Operating as a separate business unit within the Financial Ombudsman Service (FOS) Australia, the Code Compliance and Monitoring Team plays a vital role in supporting the Insurance Brokers Code Compliance Committee to monitor professional standards in the world of broking.
The team investigates consumer complaints about possible Code of Practice breaches, as well as working with Code subscribers to remedy issues, and referring matters to the Committee to assess whether the Code has been breached.
This all means the team’s General Manager has an eagle-eye view of the issues that can get brokers into strife.
Insurance & Risk Professional: You’ve been working in dispute resolution for 15 years now. What is your current focus in the new role?
Sally Davis: My main focus is to make sure I get to know all the various stakeholders, because with all committees there are a lot of stakeholders. There is also a strong focus on how we can raise awareness of the codes of practice.
The purpose of a code of practice is to enhance the trust between the consumer and the service provider. But upholding a code isn’t just compliance. To me, it’s a point of difference. It represents a higher level of service for a consumer, a higher standard of professional conduct and just generally, practice standards and ethical behaviours.
IRP: Would you say there’s more to be done to raise the awareness of what the Code means for consumers?
SD: I think there’s always more to be done. One of the first functions that I attended in my new role was the NIBA Convention, and I really enjoyed hearing Dallas Booth in particular, addressing the Code and raising awareness of it and how it can be used in that way.
You can’t be complacent just because the code exists. It isn’t necessarily enough. Certainly, the committee’s very mindful of dealing with NIBA always in a proactive sense in trying to raise awareness of the code.
IRP: Having a ringside view in the operation of the Code, what advice would you have for brokers to keep them on the right side of it?
SD: One of the things that arises so often is general miscommunication. That can occur on so many levels for a broker, which makes it so important to take really good notes and records at all times.
That can assist in the dispute resolution process generally, but of course a lot that a broker does can be verbal communication, in which case they need to remember that they are the professional in the relationship; they should be the one who putting it in writing.
It doesn’t need to be formal, but it can be extremely valuable to have some methodology for putting something in writing to ensure that communication is clear.
Another one is not to act as a post office; for example, when receiving a renewal, not just putting it in the mail and passing it on, but exercising the positive obligation that exists to spell out to the client the terms of the policy, in particular, any exclusions.
In the current climate, where there’s more emphasis on electronic communication, that’s important.
A third thing is fees. It ties in well with my first two points. Clear, precise and up-front communication about fees can save a lot of heartache later on.
The other is not being afraid to get a complaint from a consumer and deal with that complaint, rather than sweeping it under the carpet or implying that a business never has any
issues of that nature. That’s unlikely to be the case because that’s often just human nature.
I don’t think mistakes are entirely avoidable, particularly in larger organisations, provided that a broker has the proper procedures in place.
Everyone in the organisation – from the receptionist to the CEO – needs to be on board with a culture where complaints are taken on board, and processes are put in place to rectify and remedy them. It’s about continuous improvement. It’s not about never receiving a complaint – that’s not going to happen. It’s about how you deal with them.
IRP: From your vantage point, have you noticed any trends for the way professionalism is moving in brokering?
SD: In 2012 we conducted an own-motion inquiry into a hundred broker websites, which we followed up last year and saw a large improvement in the disclosure of what their internal and external dispute resolution processes were.
That’s just an example of some of the ways that the code has been adopted and used to improve services and that continuous improvement element that I talked about, being undertaken. In terms of overall trends, you can’t get away from the fact that ASIC, for example, has increased its focus dramatically in talking about issues like trust and culture and what consumers want.
I think brokers are well placed to take advantage of the code and of the good practice to encourage that consumer trust and confidence and just general engagement with their customer base. That’s not going to just happen automatically, so they have to just take continually thinking of it as a work in progress.