noted when someone resigns.
- Look at conduct complaints by branch and see whether they cluster.
- Confirm with a qualified professional the investigation, recording and retention rules that apply.
Confirm with a qualified professional. What applies depends on your establishment, your state and your sector, and it changes. This page describes a practice; it does not state a legal position.
What this looks like in banking, financial services and insurance
The parts of employee relations that are specific to this sector, rather than general.
Conduct and Mis-selling Risk
Consistent handling of customer-facing misconduct.
What this coversHide
Conduct and Mis-selling Risk
Consistent handling of customer-facing misconduct.
What this coversHide- Code of conduct
- Customer-interaction standards
- Mis-selling complaint process
- Investigation procedure
- Show-cause and warning process
- Escalation matrix
- Disciplinary consistency review
- Incident documentation
- Corrective action tracking
Questions on this, in banking, financial services and insurance
No. GullyHR does not give legal advice. We help you design procedures and records, and the obligations that apply to a case, including the rules on notice, hearing and any dismissal, should be confirmed with a qualified professional.
Because a person raising a concern should not be treated as the subject of an inquiry, and an accused person needs a different process. Keeping them apart protects both and keeps the record clear.
We can design the process and templates, and support your investigator. Where an independent investigation is needed, we discuss the arrangement with you, and what is appropriate depends on the case and your advisers.
They should follow the route your policy and your advisers set. We help you make sure that route exists, is known and is recorded, and we do not advise on what the law requires.
As conduct matters with a defined investigator, a documented finding and a consistent range of outcomes. How the matter is reported outside the company is a question for your compliance and legal advisers.
A central register is the easiest way to show what was decided and why, and to see whether similar cases are treated alike. It also lets you spot patterns, such as complaints that cluster around a manager.
By a named person independent of the branch, with a written finding and the action taken, kept on file. A conversation and an apology are not an investigation.
Because patterns only show at the centre. A branch sees one complaint, and the company can see that the same officer, branch or product keeps appearing.
Note the case as open, complete the record as far as possible and keep it. The question may be asked later, and an unfinished record is better than none.
Look at when and where they occur. Clusters at quarter-end or in a particular product suggest the target or incentive is pushing conduct.
Give Complaints and Conduct Cases a Clear Path
Tell us how cases are handled in your business today, and we will help you design routes that your people understand and your managers can follow.
Prefer to talk first? Call +91 80958 58589 or write to hello@gullyhr.com.
Book an Employee Relations Consultation
Tell us about your branches, your current procedures and the types of case you see.
The general method — what employee relations covers, the questions it answers and what an engagement produces — is the same whatever the sector, and is set out on the grievance and disciplinary process page. What is above is the part that differs for banking, financial services and insurance.
To run this in a system rather than on paper, see engagement and employee relations software.
Other HR topics for banking, financial services and insurance
Where to start
Most engagements begin with a review of how this runs in your business today, then a written process and the sequence to implement it.
See all HR topics for banking, financial services and insurance, or another industry.