Our Disclosures

How our culture aligns with the Fair Conduct Principle

• IAG’s culture is called The IAG Way. It includes our purpose ‘We make your world a safer place’, and mindset ‘Ready for anything’, and our values and behaviours are aligned to our customer promises. 

• Our customer promises include being honest and upfront, making things easier together, taking initiative and accountability, understanding our customers’ needs, and treating everyone fairly. 
  
  
• IAG’s Code of Ethics and Conduct outlines these promises, and all employees must read it during onboarding and review it annually. 

How we govern and maintain our Fair Conduct Programme 

• IAG NZ, a subsidiary of Insurance Australia Group Limited, operates under an independent New Zealand Board. 

• The IAG NZ Fair Conduct Programme is approved and overseen by the IAG NZ Board. 

• A range of internal governance forums support our Fair Conduct Programme and the fair treatment of our customers, including the IAG NZ Board, and board committees.

• Our customer governance team is responsible for maintaining oversight of the policies, processes, systems and controls in place that make up our Fair Conduct Programme. This team tracks how the Fair Conduct Programme changes, providing input to ensure that the overall integrity of the programme is maintained. 

• The customer governance team monitors Fair Conduct Programme reporting and the treatment of our customers, provides input on our response to any issues, and reports regularly on the outcomes of our monitoring and activities to senior management and the Board. 

How we meet our legal obligations to customers

• IAG NZ manages compliance with applicable laws and regulations by adhering to processes set out in our Regulatory Risk and Compliance Policy as well as our Compliance Risk Standard. 

• We administer compliance plans including obligation registers, training, and compliance assurance for various legislative regimes and licenses.  

• We conduct a regulatory scan to monitor the introduction of any new laws, regulations, and guidance from regulators.  

• Oversight and governance of legal compliance is provided through reporting to senior management and the Board.  

How we manage our products, services, and distribution methods 

• Our products are distributed through our employees, brokers, and other third-parties (including banks, agencies and employer schemes). 

• We run quality assurance activities over the engagements our employees and our offshore partners have with customers during sales, service and claims interactions. 

• Our products are designed and reviewed against our Product Policy and Product Design Principles (PDPs). These ensure fair customer outcomes, requiring that our products meet the needs of customers, provide value based on verifiable data, and are easy to understand. The PDPs are operationalised in processes that cover:
  
  
  • Creation of new products
    
    
  • Periodic reviews to ensure relevance to customer needs
    
    
  • Product changes
    
    
  • Decommissioning and discontinuance including identifying and managing any risks or impacts to customers 

How we identify, monitor, and manage conduct risks 

• Our board and senior management committees are obliged to prioritise conduct and culture outcomes, which includes a focus on customer outcomes.  

• The Board Risk Committee is accountable for oversight of risk, including organisational conduct and customer risk (OCCR). 

• Conduct risks are captured and managed in a centralised risk management system, which is used to provide reporting to senior management and the Board. 

• Our Conduct and Customer Risk Standard helps employees understand their roles and responsibilities in managing OCCR. The standard requires employees to consider the question ‘Should we do this?’ in the day-to-day performance of their roles rather than simply asking ‘Can we do this?’.  

• We have OCCR-specific training to ensure awareness of the requirements of the Standard, and our leaders use this knowledge to guide employees in their identification and management of conduct risks. 
  
  
• Our employees are expected to raise, address, and manage any conduct concerns, including conflicts of interest. 

How we oversee the conduct of our employees and suppliers

• We hire people with relevant skills, experience, and character for their role. Employees are supported where appropriate in their roles through:
  
  
  • Onboarding processes 
    
    
  • Role-based training
    
    
  • Training on our Code of Ethics & Conduct
    
    
  • Manager supervision
    
    
  • Quality Assurance monitoring
    
    
  • Personal and professional development plans
    
    
  • Recognition and reward programmes which reward good conduct and customer outcomes 

• Our employees are expected to conduct themselves in accordance with our compliance, risk and culture expectations. Employees are trained to use our tools and processes to call out conduct that does not meet our standards and are subject to performance management when their own conduct fails to meet expected standards. 
  
  
• We outsource some functions of our insurance businesses. Our outsourced functions are subject to contracts that require the supplier to comply with our Supplier Code of Conduct and other relevant policies. 

How we train our employees to support the Fair Conduct Programme

• We provide our employees with both compliance and role-specific training to give them the necessary skills to fulfil the requirements of their role. This includes training that reinforces standards and behaviours that align with our customer promises and the IAG Way.
   
• All employees are trained in the IAG Fair Conduct Programme. 

How we manage sales incentives for employees and third parties who sell IAG products 

• IAG has a remuneration framework which requires that employee remuneration aligns with customer interests.  

• None of our employees and their immediate managers who are involved in the sale of our products have performance goals with sales incentives tied to volume / value targets. 
  
  
• We distribute products through brokers and partners. Our internal standards prohibit variable remuneration arrangements that contravene incentives regulations.  

How we communicate with IAG customers

• We engage and communicate with customers by phone, letter, email, digital platforms, social media, our websites, and in face-to-face conversations.  

• Our internal communications requirements govern all forms of customer communication including policy documentation, general information about our products and services, marketing, and advertising. 

• Quality assurance is applied to engagements with customers, while all communications templates, online knowledge content, advertising, and marketing material is subject to legal and communications review.
  
  
• Communications between our people and our customers are recorded in our systems. 

How we manage claims

• Internal policies and processes require consideration of the diverse needs of the customer, including when determining the validity of claims, appropriate customer communication and standards of professionalism in the carrying out of claims practices.  

• Our policies also set out minimum requirements for assisting customers experiencing vulnerability, managing complaints, responding to major events and considering ex gratia payments to customers when it is fair and appropriate to do so.
  
  
• Our processes require regular communication with customers for the duration of their claim, and compliance is reported to senior management. 

How we handle complaints and support customers experiencing vulnerability

• Employees use our complaints management system to lodge and manage complaints about our products and services.  

• All customer-facing employees are trained in managing complaints in accordance with our standards and complaints process. Any complaints that cannot be resolved are escalated and managed to conclusion by our internal customer resolution team. 

• Complaints provide useful insights into how we can better support our customers and improve our conduct. Complaints reporting is provided to senior management and the Board.
  
  
• We know that customers can experience vulnerability and require extra care. Customer-facing staff are trained to recognise customers experiencing vulnerability and refer customers to our specialist care teams within sales and claims who provide additional support. 

How we continuously improve

• We take lessons from customer interactions and use our internal reporting to identify opportunities to learn and improve outcomes for our customers.
  
  
• We have policies and processes that govern our responses, where instances of poor customer outcomes have been identified.