Health Matters

Our responsibilities under the

Financial Services Authority

Health Matters is continuing to embed, within its workforce, the importance of the Financial Services Authority. We are adopting new procedures to further comply with the directives and guidelines laid out by the FSA.

Most recently we have introduced a new training and development programme for our staff and we monitor and record all employees training. All new recruits are put through an intensive training course and have a mentoring programme for the first few months after joining us the business.

During last year we implemented a colleague ‘signoff’ system whereby upon completing a scheme renewal or after the acquisition of a new client all files need to be checked and signed off by a colleague prior to the file being closed.

 

Treating Customers Fairly

Self Assessment

Treating Customers Fairly is at the heart of all our operations, from the products we offer our clients through to the care we take to deliver on our post contract promises, and every aspect of our activities is constantly viewed from the client’s standpoint. When assessing how we are meeting the requirements of treating customers fairly the following questions have been asked and answered.

 

Management Responsibilities

1: How have we included TCF into the way we run our business and our firm’s values?

• All staff have been provided with a copy of the FSA’s Principles for Business and Approved Persons with a copy of the Approved Persons Principles and Code of Practice. These clearly set out the standards of behaviour expected and demanded of staff, including acting with integrity, acting with due care, skill and diligence, being fair, clear and not misleading in all our communications and treating customers fairly.
• At recruitment the firm’s values and ethos is explained to potential recruits
and their acceptance of and ability to works to these standards is assessed
• All staff have been trained on and understand the need to fully and fairly investigate and sympathetically address all client complaints
• Staff are not incentivised on the basis of volume over quality
• The firm operates a performance development programme which focuses on behaviours that will help individuals and the firm achieve their goals, both personal and business

2: How do we assess whether we are treating our customers fairly, and how is this reported to management?

• Information on renewals, lapses, cancellations, complaints and referrals is collected and reviewed by the Principal each quarter
• An analysis of potential conflicts of interest is carried out each quarter
• An on-going random of client files is conducted to ensure that ICOB rules continue to be complied with and outcomes reported to senior management each quarter

3: What gaps are there against TCF and how are these being filled?

• The firm has reviewed all its communications and promotions to satisfy itself that they are clear, fair and not misleading
• File audits have been conducted to ensure that the ICOB rules are being complied with and suitable advice has been provided in every case
• We have reviewed our remuneration and rewards system to ensure there is neither bias not inappropriate inducement
• The firm has confirmed that management receives the appropriate information to allow it to monitor the relevant TCF measures
• Contract certainty issues are being monitored to determine whether or not the firm can consistently meet the five day and thirty day communication requirements

4: What changes could we make to our organisational structure or to services/products offered to support TCF?

• The firm’s organisational structure has been reviewed to confirm it’s appropriateness in delivering TCF
• A review of services and products offered has been undertaken. No changes are deemed necessary

5: How are we engaging, motivating and training all of our staff on TCF?

• Relevant FSA and industry articles will be circulated to all staff
• Staff invited to offer suggestions on how the firm’s TCF experience can be improved

6: How does we measure the understanding of TCF by staff?

• TCF understanding explored during the annual performance appraisal
• Observations, case studies and file checks are carried out on a regular and on-going basis.
 

7: How does management indicate their support of TCF?

• The firm’s senior management is committed to operating compliantly and encourages a culture of putting the needs of clients first
• Senior management meetings have TCF as a standing item on the agenda

8: How is the requirement to treat customers fairly included in the performance measures, objective setting and rewards for staff?

• The firm’s KPIs include customer care and satisfaction and the absence of complaints in addition to volume of work and profitability
• The firm has clear objectives regarding time scales for dealing with correspondence from customers, Insurers and other stakeholders

9: How does our record keeping enable us to demonstrate whether we have met our TCF obligations? How is that information shared with others in the firm?

Information on the following is reviewed quarterly by senior management:
 

• Renewals/lapses/cancellations analysis
• Claims analysis
• Complaints log
• Compliments log
• File audits

 

Sales & Marketing

10: How do we ensure we understand the product we are offering to our customers?

• Attendance on Insurers training courses when available
• Policy documents are provided to staff who are required to read, understand and be able to explain to them clients
• Individual coaching, where appropriate, is provided by supervisors
• In-house training sessions are conducted

11: How are our promotions targeted to make sure they are aimed at the right customers?

• Financial promotions, both hard copy and website, are targeted at appropriate potential customers

12: What process do we have for approving a financial promotion?

• All financial promotions are submitted for approval by the Managing Director and clearance by RWA Compliance Services prior to printing/publication
• The firm uses the Financial Promotions Checklist provided by RWA Compliance Services

13: How are customer queries and complaints used to improve or stop financial promotions?

• “Customers” queries or complaints regarding the firm’s financial promotions would be reviewed by senior management and responded to accordingly

14: How do sales people ensure customers understand the risk and limitations of a product as well as its benefits?

• Advisers use their skill and experience to accurately determine the customer’s demands and needs and, when these cannot be fully met, the risks and limitations of the contract offered would be fully explained
• Customers are also provided with the Insurers Summary of cover which sets out the details of the cover provided

15: What processes and checks are in place to ensure records are kept of discussion and communication with customers?

• All conversations and written communications are recorded on our CRM software
 

16: How have our training & Competence requirements developed to implement TCF?

• All staff have received a copy of the firm’s TCF Self Assessment document
• TCF issues are reviewed with staff during the performance appraisal process

17: What steps do we take to understand, manage and, where appropriate, fulfil our customers’ expectations of our firm after the point of sale?

• Our TOBA clearly sets out the range and standards of service offered by the firm
• All business is transacted on the basis of a detailed quotation/fact finding process when customers’ demands and needs are clearly identified and agreed
• Customers are encouraged to contact us with any query or concern during the period of the contract
• Staff are encouraged to assist customers wherever possible, whether it be providing guidance, handling claims, dealing with MTAs etc.
 

18: What do we do to ensure that service issues and claims are processed in a timely manner?

• FSA renewal time frames for commercial customers met and monitored
• All claims correspondence is dealt with on day of receipt
• Fax and email used where this would improve communication with customers
• Diary used to monitor and chase up progress of policy issue, claims and complaints

19: How do we ensure that an effective flow of information to customers is maintained and recorded (including verbal discussions)?

• Written documents are forwarded to our clients on a regular basis informing them of changes within the market
• At each renewal a new market review and report is prepared

20: How do we identify trends and remedy issues arising from our handling of customer complaints that may indicate a wider or recurring problem?

• All complaints are recorded in the Complaints log and then reviewed by senior management on a quarterly basis to look for trends or recurring issues

21: What targets do we set for people handling complaints?

• Where possible complaints are dealt with and resolved on the same day
• All staff are aware of the complaints handling timeframes
• Staff are encouraged to view complaints positively and record expressions of dissatisfaction accurately
• Senior management review the complaints log on a quarterly basis
• Staff are encouraged to communicate with customers at every stage to keep them informed of developments

22: How are lessons from complaints shared between different business areas?

• All staff are aware of the Complaints Procedures
• If trends or training issues are identified by senior management this would be communicated to relevant staff, and appropriate measures implemented

23: What is done to ensure the outcome offered to customers is full and fair?

• Senior management are concerned to ensure the best possible outcomes for customers and will become involved when appropriate
• Settlement figures, when known, are checked with policy cover limits and excesses
• The complaints procedures are clearly explained in the firm’s TOBA which is provided to clients at inception and renewal