Customer Protection Policy

Transcription

1 Customer Protection Policy 1. Purpose of this policy The purpose of this policy is to ensure that PPSI customers are treated fairly and are adequately protected when dealing with PPSI. PPSI will endeavour to treat all customers equally irrespective of age, gender, profession, race, adviser, relationship with PPSI boards and other key PPSI stakeholders, location, duration of policy, size of policy and Profit Share Account, and duration of membership. It should be noted, however, that by design, PPS Investments investors who are not PPS members, i.e. who have an OPN investment will not be able to share in the profits of PPS Investments, as these profits are distributed through PPS Holdings Trust to PPS members only. PPSI Group adopts the principles of Treating Customers Fairly ("TCF") and aims to achieve the outcomes as determined by the Financial Services Board throughout the product life cycle of every customer and investor at PPSI. The policy aims to achieve: a. Improved customer confidence b. The supply of appropriate products and services to customers; and c. Enhanced transparency and discipline at PPSI. 2. Scope of this policy This framework applies to all entities in the PPSI Group that are subject to TCF. PPSI includes PPS Investments and all its subsidiaries. Any reference to "PPSI" in this document means any subsidiary and associate. In implementing the framework, PPSI will determine where the framework applies to its subsidiaries and associates. 3. Customer Protection principles PPSI seeks to ensure that customer fairness is demonstrably delivered through the implementation of the following the key principles: I. Culture Values, strategies and initiatives consider fair customer outcomes during formulation, implementation and on-going maintenance. Explicitly acknowledge and evaluate fair customer outcomes in records such as relevant minutes, project plans and risk registers. Ensure that all stakeholders are aware of customer fairness and the desired outcomes. PPS Investments Customer Protection Policy Page 1 of 5

2 II. Product Products offered comply with the Product Development Policy that includes TCF considerations and addresses: Market segment appropriateness Customer input in product design Product monitoring to ensure that product behaves and is sold to target market. III. Information All communications comply with the Communication Policy that includes TCF considerations and addresses: Tone, clarity and language for communication General standards regarding format and structure Communication triggers and monitoring Communication approvals and distribution Communication content IV. Advice Appropriate due diligence are performed on all Intermediaries who apply for contracts to provide advice and intermediary services to PPSI investors. All contracted Intermediaries must receive appropriate training to provide advice and intermediary services for PPS and OPN products. Remuneration must as far as possible support the TCF outcomes in this regard. V. Delivery Service interventions with customers treat customers as they expected by applying the PPSI value system. Monitor and evaluate all feedback to ensure fairness and meeting reasonable expectation of the industry service standards, or the PPSI service standards, whichever favours the customer. Any TCF related risk identified on risk registers must be treated according to the risk management framework and this policy s principles. VI. Post-sale PPSI must facilitate sound support for customers to manage the requirements of their policy so that they are not unreasonably prejudiced by any policy provision. Reasonable and communicated requirements for submitting claims and compliance must be available. PPSI supports customer redress, see Annexure 1. PPSI must ensure that the customer controls on-going maintenance of their investment with PPSI and should facilitate reasonable requests for changes to a product or product provider. 4. Accountabilities and Responsibilities for customer protection The roles and responsibilities associated with customer protection is the following: I. Board of Directors or Trustees (where applicable) Approve the Customer Protection Policy on an annual basis and ensure adherence to the Customer Protection Policy and TCF principles. PPS Investments Customer Protection Policy Page 2 of 5

3 II. Social & Ethics Committee Ensure that the implementation of TCF at PPSI reflects the values of PPSI and that the TCF outcomes are routinely monitored and managed in the usual course of business. III. Risk and Audit Committee Ensure that management treats any risks of not achieving the TCF outcomes to within the accepted risk appetite of the PPSI board. Consider and approve any redress recommendations from the Executive Committee. IV. Executive Committee Must identify all Management Information (MI) to evaluate and demonstrate the achievement of the principles and TCF outcomes, as well as identify the necessary structures to implement initiatives to effectively treat the risks to achieving the outcomes. Determine if redress is required and make appropriate recommendations to Risk and Audit Committee. Ensure that management implement initiatives identified. Ensure that customer fairness outputs are included in the performance contracts of managements of staff management and that performance are assessed routinely against such contracts during performance reviews. V. Management Must identify the TCF outcomes in the processes and outputs under their management both direct and indirect and ensure that the MI used to deliver these outputs is enhanced to highlight the TCF aspects. Ensure that staff is informed of customer fairness and relevant procedures. Ensure that staff performance contracts include customer fairness outputs and that performance is assessed routinely against such outcomes during performance reviews. VI. Staff Staff must adhere to this policy, the PPSI values and all applicable procedures and standards. Ensure that any examples of unfair customer treatment are brought to the attention of management or relevant structures in business set up for this purpose. 5. Policy Administration Target audience: PPSI Group Executive Committee and Management PPS Investments Customer Protection Policy Page 3 of 5

4 Approved and Issued by: PPSI Board of Directors Person responsible for Policy administration: Emma Leigh, PPSI Executive: Finance and Governance Version: 1.0 Valid from: 1 July 2014 Replaces: None Next update required: June Annexure 1 Redress Customer redress will be considered on a group basis for active members should PPSI discover that a class or group of customers suffered similar unfair treatment or when a grievance is lodged to remedy any undesirable or unfair situation. PPSI will endeavour to treat all members equally and corrections made to an investor should be applied equally to other similar situation investors (irrespective of whether they are aware of issues or not and irrespective of the cost to PPSI of remedying the error). i. Aim of redress Wherever possible and practicable, members detrimentally affected by unfair treatment should be returned to the position they would have been in if the failure had not occurred. ii. Scope of redress Redress will be proportional to the degree and nature of the failure and hardship or injustice suffered. iii. Determine the need for redress and viable options Regular monitoring of the PPSI Feedback Framework (including customer complaints) will be used to identify complaints that may qualify for redress. The extent of the prejudice will be determined for cases identified and assessment will be made if the matter qualified for redress. The following factors will be considered: Any legal obligation imposed on PPSI by way of the operation of law or any contract Non-adherence to this PPSI Customer Protection Policy The effective dates of the Policies of Insurance in question PPS Investments Customer Protection Policy Page 4 of 5

5 iv. Redress for the complainant may include some or all of the following: An explanation Practical action to mitigate any detriment Where possible, reimbursement of actual loss and / or costs incurred Reasonable compensation for time and trouble taken by complainant (where relevant) or as a tangible expression of regret Other appropriate action suggested by the complainant or organisation v. Redress should: Be fair and reasonable Take into account the wishes and needs of the complainant (where relevant) Be procedurally fair Be provided in a timely manner Provide, as far as possible, a comprehensive resolution of the issue remembering that it may apply not only to the complainant but others who have suffered as a result of the same failure. vi. Redress may be limited by: The time elapsed since the problem occurred The degree to which the complainant had a contributory responsibility for the failure and detriment suffered The capability of the organisation to comply PPS Investments Customer Protection Policy Page 5 of 5