By Tracey Ward, Head of Marketing & Business Development, Generali UK Employee Benefits
The new Consumer Duty rules, introduced last year, enhanced the Treating Customers Fairly (TCF) requirements by placing emphasis on achieving, and monitoring, good customer outcomes. The Consumer Duty rules might not always apply to providers of employee benefits, but the higher standards of consumer protection associated with these rules arguably make sense whatever the product.
So, when assessing providers, it’s worth examining what they’re doing through a Consumer Duty lens, to ensure they’re: being open and honest; avoiding causing foreseeable harm; and supporting their members with products and services that are right for them. A big part of this is the need to pay particular attention to the needs of vulnerable members; ensuring their outcomes are as good as those for everyone else.
If you work in HR, it’s likely that you and Consumer Duty haven’t crossed paths. That’s because it applies to financial services firms that sell products direct, or via a broker, to individual consumers and SMEs.
It’s about the insured individual after all!
Ensuring our individual members get the kind of service and support their employer (our client) expects, is as important for group insurers as it is for those that sell direct to consumers. After all, if the individual employee is happy, everyone is happy!
It’s for this reason that, over the past year, we have proactively established our own Consumer Duty governance, with champions at every level of the organisation.
We mapped out the full customer journey, examining all risks and key performance indicators for various aspects. This included an assessment of all our member documentation, by individuals with and, crucially, without any knowledge of insurance. It also involved an examination of claims and complaint trends, timeliness of handling and service standards.
Customer outcome assessments are now carried out on a quarterly basis by various people across the business, and reported to the governance committee, with a view to identifying potential problems before they happen.
In short, this is a commitment by us to an ongoing assessment of what our members should be getting, in terms of:
- The support they need, when they need it.
- Communications they understand.
- Products and services that meet their needs and offer fair value.
In addition to the consumer duty work we also undertake annual product assessments to ensure that our products meet the needs of the target market and offer fair value. Management information is also monitored on a regular basis to ensure that this continues to be met. As part of fair value assessments, we examine things like exclusions, claims data, complaints data, whether the products are being distributed correctly and whether commission is appropriate.
Adherence to the Consumer Duty rules makes our commitment to members an ongoing business-led task. Not only a compliance-led task. Or a once-and-done task. This cross-functional, ongoing business led ownership is really important.
It helps ensure that everything is more outcomes and evidence driven. So, we can evidence, for example, that we deliver a great claims experience, as opposed to only basing this on number of complaints and TCF assessments of our complaints handling.
In short, the Consumer Duty simply makes sense. And it’s worth asking your provider what they’re doing in this regard the next time you’re carrying out a review.
Disclaimer:All information contained herein represents the views and opinions of the author as at the date of writing and is provided for general information only. Nothing herein constitutes or is intended to constitute financial or other form of advice and no individual should rely upon the information provided in making a specific investment decision without first seeking independent professional advice.
