Fair Conduct Programme

FCP Components

Under the FCP, Hollard has developed a programme of policies, processes, systems and controls to support the Fair Conduct Principle. This includes the following core FCP components.

Hollard’s governance structure

Hollard’s governance structure underpins the Hollard FCP. The Hollard Board, Board Committees and Management Governance Groups oversee and are responsible for ensuring the fair treatment of Hollard customers.

Hollard’s Risk Management Framework

Hollard maintains a Risk Management Framework which provides a structure for identifying, monitoring and managing material conduct risks.

Hollard’s governance & compliance frameworks and policies

Hollard maintains governance & compliance frameworks and policies, to ensure we meet the Fair Conduct Principle. This includes with respect to the treatment of vulnerable customers. Hollard seeks to ensure fair treatment of all vulnerable customers, by providing extra care and support to any customers experiencing vulnerability.

Hollard’s Fair Conduct Statement

• Hollard has developed a Fair Conduct Statement, which defines and directs the delivery of the Outcomes, by establishing a set of ‘Standards’ that the Hollard Board mandates must be delivered at all stages of the product lifecycle.
• These Standards cover the following core areas:
  • performance metrics
  • remuneration
  • product development and governance
  • product marketing
  • sales and distribution
  • product literature and fulfilment
  • policy administration
  • claims handling, and
  • complaints handling.

Hollard’s Compliance Obligations Register

Hollard maintains a Compliance Obligations Register, mapping business capabilities against compliance requirements, to ensure we meet all legal obligations to consumers, including under CoFI and other relevant laws.

Hollard’s partner agreements and risk assessments

• Hollard appoints and authorises our distribution partners to perform certain insurance activities on our behalf. Delegations are set out in relevant Intermediary/Distribution Agreements, which also articulate Hollard’s conduct expectations.
• Hollard also undertakes partner risk assessments to ensure appropriate and proportionate assurance and oversight of our distribution partners from a conduct perspective.

Hollard’s Fair Conduct Compliance Guidelines for partners

Hollard has developed Fair Conduct Compliance Guidelines which provide guidance to our distribution partners on conduct compliance requirements applicable to the activities they perform.

Partner policies, processes, systems & controls

Hollard’s distribution partners must ensure their policies, processes, systems and controls adhere to contractual requirements and the abovementioned Fair Conduct Compliance Guidelines.

Hollard’s Fair Conduct Programme Assurance Plan

Hollard maintains an evidence-based Assurance Plan, which includes data-based assurance (via a Fair Conduct Risk Dashboard comprising customer value metrics) and technical/thematic reviews.