Sustainable sales and marketing
For an insurance company, it is important to gain the trust of customers by ensuring that the products and services offered are clearly explained and transparently marketed.
The trust that customers have in the Sampo Group companies’ integrity is the foundation of the companies’ positive reputation. Therefore, paying attention to the risks associated with sales and marketing is important to Sampo Group. Such risks include inappropriate customer advice and product sales; lack of clarity in terms, prices, and fees; errors in claims handling; and errors in the complaint process. To minimise the risks and increase value for the customer, Sampo Group continuously works to develop and improve customer service, and sales and marketing practices.
Approach
The Sampo Group Code of Conduct sets the group level requirements for responsible sales and marketing practices. In addition, each Group company has adopted supplementary and more detailed policies, guidelines, and processes for their own purposes.
Sampo Group has controls in place to ensure that information provided to customers is accessible, relevant, and timely before a customer commits to any purchase, and that the company satisfies all regulatory and conduct obligations. The associated controls and measures are regularly assessed. Sampo Group assesses products regularly to ensure they remain appropriate.
To ensure compliance with laws, regulations, and internal policies, Sampo Group has continuous training programmes that develop personal conduct, and increase the competence of sales teams and other customer representatives. Customer feedback channels are also offered to make it easy for customers to provide feedback on the products and services, and to complain if they are dissatisfied.
Sampo Group aims to clearly inform customers of their complaint options, as well as to ensure a fair and transparent complaint process. In the case of a complaint, the priority is to discuss with the customer to find a solution that is satisfactory to both parties. If a consensus cannot be achieved, the customer is entitled to appeal to external complaints boards (ECBs) or similar, according to local practices in each operating country. In addition, as required by law, certain Sampo Group companies have internal customer representative functions that the customer can contact to submit a complaint. Regardless of the outcome of appeal cases, Sampo Group always analyses how it can improve its sales and marketing practices.
Goals and Ambitions
Sampo Group’s goal is to act in the best interests of the customers using sustainable sales and marketing practices.
Company-level information
Governance
If’s sales and marketing practices focus on meeting the demands and needs of customers and providing customers with the information necessary to make well-informed decisions. If’s Distribution Policy includes instructions on responsible sales and marketing practices. According to the policy, If and its distributors shall always act honestly, fairly, and professionally, with due care, and in accordance with the best interests of customers.
Employee training
The sales personnel involved in the distribution of insurance contracts continuously undergo comprehensive training in this area. Training is given according to annual plans on various topics such as insurance products, evaluation of risks and customer needs, legislation and guidelines, business ethics, and conflicts of interest. The training varies depending on the country and business area in question. If also provides training to its external distributors.
If continuously develops and improves the control mechanisms and follow-up routines regarding insurance product and service information, as well as marketing communications. If monitors that training requirements are fulfilled by external distributors and that products are sold to the right target group, in accordance with the company’s instructions.
Remuneration
In If’s remuneration structure, fixed compensation represents a sufficiently high proportion of the total remuneration to avoid employees being overly dependent on variable compensation and to ensure that they act in the best interests of customers. If does not remunerate or assess the performance of its employees in a way that conflicts with the duty to act in the best interests of customers. For example, there are no sales targets that could provide an incentive to recommend a particular insurance product to a customer when a different insurance product would better meet the customer’s needs. In addition, variable compensation programmes include a clause that gives the company the right to cancel, in whole or in part, the payment of variable compensation, if material, non-acceptable risk-taking or breaches of internal or external business rules have materialised.
Governance
Topdanmark wants its customers to have the right coverage to match their needs and wishes. The company is aware that this requires good and correct customer advice in sales and consulting situations, from competent employees.
Topdanmark has one central and several local compliance departments, ensuring that sales personnel meet quality requirements and follow agreed business procedures and applicable laws and regulations. There is a reporting system in place, which ensures that inappropriate situations are evaluated to improve customer service and avoid errors in the future.
Topdanmark provides customers with easily accessible information on products, price, and coverage. Therefore, customers can get an overview of what can be expected from the insurance policy. Furthermore, all text used in customer communication is always checked to ensure that the content is understandable to the average customer. Topdanmark improves product information continuously, based on customer feedback.
Employee training
Topdanmark ensures the competence of employees by providing them with adequate training. All salespeople are trained at the Insurance Academy, and new employees are trained in Topdanmark's business and sales procedures. In addition, employees continuously receive training in professional and interpersonal skills.
Remuneration
In Topdanmark ’s remuneration structure, fixed compensation represents a sufficiently high proportion of the total remuneration to avoid employees being overly dependent on variable compensation and to ensure that they act in the best interests of customers. Most of the employees in Topdanmark have fixed compensation and no variable compensation. Topdanmark does not remunerate or assess the performance of its employees in a way that conflicts with the duty to act in the best interests of customers. For example, there are no sales targets that could provide an incentive to recommend a particular insurance product to a customer when a different insurance product would better meet the customer’s needs. In addition, variable compensation programmes include a clause that gives the company the right to cancel the payment of variable compensation, if material, non-acceptable risk-taking or breaches of internal or external business rules have materialised.
Governance
Hastings’ customers can purchase their products digitally or via the contact centre. Regardless of the channel, customers are provided with clear and transparent information prior to purchasing a policy, with full disclosure provided on product coverage, coverage limitations, exclusions, excess levels, and any fees connected to the ongoing management of their insurance policy.
At Hastings, the existing sustainable sales and marketing conduct framework is based on the Financial Conduct Authority’s (FCA) six best interest outcomes. The company also assesses each product at least annually to ensure it remains appropriate.
Hastings has robust controls in place to ensure that information provided to customers is clearly accessible, relevant, and timely before a customer commits to any purchase, and the company satisfies all regulatory and conduct obligations. The associated controls and measures are regularly assessed and reported to Hastings’ executive and board committees, whereby Hastings focuses on customer conduct. This includes outcomes, experience, and value measures with a focus on customer vulnerability.
For those customers in vulnerable circumstances, Hastings has a well adopted user experience and user interface design process. Design principles are used to deliberately avoid using dark patterns (a digital term whereby designs are used on websites and in apps that make users do things they did not mean to, like buying or signing up for something). This eliminates any risk or intent to deceive customers.
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