Motor Dealers Manual. Individual Distributor / Sole Trader / Locum

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1 Motor Dealers Manual Individual Distributor / Sole Trader / Locum

2 Document Control Version Number Description of Change Date approved 1.0 Initial Draft May Final June Structural and organisational changes and reference to Motor Dealer Operations Manager April Update to FOS name and phone number March Motor Dealers Manual - Individual Distributor / Sole Trader / Locum

3 Contents Defined Terms 4 What is this manual about? 5 Sales Procedures Flow Chart 6 Overview of sales procedure 7 Complaints 9 Incident Reporting 11 Supervision and Monitoring 12 Procedure for change of details 13 Paperwork 14 Distributor Disclosure Document 14 Quick Guide Sales Process 15 Motor Dealers Manual - Individual Distributor / Sole Trader / Locum 3

4 Defined Terms Version Number ASIC Authorised Product AM Corporate Distributor CRU Distributor Financial Services law FOS Individual Distributor Licensee Product Disclosure Statement (PDS) Suncorp Insurance You/Your We/Us/Our Description of Change Australian Securities & Investment Commission Insurance products in which you are authorised to deal in Suncorp Group Motor Dealer Account Manager A Distributor who is body corporate authorised to provide financial services on behalf of a Licensee. Corporate Distributors can sub-authorise its employees to be Individual Distributors Customer Relations Unit A person who is authorised to provide financial services on behalf of a Licensee. In this document, Distributors encompasses Corporate Distributors, Individual Distributors who are sole traders and locums. The legislation contained in Chapter 7 of the Corporations Act and the Corporate Regulations to regulate the provision of financial services including insurance products. Financial Ombudsman Service Australia Means the employees sub-authorised by the Corporate Distributor or if the Distributor is not a body corporate, a sole trader. Means the AFS licensee who appoints the Corporate Distributor. In this document, it means AAI Limited ABN trading as Suncorp Insurance A document given to the customer to explain the main features of the insurance. It includes information about: the main benefits and any additional benefits sold with the insurance; what is excluded from the insurance and the conditions (including how to make a claim); the cost of the insurance and its taxation impact; the customers rights in respect of cooling off, dispute resolution and privacy; and the insurer s contact details. AAI Limited ABN trading as Suncorp Insurance the Corporate Distributor Suncorp Insurance 4 Motor Dealers Manual - Individual Distributor / Sole Trader / Locum

5 What is this manual about? This manual explains what Financial Services law is about and what your responsibilities are as an Individual Distributor. This manual will assist you to ensure that you are fulfilling those responsibilities. As an Individual Distributor you have the responsibility to ensure that: You understand how Financial Services law affects your business you complete the relevant training in Financial Services law compliance Your responsibility as an Individual Distributor As an Individual Distributor, there are certain obligations to be fulfilled. Your obligations, briefly set out below, are covered in this manual. Ensure that financial product advice is not provided Report any incidents where financial services obligations have not been met. Notify us of changes to the ownership of the Motor Dealership, if you are a sole trader Ensure complaints are received and handled in the correct manner and notified to us Ensure that your Distributor Disclosure Document is accurate, current and approved by us Understand and utilise the established sales processes relevant to the financial services/s you are authorised to provide and comply with disclosure requirements Be aware of the supervision and monitoring procedures Ensure that training is appropriate, current and maintained for the financial services you are authorised to provide Ensure that our advertising and marketing materials used are the current versions provided. Be aware of and follow the termination, appointment and selection processes as described. This manual describes each of these sections. If you have any questions after reading this Manual, please contact your Account Manager (AM) Motor Dealers Manual - Individual Distributor / Sole Trader / Locum 5

6 2. Identify and 6. Close 5. Present Solution and reach agreement 4. Obtain Solution 3. Discover Customer Needs 1. Contact Build report Sales Procedures Flow Chart Customer not interest, no 6 Motor Dealers Manual - Individual Distributor / Sole Trader / Locum

7 Overview of sales procedure The Sales Procedures Flow Chart is designed to assist you in meeting Financial Services law obligations throughout the sales process. These procedures must be followed in accordance with the chart and can only be altered with our written consent. To assist in remembering the important steps of the sales procedure, a Quick Guide is available in the Paperwork section of this manual. How do the Financial Services laws affect the Sales Process? A key objective of the Financial Services laws is to bring about consistent and comparable disclosure within the whole financial services industry to ensure that customers are able to make confident and informed decisions. No advice You must not provide any advice regarding the Authorised Products and can only provide factual information about the insurance that is to be provided to customers. For example, if the customer indicates that they require Motor Vehicle Insurance for their new motor vehicle, and asks what insurance would be best for their personal financial situation, you are permitted to provide factual information about the product with reference to the relevant Product Disclosure Statement. But you are not permitted to provide any advice to the customer about which type of policy may be best for them. Factual information is accurate and objective information given to customers about: the insurer; the Distributor; or the Insurance Products. Documents to be provided during stages of the Sales Process Throughout certain stages of the sales process, you are required to provide the following documentation to the customer: Distributor Disclosure Document Product Disclosure Statement (PDS) These documents are described in the following sections. Distributor Disclosure Document To make it easy, a sample Distributor Disclosure Document is provided in the Paperwork section of this manual. You are required to give the customer a Distributor Disclosure so that the customer is made aware of who you act for, how you may be remunerated for your services and how they may access our dispute resolution service. You may reproduce this document as a brochure or as required. You may not change your Distributor Disclosure Document without receiving our written consent. When a Distributor Disclosure Document is updated and approved, the new Distributor Disclosure Document must be issued. Outdated stock must be withdrawn. A Distributor Disclosure Document must be provided: to all new customers, or when new products or financial services are provided to an existing customer and the Distributor Disclosure Document that the customer possesses is an outdated version. Verbal Disclosure In some instances, you will not be in a position to provide a hard copy version of the Distributor Disclosure Document, for example, when speaking to a client over the telephone. In these instances, a Distributor Disclosure document will need to be provided immediately by fax or and followed by the verbal script provided and the hard copy of the Distributor Disclosure document forwarded to the client by mail within 5 days. Please note that the Distributor Disclosure Document must be provided when the customer is interested in proceeding with a quote and does not have a current copy of the Distributor Disclosure Document. The Sales Procedure Flow Chart clarifies the various stages at which a Distributor Disclosure Document must be provided to the client. An appropriate example of a Verbal Disclosure is as follows: I am required to provide you with certain information. I am a distributor of the insurer, Suncorp Insurance and can deal in and arrange insurance policies on its behalf, but cannot provide advice. I may receive remuneration including commission from Suncorp Insurance for my services. Details of Suncorp Insurance s dispute resolution process can be found in the Motor Insurance PDS. A Distributor Disclosure document will be mailed to you within 5 days. Motor Dealers Manual - Individual Distributor / Sole Trader / Locum 7

8 Product Disclosure Statement Put simply, a PDS helps customers to answer the question, What motor vehicle insurance product am I buying? Customers can read a PDS to identify the features of a financial product, along with its benefits and costs. When do I give a PDS to a customer? There are two instances when a PDS needs to be provided to customers: Following a customer request for information about Motor Vehicle Insurance. A PDS can also be given when a new or existing customer asks for one. For example, they may have seen an advertisement for a product that directs customers to obtain a PDS. At or before the time an offer is made to issue or arrange the issue of Motor Vehicle Insurance (provided the customer does not already have a current PDS). The Sales Procedure Flow Chart clarifies the appropriate stage at which the PDS must be provided to the customer. For example, if a customer is interested in acting upon a quote and indicates they are interested in taking out a policy, you should first check that they have a current Distributor Disclosure Document. If they do have a current copy of your Distributor Disclosure Document, then you can proceed with providing a copy of the PDS for the relevant policy. Verbal Product Disclosure Statement In some instances, you will not be in a position to provide a hard copy version of the PDS to a customer, for example when speaking to a client over the telephone. In these instances, a PDS may be provided verbally and the hard copy of the PDS forwarded to the client by mail, fax or within 5 days. Please note, the PDS should be provided at the end of the application process and prior to the creation of a policy. The Sales Procedure Flow Chart clarifies the various stages at which a PDS should be provided to the client. A guide to using a Verbal PDS is provided on the following page. You may wish to photocopy the following page to keep near the phone for easy reference. What I will do now is send you your certificate of insurance and product disclosure statement. This insurance is issued by Suncorp Insurance. Please read these documents carefully as they contain full details of what is and isn t insured, and our 21 day cooling off period. You can call us on , 24 hours a day, 7 days a week. Before we continue would you like any further information about your insurance? If yes Comprehensive The insurance cover you have chosen is Comprehensive. This covers loss or damage to your vehicle and any damage your car causes to other people s property up to $20 million unless a lower limit is shown on your certificate of insurance. If you are not happy with our product or service, you can phone our Customer Relations Unit on Third Party Fire and Theft (also known as Extra ) The insurance cover you have chosen is Third party Fire and Theft. This covers your vehicle for fire or theft plus any damage it causes to someone else s vehicle or property. If you are not happy with our product or service, you can phone our Customer Relations Unit on Third Party Property The insurance cover you have chosen is Third Party. This covers any damage your vehicle causes to someone else s vehicle or property. If you are not happy with our product or service, you can phone our Customer Relations Unit on Motor Dealers Manual - Individual Distributor / Sole Trader / Locum

9 Complaints Complaint and Complaints Resolution Procedures A complaint is an expression of dissatisfaction made to an organisation, related to its products or services, or the complaints handling process itself, where a response or resolution is explicitly or implicitly expected. It is important that ALL complaints, irrespective of the nature, be reported regardless of the time taken to resolve it. Procedure for handling complaints If you receive a complaint about any type of General insurance product or service directly from a client you should: 1. Ascertain the nature of the complaint and any applicable reference numbers eg Policy or Claim number 2. Do not admit liability or provide thoughts/opinions on the outcome of the complaint. 3. Record in detail any discussions with the client including exactly what the complaint is about and the desired solution. 4. If the complaint is resolved by you within 1 working day of being lodged, then it must be reported directly to your RM who will record it appropriately. 5. If the complaint cannot be resolved by you within 1 working day of receiving it, then you must take appropriate action depending on the nature and origin of the complaint. Types of complaints Complaints can be divided into 2 categories: 1. Claims complaint - anything that results and relates to a General Insurance claim. General insurance claims can include motor vehicle claims (but does not include CTP). If the complaint results in, or is related to a claims matter, then it should be referred to Claims Assist. The customers can then deal directly with that staff member or speak to a Claims Supervisor if they wish. Suncorp Claims Assist If the customer prefers to supply a claims complaint in writing and not speak to someone, you can forward the written complaint to: The Manager Motor Dealers IPC 4GI 109 GPO Box 1453 Brisbane QLD 4001 Direct contact should be made with your Account Manager as soon as is possible to report the complaint. Under no circumstance should you send written acknowledgment to the customer. All reported complaints will receive acknowledgments from the Manager Motor Dealers. The Manager Motor Dealers or relevant claims representative will attempt to resolve the issue within 15 working days. They will liaise with your AM and you where necessary. Where required the Manager Motor Dealers will ensure a final decision letter is issued to the customer. This letter will confirm the outcome of the complaint investigation including our resolution offer where appropriate. 2. Non-claims complaint - all other issues including underwriting, premium increases and service related matters. If the complaint is relating to any other issue than a claims matter then it is to be referred to the Customer Relations Unit (CRU) within 1 working day. CRU Contact Details Phone: customer.relations@suncorp.com.au Direct contact must be made with your AM as soon as is possible to report the complaint. The CRU will acknowledge receipt of any non-claims related complaint with the customer and attempt to resolve the issue within 5 working days. They will liaise with your AM and you where necessary. You must not correspond with the person making the complaint unless your AM has given permission. Keep a copy of the correspondence for your record. Where required the CRU will issue the customer with a Final Decision letter confirming the outcome of the complaint investigation including our resolution offer, where appropriate. Motor Dealers Manual - Individual Distributor / Sole Trader / Locum 9

10 External Complaints Resolution Procedures We are required under our Australian Financial Services licence obligations and the General Insurance Code of Practice, to be a member of an appropriate external dispute resolution (EDR) scheme. The EDR scheme that we belong to for General Insurance disputes is the Financial Ombudsman Service (FOS) Australia. Customers wishing to use FOS must do so within 90 days of receiving the final decision from Suncorp via our Internal Disputes Resolution (IDR) process. Details of FOS can be found in the Distributor Disclosure Document and any of our PDS. 10 Motor Dealers Manual - Individual Distributor / Sole Trader / Locum

11 Incident Reporting What is an Incident? An incident is a failure by you or your sub-authorised distributors to comply with any policy or procedure. This may amount to a breach of law, or it may merely be a failure to follow the correct procedure. We have an obligation to report significant breaches or likely breaches of our AFS licence conditions to ASIC. Examples of incidents include: Failing to give the Distributor Disclosure Document and/or PDS; Giving Advice to a customer; Telling a customer a claim will be paid. Behaving unfairly or dishonestly towards clients. Reporting Incidents You should report incidents that could be a breach immediately after you become aware of it to your AM. It is important that all incidents or potential incidents are reported promptly so they can be notified to ASIC if necessary. It is also important that we are promptly notified of incidents so we can take any remedial action that might be necessary. An incident may require us to initiate remedial action for your employees, such as additional training, and may result in us carrying out additional monitoring and supervision activities to identify any systemic breaches or ongoing compliance problems. Motor Dealers Manual - Individual Distributor / Sole Trader / Locum 11

12 Supervision and Monitoring As outlined in our Agreement, compliance with this manual will be monitored by us at regular intervals. The checklist below outlines activities which will be monitored: Disclosure Documents Is the current Distributor Disclosure Document up-to-date? Are you providing the customer with an up-to-date version of the Distributor Disclosure Document? Are you using the latest version of the PDS for the respective products? Can you demonstrate that the Distributor Disclosure document and the PDS are being issued prior to every offer? Authorised Activity Are all persons, selling the Authorised Products, correctly authorised by us? Have any of your employees sold the Authorised Products prior to authorisation being given? Is there any evidence that advice has been given to customers in relation to the Authorised Products? Advertising Material/Signage Advertising material including signage, business cards, promotional material, stationery etc will be checked for: Correct use of Authorisation eg. Distributor for Suncorp Insurance The most up-to-date materials supplied are being displayed and provided to clients. Compliance If remedial action(s) have been implemented previously, are they being sustained? Complaints Are you aware of the process for reporting any complaints received from a customer about the Distributor? If any complaints have been received about you, have they been reported to Suncorp Insurance? Additional Checks Do you have a brochure concerning the Complaints process and is it available to the customer? Can your produce your copy of this manual? Has there been any incidents that have not been reported to us? 12 Motor Dealers Manual - Individual Distributor / Sole Trader / Locum

13 Procedure for change of details You are required to advise us of any changes in details within five (5) working days. Please see the details checklist below: For Sole Traders Changes which require notification: 1. Name Change 2. Principal Place of Business Address 3. ABN / ACN 4. Distributor Disclosure Documents Should a change occur in any of the details listed 1-5, you must advise the Motor Dealer Operations by to motordealerscompliance@suncorp.com.au. For Sub-Authorised Employees Changes which require notification: 1. Name change 2. Cessation of Individual Distributor s authorisation. Should a change occur in any of the details listed 1-2, you must advise the Motor Dealer Operations by at motordealerscompliance@suncorp.com.au. Motor Dealers Manual - Individual Distributor / Sole Trader / Locum 13

14 Paperwork Distributor Disclosure Document Distributor Disclosure Document Important Information About us and who we act for Name: ABN: Telephone: xxxxxxxxxxxx xxxxxxxxxxxx xxxxxxxx We are authorised to provide a service of dealing in certain financial products on behalf of: AAI Limited ABN AFSL No trading as Suncorp Insurance (the Insurer). Level 28, 266 George St, Brisbane QLD 4000 Phone: How we are paid From the premium that you pay the Insurer, we will receive remuneration at the rates displayed in the table below. The rate is calculated based on the premium (exclusive of government charges) for each product. We will usually receive this amount at the end of the month following payment of the premium. Any remuneration we receive is not charged directly to you. Product Motor insurance issued by the Insurer Commission rate % to Distributor Up to 31.5% of the inception premium From time to time we may also receive sponsorship and additional rewards from competitions and promotions. Remuneration or other benefits received by our staff or contractors Our staff and contractors ( staff ) receive a salary. Staff may also receive a payment or commission, from the commission we receive, for the financial service they provide. Staff may also receive non-monetary benefits, such as gift vouchers. If you have a complaint Should you be dissatisfied with our service, please tell us. Alternatively you can contact the Insurer in any of the following ways: Phone: Fax: customer.relations@suncorp.com.au Mail: Reply Paid 1453 Customer Relations Unit RE058 GPO Box 1453 Brisbane QLD 4001 If you are not satisfied with the Insurer s final decision or if the Insurer has not been able to resolve the complaint to your satisfaction within 45 days you may be able to take the complaint to the Financial Ombudsman Service (FOS) Australia. The FOS is an independent external dispute resolution scheme and its service is free to customers of the Insurer. We agree to accept a FOS decision however you have the right to take legal action if you do not accept their decision. The FOS will tell you if they can help you, as their services are not available to all customers. You can contact FOS: By phone: (free call) By fax: (03) By info@fos.org.au In writing: Financial Ombudsman Service Limited GPO Box 3 Melbourne VIC 3001 By visiting: /04/14 A 14 Motor Dealers Manual - Individual Distributor / Sole Trader / Locum

15 Paperwork Quick Guide Sales Process QUICK GUIDE FACE TO FACE SALES TELEPHONE SALES 1. Contact made by customer 2. Clarify customer needs 3. Provide factual information from Product Disclosure Statement (If requested) For telephone sales follow steps 1 5 and then shift to steps 6, 7 and 8 below. 4. Provide quote 5. Does client wish to proceed? No No further action. Yes go to point Provide Distributor Disclosure document. 6. Ask the client for their address and immediately them the Distributor Disclosure document. Read the scripted verbal Distributor Disclosure to the customer. (As attached) 7. Provide Product Disclosure Statement 7. Read the scripted verbal Product Disclosure Statement to the customer. (This is displayed after the policy number is assigned in POS) 8. Does client have other needs? 8. Follow up by mailing Distributor Disclosure and Product Disclosure Statement within 5 Days. 9. Confirm transaction: Insurance Application D Distributor Disclosure D Product Disclosure Statement D Receipt for any cash received D VERBAL Distributor Disclosure (DD) I am required to provide you with certain information. Suncorp product(s) I am a distributor of the insurer, AAI Limited trading as Suncorp Insurance, and can deal in and arrange insurance policies on its behalf, but cannot provide advice. I may receive remuneration including commission from Suncorp Insurance for my services. Details of Suncorp Insurance s dispute resolution process can be found in the Motor Insurance PDS. A Distributor Disclosure document will be mailed to you within 5 days. Motor Dealers Manual - Individual Distributor / Sole Trader / Locum 15

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