Complaints Management Policy:

GB Life Luxembourg S.A.’s aim (hereinafter the “Company”) is to offer contracts that fully meet the expectations and needs of its customers. As such, the Company has implemented a complaints management and complaint handling process in order to provide an individualized and adequate response to each of its customers’ concerns.

The current complaints management policy is to inform you on how to submit your complaint and how it will be managed by the Company (process, deadlines, information and steps).

What the term “complaint” exactly means:

A complaint is defined as a complaint or a claim made to a professional to obtain recognition of a right or redress a prejudice.

The complaint is to be distinguished from the simple request for the performance of the contract or the request to provide the service, as well as simple requests for information or explanations on the contract.

The Company has set up an electronic register centralizing the complaints received in order to ensure the complaint handling process.

How is my complaint handled by the Company?

The complaint may be submitted in writing by post to the address of the Company (3 rue Jean Piret, L-2350 Luxembourg). It may be drawn up in French, in English or in the language of the complainant’s insurance contract and includes at least the contract number and an accurate description of the facts giving rise to the complaint.

The Company undertakes to acknowledge receipt in writing of the complaint within a period not exceeding 10 working days from receipt of the complaint, unless the response itself is provided to the complainant within that period.

The letter acknowledging receipt of the complaint will inform the complainant of:

  • The type of information to be provided by the complainant,
  • The identity and contact details of the person/department in charge of complaints handling process, and
  • An indicative timeline for complaints handling process.

As part of effective complaints management, the Company makes every effort to gather and examine all relevant evidence and information and explain in plain and simple language, the issue and a foreseeable solution.

The Company undertakes to provide to each complainant with a response to his complaint without unnecessary delay and in all cases within a period of 30 days as from the date of receipt of his complaint, except where the complexity of the request requires an extensive analysis, in which case the Company will indicate the causes of the delay and the foreseeable date of its response.

Can I dispute the Company’s position to my complaint?

When the complainant considers that the reply to his/her complaint was not satisfactory, he/she may inform the professional in writing within 30 days as from the date when the Company s ‘response was sent. Otherwise, the Company shall be entitled to consider the complaint as completed.

When the complainant has informed the Company in writing of the reason of his/her dissatisfaction, the Company will provide the following information to the complainant:

  • The option to escalate the complaint to the management level or to the appointed delegate of the Company,
  • The contact details of the person in charge of the second analysis,
  • The possibility of submitting a request for an out-of-court resolution of disputes to the commissariat aux assurances (“CAA”) in accordance with the procedure described below.

Finally, the Company recalls that this complaint handling process does not prevent the complainant from his/her right to take legal action or pursue a mediation.

If the customer is still not satisfied with the Company’s handling of the complaint, he/she may use the alternative out-of-court resolution of disputes with CAA.

How to use the out-of-court resolution of disputes in front of the CAA?

The role of the CAA is to facilitate the handling of complaints against professionals without going through a legal proceeding. The procedure is not a mediation procedure within the meaning of the Law of 24 February 2012 introducing mediation in civil and commercial matters and the intervention of the CAA is subject to the principles of impartiality, independence, transparency, competence, efficiency and fairness.

CAA’s reasoned conclusions are not binding upon the parties.


The opening of the procedure is subject to the condition that the complaint has been previously processed at the level of the Company and that the complainant has not received a response or a satisfactory reply within the period of 90 days as from the date he/she sent his complaint.

Then the complainant may refer to the CAA within one year from the date on which he lodged the first time his/her complaint with the Company.


The application must be submitted in writing to the CAA, either by post at the address of the CAA (7 boulevard Jospeh II, L-1840 Luxembourg), either by e-mail at or via the electronic form freely downloadable on the website

The application may be drawn up in Luxembourgish, German, French or English languages and must be substantiated and accompanied by the following documents:

  • A detailed and chronological explanation of the facts at the origin of the complaint and the steps already taken,
  • A copy of the complaint filed with the professional,
  • Either a copy of the response to the complaint, or confirmation by the complainant that he/she has not received a response within 90 days period as from the date he/she sent his complaint,
  • A copy of the general conditions and specific conditions of the insurance contract and any amendments,
  • The applicant’s statement that he/she has not submitted his complaint to the court, arbitrator or to other alternative dispute resolution organization, in Luxembourg or abroad,
  • The applicant’s agreement regarding the terms and conditions of the intervention of the CAA as an out – of – court resolution body,
  • The applicant’s express authorization to the CAA to provide his/her application (including attachments) and any future correspondence or information to the professional who is the subject of the complaint,
  • If a person represents or assists the complainant, a document attesting his or her power of representation, and
  • A copy of a valid ID card of the applicant.



The CAA acknowledges receipt of the application within a maximum of 10 working days of the receipt of the application unless the response itself is provided to the applicant within that period.

The CAA sends within 3 weeks a written confirmation to the applicant when the application is considered admissible and complete or considered not admissible.

The CAA forwards a copy of the application for position to be taken by the professional within a period of 30 days as from the date the applicant lodges his application unless the CAA considers that the application is manifestly unfounded.

After analysis of the case by the CAA, the parties receive a letter of conclusion containing the reasons of the position taken and, where appropriate, an invitation to settle the dispute to that effect and to inform the CAA of the action taken.

The CAA communicates its reasoned conclusions within 90 days of the confirmation of the admissibility of the complainant’s application. There are not binding so that the parties retain the freedom to accept or refuse to follow them.

Where the reasoned conclusions of the CAA require an extension of the 90 days period, the CAA inform the parties of the additional period required.


The parties to the proceedings in front of the CAA undertake to keep confidential the documents drawn up, communications made and statements collected during the proceedings. The persons responsible for handling applications for out-of-court resolution of complaints within the CAA are bound by professional secrecy as referred to in Article 7 of the amended law of 7 December 2015 on the insurance sector.

For more information regarding the out-of-court resolution of complaints with the CAA, the Complainant is invited to visit the CAA website

Marc Stevens

Chief Marketing & Distribution Officer (CMDO)

Marc Stevens has extended experience in international insurance industry. Before taking on the role of Director of Marketing and Distribution at GB Life Luxembourg in November 2018, he worked for ABB Insurances and OHRA Leven (Delta Lloyd Life) where he was Commercial Director. Following that, he was General Manager at VITIS LIFE and then CEO of OneLife Luxembourg. He is a visiting professor for the Master’s in Personal Financial Planning course at the Management School of the University of Antwerp. Marc holds a Master’s degree in criminology from the Catholic University of Louvain and a postgraduate diploma in Marketing from the Business School of the University of Antwerp.

José Bustillo

Chief Operations Officer (COO)

José Bustillo has a long-standing experience in managing and auditing complex and large projects in back-office operations environments. He joined GB Life Luxembourg in 2017 as Chief Operation Officer after more than 30 years of experience in the financial industry among others with Euroclear. Prior to joining GB Life Management Team, José was a partner with a risk management specialized consultancy firm, now part of McKinsey & Company. His main focus was on Solvency II. José holds a Civil Engineering degree from the Université Libre de Bruxelles.

Gaëlle Leclaire

Chief Risk & Compliance Officer

Gaëlle Leclaire has 20 years of experience in the life insurance sector. She started her career as a financial auditor in France before moving to Luxembourg. She has previously worked for Mazars, PWC and ABN AMRO Life S.A.. She joined GB Life Luxembourg in 2008 and joined the Board in 2009 as CFO. She took over the position of COO in 2015, where she was also responsible for Product Management. In 2017, she took over the position of Chief Legal and Compliance Officer within GB Life Luxembourg. Gaëlle is graduated from a Business School and has professional certification in Accountancy and Finance.

Will Romero

Member of the Board

Will has served in leadership positions at Financial Guaranty, Benfield, Swiss RE, Ernst & Young and New York Life. Most recently, he created Factor Re, a low cost and efficient financing vehicle for the embedded value in life insurance blocks. Will holds a B.A. with honors from Yale University, a J.D. from the University of Colorado, and an LL.M. in Taxation from New York University.

Matteo Castelvetri

Member of the Board

Matteo spent 19 years in Investment Banking at Morgan Stanley and Goldman Sachs. As a Managing Director of Morgan Stanley’s Financial Institution Group, he led the European Insurance effort and held primary coverage responsibility for several European large cap insurers. He has advised on over 50 transactions and has originated and executed some of the most prominent insurance M&A events, restructuring and IPOs in Europe. Matteo started his career at Goldman Sachs as a government bond and distressed debt investor first and then as an advisor to banks and insurers. He received a summa cum laude Bachelor Degree in Economics from Bocconi University in Milan and also holds a Bachelor Degree in Classical Guitar.

Victor Rod

Chairman of the Board

Victor Rod earned a law degree at University of Nancy (France) in 1973. After a short period as an attorney at the Luxembourg bar, he served as secretary general of the Luxembourg insurance companies association (ACA).

In 1980 he was appointed first full time director of the Luxembourg insurance supervisory authority (Commissariat aux assurances). He has been the longest serving head of an insurance supervisor in Europe until his retirement on 31.12.2014

Victor served as Alternate Chair of the European Insurance and Occupational Pension Authority (EIOPA) headquartered in Frankfurt since its inception until his retirement.(2010 – 2014)

He was also Luxembourg’s delegate at European Insurance and Occupational Pension Committee (EIOPC) in Brussels and a member of the executive committee of the global standard setter in insurance matters International Association of Insurance Supervisors (IAIS) in Basel.

Victor served as a chairman of a Luxembourg Bank for 25 years. In addition to serving as chairman and independent director of GBLife, Victor is sitting on the board of a large domestic retail insurance company and he has a 20 years experience as a non-executive board member of World’s largest satellite operator.

Since 2015, Victor serves as Of Counsel with Luxembourg’s largest independent law firm Arendt & Medernach (A & M) where he mainly advises on insurance and reinsurance legal, regulatory and technical matters.

Christophe Hucque

Chief Finance Officer (CFO)

Christophe Hucque has an extensive experience in the insurance domain. Christophe joined GB Life Luxembourg (formerly ING Life Luxembourg) in 2000 as Actuary. Since 2006, he has covered several leading position within GB Life Luxembourg. He joined the Management Team in 2006 as CFO/CRO. Between 2007 and 2009, he combined the CFO position for both ING Life Luxembourg and ING Variable Annuities Europe (The Hague, NL), dealing with the Europe-wide roll-out of the Variable Annuities product suite. Christophe moved to the COO position in 2009 where he was also responsible for Product Management and the commercial relationship with ING Bank. He has been back in the CFO position since 2015, also responsible for Risk between 2015 and 2017. Christophe holds several degrees in Mathematics and in Actuarial Sciences.

Pieter Coopmans

Chief Executive Officer (CEO), GB Life Luxembourg

Pieter Coopmans has over 20 years of experience in the insurance and banking industries, in different leadership positions. Before joining GB Life Luxembourg in 2012 as Chief Executive Officer and Dirigeant Agréé, he held management/executive roles in leading financial service providers such as NN Group, Zurich Financial Services, SNS Reaal and ING Group. Pieter has played a key role in the disentanglement and rebranding process of GB Life from the ING/NN Group and the repositioning of the company in the cross border life insurance space. Under his responsibility, the leadership team prepared and executed the sale of GB Life to an affiliate of Global Bankers Insurance Group in 2017. Pieter holds a Bachelor in BA from European University and a Master in BA from Nyenrode University in Breukelen.