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Customer Family and Domestic Violence Policy

Last Updated: 1 July 2020

Scope

This Policy applies to the following Marsh Australia group companies:

  • Marsh Pty Ltd ABN 86 004 651 512 AFSL 238983
  • Marsh & McLennan Agency Pty Ltd ABN 33 000 668 584 AFSL 238984
  • Marsh Advantage Insurance Pty Ltd ABN 31 081 358 303 AFSL 238369
  • Victor Insurance Pty Ltd ABN 11 146 607 838 AR No. 000403803
  • Victor Insurance Australia Pty Ltd ABN 83 161 243 198  AR No. 001276980
  • Echelon Australia Pty Ltd ABN 96 085 720 056 AR No. 000411224

All references to Marsh should be construed as a reference to the relevant entity.

Overview

Marsh recognises that family and domestic violence are issues that can impact a person’s insurance arrangements. At Marsh, we are committed to helping and supporting people who are experiencing family or domestic violence. The purpose of this policy is to provide an understanding of Marsh’s processes and procedures which have been implemented to help minimise the risk of harm in Marsh’s interactions with customers who are experiencing family or domestic violence, and to help ensure that Marsh provides those customers with timely, consistent and targeted assistance. For the purposes of this policy, ‘customer’ includes an individual insured or a third party beneficiary of a policy or scheme Marsh arranges or manages, a potential customer, or an individual from which Marsh is seeking to recover money.

Definition

Domestic violence refers to acts of violence by a family member. This violence can include threats and intimidation and may be sexual abuse, financial or economic abuse, emotional or psychological abuse, social abuse and/or damage to property. The Family Law Act 1975 (Cth) defines ‘family violence’ as ‘violent, threatening or other behaviour by a person that coerces or controls a member of the person’s family… or causes the family member to be fearful’.

Identification

At Marsh, we are aware that customers may be reluctant or unable to disclose to our employees that they are affected or are experiencing domestic or family violence. Therefore, we provide our employees with training so that they are able to identify signs that may indicate a customer is affected by family violence. This training also teaches our employees techniques to facilitate an environment where customers affected by family violence feel comfortable to disclose their circumstances to our employees, as well as other techniques to improve their experience.  In particular, employees must not require evidence of family violence, such as an intervention order, from the customer before they enact the procedures required by this policy. Instead, an employee should utilise the relevant processes that this policy requires if a customer self-identifies to the employee as being affected by family violence or the employee recognises signs or otherwise identifies that the customer may be affected by family or domestic violence. Having adequate identification processes in place also allows Marsh to effectively treat matters involving family violence and best select the course of action appropriate to the individual matter as outlined within this policy. For example, employees can treat claims as a matter of priority, organise/provide financial hardship help, escalate an issue to a more senior person, or refer the customer to specialist services for further guidance.

Interaction with employees

It is important to Marsh that, once we identify customers who may be affected by family or domestic violence, we interact with them in a supportive manner. Therefore, we aim to always engage in careful and sensitive conversations with customers affected by family violence. We also aim to keep such conversations confidential so that we do not disclose to the perpetrator of such violence that we are aware of the violence or other personal details of the customer that may enable the perpetrator to continue the family violence. Confidentiality in our dealings with customers who may be affected by family or domestic violence is of the utmost importance. Training is also provided to our employees on how to interact with customers who have been identified as being at risk of experiencing family violence so that support, sensitivity and confidentiality are always maintained in our communications with them.

In our communications with customers affected by family or domestic violence, we aim to minimise the amount of times a customer has to disclose their family violence situation. We do not wish for customers to have to repeat their disclosures as we understand that reliving the experience can be uncomfortable and even traumatising.  To do this, we may flag a customer’s account when we have identified that they may be affected by family violence. This also allows us to maintain that customer’s confidentiality and privacy more effectively, and implement specific security measures. More information on confidentiality, privacy and security is outlined below. 

We would like to make our customers aware of some strategies that can help us in our interactions with those who are affected by family violence. If you are a customer who is affected by family violence, please let us know if you would prefer to speak to a specific employee. We understand that, if you have opened up to an employee about your circumstance in the past, it would likely be more comfortable for you to make any further communications about your circumstances to them. We also understand that you might want to open up about these issues to an employee of a specific gender only. Please also let us know if, when we are communicating with you about issues relating to family or domestic violence, you are not in a position to talk about such issues. This may be the case because the perpetrator is present or may be monitoring your calls or mobile phone usage. We will not communicate with you about these issues over email or over the internet generally because of the sensitivity of the matter and the possibility that other people within your family (the perpetrator or otherwise) may have access to your email account or internet browser. Before we communicate with you about such issues, we will need to be sure of your identification and we do adopt security measures to ensure this.

Confidentiality and Security

Marsh ensures the confidential handling of all private and confidential information collected about a customer who may be experiencing family or domestic violence. This is done foremost to protect the safety of the customer and, thus, additional requirements are imposed on Marsh employees on top of usual confidentiality practices. These practices are in place so that details that could compromise the safety of the customer, such as their physical address, are secure and not at risk of deliberate or inadvertent disclosure to the perpetrator of the family violence.  The risk that perpetrators of family violence can access private information of their family members who they are abusing may be high as they may know details about the customer to pass privacy screening questions or, where they are also listed on a joint policy, it may seem like they have the right to that information. Therefore, we may flag a customer’s account who is experiencing family violence so that all employees know not to disclose that information to anyone except the customer and put additional security measures in place so that we can be sure it is the customer we are communicating with at all times.

Where joint policies are concerned, we will also work with the customer so that we can maintain dual sets of information on file, so that we can separate the perpetrators information from the information of the customer who is being abused. Where possible we will put in secondary addresses, email addresses, bank account details etc. and we will not notify the perpetrator of this. Such details will be subject to the additional security measures outlined above. Where the perpetrator tries to access the information and is confronted with such security measures, we will not identify why the security measures are in place. The fact that an account has been flagged as having family or domestic violence concerns is confidential in and of itself.

We will set up the measures outlined above for all accounts the customer has with us.

Claims

We understand, that where a customer is experiencing family or domestic violence, that making a claim, particularly against a joint policy under which the perpetrator is insured, can lead to instances of abuse. We also understand that some claims can be a result of family or domestic violence, for example, where the perpetrator has damaged the customer’s property. Therefore, our employees will handle claims made by a customer experiencing family or domestic violence with sensitivity, flexibility and care. We will give a customer additional time frames for claims if needed, as we understand that a customer may not always be in a position to communicate with us about the claim. We will not abandon the claim if we do not get a response from you if we are aware you are being affected by family violence. We will allow one party of a joint policy to make a claim without the other party’s knowledge and/or permission and we will keep this claim confidential if it relates to family violence. We also understand that customers may not have access to some documents we usually require to settle a claim and will take this into account when handling claims of customers who are experiencing family or domestic violence. We will also prioritise claims where a matter is of financial urgency due to family violence. When a claim is paid, we will undertake investigations to determine whether we are paying the correct party and whether the customer who is experiencing family or domestic violence will have access to the claims money once paid.

Financial Hardship Help

Customers who experience family or domestic violence may also experience financial hardship, particularly where they are a victim of financial abuse. We will aim to determine whether, due to a customer’s circumstance of experiencing family or domestic violence, a customer is experiencing financial hardship. If a customer is experiencing financial hardship due to family violence, we will work with them to formulate options so that they can retain their policy if they cannot pay their premium. These options may include:

  • changing the benefit structure or the sum insured of the policy;
  • reducing the benefits of the policy; and
  • pausing premium payments, without cancelling the policy.

We will also fast-track any request for financial assistance which may be made. Where we are assessing your request for financial hardship assistance, and the perpetrator is a joint policy holder, we will not need the consent of the perpetrator to conduct the assessment. If a customer cannot obtain the relevant documents usually required to undertake a financial hardship assessment due to their circumstance of experiencing family violence, we will take this into account.

If a customer who is affected by family or domestic violence has an existing debt with Marsh, where possible, we will not refer the debt onto a third-party debt collection agency. If we only become aware that a customer debt is due to or related to family or domestic violence after it has been referred or to a third party collection agency, then Marsh will work with the collection agency to provide the best outcome for the customer.

Support

In certain circumstances, Marsh will not be well-placed to provide help or support to persons experiencing family or domestic violence, particularly outside the scope of the financial relationship Marsh has with the customer. Where employees identify that this is the case, they will refer the customer to external legal or support organisations.  A list of external organisations which may be helpful to customers experiencing or affected by family or domestic violence is provided below.

Australia-wide

  • Kildonan UnitingCare
  • 1800 RESPECT
  • Lifeline (13 11 14)

Australian Capital Territory

  • Legal Aid ACT

New South Wales

  • NSW Health Education Centre Against Violence
  • Women’s Domestic Violence Court Advocacy Service
  • Gendered Violence Research Network, UNSW
  • Ask LOIS (Women’s Legal Service NSW)
  • LawAccess NSW
  • Legal Aid NSW

Northern Territory

  • Northern Territory Legal Aid Commission

Queensland

  • Queensland Centre for Domestic and Family Violence Research
  • Legal Aid Queensland

South Australia

  • Legal Services Commission of South Australia

Tasmania  

  • Legal Aid Commission of Tasmania

Victoria

  • Domestic Violence Resource Centre Victoria
  • Victoria Legal Aid

Western Australia

  • Women’s Council for Domestic and Family Violence Services
  • Legal Aid WA

Modern Slavery Statement and Policy

Our Modern Slavery Statement

Last Updated: 1 July 2021

To read our latest Marsh McLennan Modern Slavery Statement, please download a copy here.

 

Our Modern Slavery Policy

Last Updated: 1 July 2020

This Policy operates in Australia and covers Marsh Pty Ltd and its related entities (“Marsh”). It complements Marsh’s code of conduct, The Greater Good, which sets out the standards weexpect of our colleagues and business partners.

Modern slavery can occur in various forms, including forced or compulsory labour, discriminatory employment practices, human trafficking, debt bondage or bonded labour, or child labour.

We are committed to conducting our activities fairly, honestly and with integrity, in accordance with the applicable laws.  We do not tolerate modern slavery in any part of our business, or in the business of our upstream or downstream business partners.  We are committed to ensuring that these type of activities do not take place in our supply chains.

How do we identify Modern Slavery Risks?

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all colleagues working for Marsh.  Colleagues are required to avoid any activity which might lead to a breach of this Policy.

If you believe or suspect that slavery is occurring, you must notify your manager as soon as possible, or report the matter via ethicscomplianceline.com.

If you are unsure whether a particular act, the treatment of workers or their working conditions may constitute modern slavery, you should still raise the matter so that it can be investigated.

We aim to encourage openness.  We will not tolerate retaliation against any colleague who raises a concern in good faith as a result of reporting their suspicion that modern slavery may be taking place in our business or supply chains.

Members of the public or people not employed by Marsh should write to: The Chief Compliance Officer, Marsh Pty Ltd, One International Towers Sydney, 100 Barangaroo Avenue, Sydney NSW 2000 or email complaints.australia@marsh.com to raise any concern or suspicion of modern slavery in any part of our business or related supply chain.

How do we enforce the Policy?

If an issue is identified in the business of our upstream or downstream business partners, we will work with them to prepare a corrective action plan and resolve the matter within an agreed timeframe.

We reserve the right to terminate commercial relationships with any business partner if they are found to be involved in modern slavery.

Any colleague who breaches this Policy will face disciplinary action which could result in dismissal for misconduct.

How do we raise awareness of this Policy?

A copy of this Policy is available on our website and on our internal intranet pages for colleagues.

General awareness training is provided to all colleagues when they join Marsh.

Those colleagues closely involved in recruitment and procurement are trained in this Policy.

Our approach to modern slavery must be communicated to all our upstream or downstream business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Who is responsible for the Policy?

Responsibility for this Policy rests ultimately with the Board of Directors of Marsh Pty Ltd.

Managers at all levels are responsible for ensuring those reporting to them not only understand but also comply with the Policy.



Product Development & Distribution Policy

1. Introduction

This Policy sets out the Marsh Advantage Insurance Pty Ltd (MAI) approach to developing and distributing retail insurance products for its appropriate target markets where MAI is acting on behalf of insurers. This Policy aims to support MAI’s customer focussed approach by aiming to provide our customers with products that are consistent with their likely objectives, financial situations and needs.

To ensure our design and distribution obligations are met, our customers’ needs will remain at the centre of our product lifecycle including:

1.      The product design stage;

2.      The product delivery stage;

3.      The product review stage; and

4.      The product modification or decommission stage.

In further supporting this objective, MAI will have in place Target Market Determinations (TMDs) which will guide the distribution of our products for appropriate target markets. These TMDs will be available on MAI’s and/or the relevant insurer’s website for all relevant products from 5 October 2021.

2. Product Design

The first stage of a product’s lifecycle is the design stage. MAI is committed to ensuring our products are designed so as to be consistent with the likely objectives, financial situations and needs of our customers for whom they are intended.

We recognise that we have a range of customers with different complex and multifaceted interests that should be considered in the development and design of our products.

When new products are developed or our current products are updated, we will start by assessing the likely objectives, financial situations and needs of the target market. This assessment may include:

  • market research and feedback to assist us in understanding the customers likely objectives;
  • needs analysis of internal and external data, industry data and other metrics; and
  • our own experience and expertise.

From 5 October 2021, TMDs will be available for retail products describing the type of customers comprising the target market for the insurance product.

3. Product Delivery

After a product has been appropriately designed, the product will be assessed to ensure that we identify the distribution channels and arrangements that are reasonably likely to result in our products reaching consumers in the target market.

We will take all reasonable steps to ensure our retail products are distributed in accordance with the TMDs including: assessing the most appropriate distribution channels for each individual product; setting distribution conditions that our distributors must follow including distribution in line with TMDs; obtaining information about the distribution from distributors; customer feedback and taking appropriate action in response; and adherence to our regulatory requirements.

4. Product Design and Delivery Review

Regular reviews will take place to ensure that our retail products are operating the way they were designed to operate and that they continue to meet our customers’ needs. Regular reviews are also important to ensure our products are distributed in a way that is likely to reach our designated target market.

Product reviews may include measuring complaints, customer feedback and other claims data and market conditions whilst also drawing on the experience of our own staff.

Commencing from 5 October 2021, product design and delivery reviews may also occur in response to TMD review triggers.

5. Product Modification or Decommission

Following a product review, it may be assessed that the product or its distribution channel require modification to ensure they remain consistent in achieving the likely objectives, financial situation and needs of our customers.

Our products may also require modification in response to regulatory changes. If following a review it is identified that a product is not delivering customer value and cannot be enhanced or distributed in a manner consistent with achieving the likely objectives, financial situation and needs of our customers, it may be decided that the product be decommissioned.

6. Review

This Policy has been developed by MAI in conjunction with Marsh Legal, Compliance & Public Affairs team and will be reviewed on an annual basis or as required.

Date of next review: 1 July 2022

 

Marsh Advantage Insurance Product Development and Distribution Policy v.1.0.

Marsh Advantage Insurance Pty Ltd (ABN 31 081 358 303, AFSL 238369) (“MAI”) arrange this insurance and is not the insurer. The Discretionary Trust Arrangement is issued by the Trustee, JLT Group Services Pty Ltd (ABN 26 004 485 214, AFSL 417964) (“JGS”). JGS is part of the Marsh group of companies. Any advice in relation to the Discretionary Trust Arrangement is provided by JLT Risk Solutions Pty Ltd (ABN 69 009 098 864, AFSL 226 827) which is a related entity of MAI. The cover provided by the Discretionary Trust Arrangement is subject to the Trustee’s discretion and/or the relevant policy terms, conditions and exclusions. This website contains general information, does not take into account your individual objectives, financial situation or needs and may not suit your personal circumstances. For full details of the terms, conditions and limitations of the covers and before making any decision about whether to acquire a product, refer to the specific policy wordings and/or Product Disclosure Statements available from Marsh Advantage Insurance on request.