As a financial institution, the Police Health Plan (PHP) is required to establish, maintain, and implement a Fair Conduct Programme (FCP). This programme outlines how we ensure we are meeting the fair conduct principle by outlining the policies, processes, systems, and controls that help us deliver fair outcomes to our members.
What is the fair conduct principle?
The fair conduct principle is that as a financial institution, we must treat consumers fairly.
This includes:
- Paying due regard to our members' interests; and
- Acting ethically, transparently, and in good faith; and
- Assisting our members to make informed decisions; and
- Ensuring that the relevant services and associated products that PHP provides are likely to meet the requirements and objectives of current and potential members; and
- Not subjecting members to unfair pressure tactics or undue influence
This applies when:
- We are designing any relevant service or associated product; or
- Providing or offering to provide any relevant service or any associated product to a member; or
- Having any dealings or interactions with a member in connection with any relevant service or any associated product (e.g., responding to a complaint or handling a claim under an insurance contract)
Summary of our FCP
Below we have summarised the key parts of our FCP.
| Key Part | Description |
| Governance | Our FCP is approved by our board. They receive regular updates on the effectiveness of the programme, conduct risks, and failures to comply with the programme. If we identify any gaps or weaknesses in the FCP, we will make improvements to ensure it remains effective |
| Reviewing products, services, and distribution methods | We conduct an annual review of the products and services that we provide. This review includes member feedback we receive about the products and services. We conduct market analysis to ensure our premiums are appropriate for the coverage that we provide. We only distribute our products and services directly to our members, and we continually assess whether this is fit for purpose. |
| Managing incentives and conflicts of interest | We do not offer incentives to our staff. When we identify a conflict of interest, we report and manage these to ensure we focus on our members' interests. |
| Communication | We provide you with a plain language policy wording to make it easy for you to understand what you are covered for. Our team is available when you need to ask questions about your policy or claims. We communicate to you before changes are made that relate to your policy, premiums, or the way you can access our products and services. We review our communications to you and the information we provide to ensure they are clear and easy to understand. |
| Customer Care | We have an internal complaint management process to support members who need to make a complaint. The process includes escalation to senior staff members and if required, escalation to the Insurances and Financial Services Ombudsman, our independent external resolution scheme. We acknowledge that sometimes our members may be experiencing circumstances that limit their ability to access or use our products and services, in these cases, we may be able to provide additional support. |
| Employee Training | We ensure our employees receive training that is relevant to their role so they can perform their duties effectively. This can cover technical aspects of their role and other additional training where required. They are also trained on key processes that help us meet our regulatory obligations, including our FCP. |
| Managing Conduct | We perform assurance over our teams to identify any areas of improvement or areas where misconduct could occur. When we identify misconduct, we correct this behaviour through our internal processes. We have a Code of Conduct that outlines our expectations for the way our employees conduct themselves when interacting with our members. Our employees can report misconduct through internal processes that support a fair and transparent review of the information they share. |
What to do if you have a complaint
If you feel that we have breached the fair conduct principle or have a general complaint, you can find more information about our Complaints Process and how to lodge a complaint here.