Fair Treatment of Customers Policy

Purpose

The purpose of this Policy is to establish a consistent approach to the fair treatment of Customers by Western Financial Group (“Western”), its Representatives and Outsourced Providers that meets the Canadian Council of Insurance Regulators (‘CCIR”) and the Canadian Insurance Services Regulatory Organizations (“CISRO”) fair treatment of Customers principles as prescribed by their ‘Guidance Conduct of Insurance Business and Fair Treatment of Customers’ and the Principles of Conduct for Insurance Intermediaries. This policy is to be used in conjunction with other policies and procedures sourced and managed by Western as the first line of defense and as part of its activities to ensure it is in compliance with Applicable Laws and Regulations.

This policy outlines Western’s responsibilities in achieving fair treatment of Customers outcomes.

Western is ultimately responsible for ensuring that its Representatives who provide its products and services act appropriately to achieve fair treatment of customers.

Eligibility

The persons to whom this policy applies.

Scope

This policy applies to Western Financial Group Employees, Representatives and Outsourced Providers acting on its behalf.

Definitions

The following terms and definitions apply to this Policy:

Applicable Laws and Regulations means all material laws, regulations, guidelines and directives applicable to Western.

Collect means gather, acquire or obtain Personal Information from any source, by any means.

Consumer includes all actual and potential Customers for insurance products and services.

Conflict of Interest means competing interests or loyalties.

Customer means clients including current and past policyholders or prospective policyholders with whom Western interacts and includes others with a legitimate interest in its product.

Employee means any employee on the Western payroll or the payroll of any of Western’s subsidiaries.

Outsourced Provider means a legal entity providing a product or service, under contract or engagement, for Western or any of its subsidiaries.

Personal Information means information collected about an identifiable individual.

Representative means any employee of Western Financial Group.

Subsidiaries means companies owned or controlled by Western, such as Western Coast Insurance Services, Western Group Insurance Services, Wyatt Dowling and any other company Western may acquire.

Western means Western Financial Group and its Subsidiaries.

Policy Statement

Western Financial Group ensures that its Customers are treated fairly and conducts its business in line with the expectations set out in the CCIR/CISRO Fair Treatment of Customers guidance, provincial insurance councils’ guidance, Western’s Guiding Principles, and all other Applicable Laws and Regulations concerning fair treatment.

Western is committed to high ethical standards in everything we do. We all count on each other to do the right thing. Fair treatment of Customers is an integral part of our business practices, and is supported by our Guiding Principles, supporting strategy, and our Code of Conduct, which serves as a guide for our individual and collective behaviors so that we always operate ethically, fairly and with integrity.

By treating Customers fairly, public trust and Consumer confidence in Western Financial Group is strengthened. Western plays a key role in that its interactions with both Customers and insurers is critical in building and justifying public trust and confidence in the Western brand as well as the insurance sector.

This policy does not outline the requirements of each provincial regulator or regulatory body that oversees Western; however, this does not remove the responsibility of Western Financial Group and its Representatives to be aware of, understand and apply fair treatment requirements in each area it does business.

This policy provides Western with the necessary latitude to determine strategies, procedures, processes and controls that apply to the offer of insurance products and services to its Customers based on the nature, size and complexity of their activities while supporting the fair treatment of Customers as described in the sections below.

Western will ensure that Customers are treated fairly throughout the lifecycle involving Western products or services, from the design of the product until all obligations under the contract have been met.

We will do this by committing to the following fair treatment of Customers principles (the “Fair Treatment of Customers Principles”):

• We will put our Customers at the center of everything we do, including strategic decisions and our daily conduct and activities.
• We will establish and implement policies and procedures, and we will assess and monitor them to ensure that Customers are treated fairly as an integral part of our business culture.
• We will act with due skill, care and diligence when dealing with Customers, intermediaries and regulatory authorities.
• We will comply with applicable laws, regulations and guidelines.
• We will develop products in a way that puts Customer’s interests first.
• We will provide our Customers with accurate, clear, sufficient and not misleading information in order to allow them to make informed decisions and be aware of their rights and obligations.
• We will work with our Representatives to uphold these Fair Treatment of Customers principles and we will have contractual arrangements with our Representatives to ensure that they achieve fair treatment of Customer outcomes.
• We will share our strategies, policies and procedures related to fair treatment of Customers with regulatory authorities and report major operational incidents which may jeopardize the interests or rights of Customers or our reputation.
• We will work towards achieving the CCIR and CISRO expectations for fair treatment of Customer outcomes.

1. Western’s Governance and Business Culture Prioritizes the Fair Treatment of Customers

The overall responsibility for fair treatment of Customers is at the level of senior management and the Board of Directors, who oversee and are responsible for the design, approval, implementation and adherence to policies and procedures aimed at ensuring that Customers are treated fairly.

The Board of Directors and senior management will assess organizational performance, including employee performance evaluation, remuneration and reward strategies, against Western’s Guiding Principles, and in doing so, evaluate the ability of Western’s culture to demonstrate fair treatment of Customers forms an important part of Western’s culture

Western Financial Group understands the importance of placing Customers at the center of its concerns, strategic decisions and daily conduct. Western strives to treat Customers fairly no matter who they are or where they live. Western’s relationship with its Customers reflects its reputation.

Western is an advocate for its Customers as well as a trusted representative of its suppliers. As such, Western is committed to conducting its business in compliance with all Applicable Laws and Regulations related to Consumer protection.

Western is committed to developing and reviewing policies and procedures to ensure that the fair treatment of our Customers remains a core component of our governance. Western’s Guiding Principles express the importance of fair treatment of Customers concepts, and in doing so support a corporate culture that emphasizes the importance of fair treatment of Customer outcomes.

As supported by this policy and Westerns Guiding Principles, the interests of Western’s Customers are at the very heart of its business transactions and decisions. Western works hard to provide a consistent, exceptional Customer experience and works to continuously improve on how Customers are treated in all areas of its business

Western’s Guiding Principles, written policies and procedures are integral parts of its business culture and guide its decision-making processes. These principles, policies and procedures keep the best interests of Western Customers in mind. Western Representatives are not driven by words on paper alone, but by the doing the right action and making the right choice for Customers.

Western puts the interest of Customers before its own when marketing, selling and servicing its products by promoting products in a clear, fair and not misleading manner. Representatives are trained to provide open, transparent, complete and honest advice.

When applicable, Western considers the best interests of the Customers during new product development, marketing and launch.

Western maintains good and sound relationships with regulatory authorities and monitors, identifies and corrects concerns where it finds that its products and/or representative do not meet its standards.

2. Fair Treatment of Customers by Identifying and Managing Conflicts of Interest

 

As Western Financial Group interacts with both Customers and insurers, its Representatives are likely to encounter actual or potential conflicts of interest. Every Representative of Western owes a duty of care to its Customers. There is a risk that when conflicting interest compete with this duty of care, a Representative acting on behalf of Western may not act in the best interest of the Customer. It is for this reason that Western develops, maintains and enforces policies and procedures to prevent harm to Customers from Conflicts of Interest.

Western is committed to ensuring that any perceived or potential conflicts of interest are managed appropriately. Western takes all reasonable steps to identify and avoid or manage potential or actual conflicts of interest. We will act in good faith by putting the Customer’s interests before our own to ensure the Customer’s interests take priority.

Western strives to avoid conflicts of interest through transparency with the Customer. Representatives disclose to the Customer in writing any conflicts of interests that are present because of compensation, inducements or conflicting duties in line with Applicable Laws and Regulations.

Remuneration and reward strategies at Western consider the fair treatment of Customers. Western recognizes that remuneration structures that create conflicts of interest may lead to poor Consumer outcomes and as such, reward structures reflect quality issues and not encourage or reward the unfair treatment of Customers. Remuneration, reward strategies and evaluation of performance consider the contribution made to achieving outcomes in terms of fair treatment of Customers. Incentives are not based solely on sales volumes.

Western monitors and reviews its actions and products for potential conflicts of interest and strives to identify and address potential or real Conflicts immediately when they are raised. Representatives are trained in the identification and reporting of conflicts of interest.

If a Conflict of Interest cannot be avoided, Western will disclose this immediately to all parties involved and work together with its Customer to determine the best solution.

3. Fair Treatment of Customers by Outsourced Service Providers

When it is to its Customers’ advantage, Western may contract or arrange with Outsourced Providers to offer or deliver products or services.

Western will ensure that the service providers have high ethical and professional standards.

If Western outsources any functions, it selects its Outsourced Providers based on high standards including their reputation of the fair treatment of Customers and the policies, and procedures that Outsourced Providers have in place to meet the laws for the protection of Customers’ Personal Information.

Western will maintain appropriate controls and monitor Outsourced Providers to ensure that all outsourced functions related to the conduct of insurance business, meet the same high standards of service and achievement of fair treatment of Customers outcomes that are expected of Western.

Western is ultimately responsible for the fair treatment of Customers, so we will monitor and review our Outsourced Providers and provide training, if necessary, to assure fair treatment of Customers. We will review all arrangements related to Outsourced Providers at the renewal date of the agreement with Fair Treatment of Customers Principles in mind.

If shortcomings are discovered, Western will address them with the Outsourced Provider to determine the cause. If the issue is severe, Western will determine whether it is in the best interest of its Customers to suspend or cancel the outsourcing arrangement.

4. Fair Treatment of Customers in the Design of Insurance Products

When Western develops new products or makes changes to current products it takes the interests and needs of the target Consumer group into account. This includes any products which may originate from a third-party administrator.

Western understands that products can be difficult for a Consumer to understand and that weaknesses in the product design or disclosure documentation can increase the likelihood that a Consumer makes a choice that is not in his/her best interest.

Western works with its Representatives and product experts to identify Consumer needs and develop coverage that provides reasonably expected benefits to those Consumers who the product is appropriate for. Western only places products with Customers who will benefit from its features.

Western is committed to ensuring its product and pricing development processes include the use of adequate information to assess the needs of different Consumer groups, and provide for a thorough assessment of the main characteristics of a new product and of the related disclosure documents by all relevant departments.

Western products are accompanied by documentation that simply, clearly and accurately describes the product coverage and outlines how it will benefit the Consumer as applicable. The language in these documents is made as simple as possible and our representatives are trained to answer any questions that arise.

Products developed and/or offered by Western meet all legal and regulatory requirements across Canada and are monitored against current Consumer expectations. If necessary, Western will revise the product (or work to have a product revised) if it no longer meets the needs of the target market or regulatory requirements.

Western will educate its Representatives to ensure they understand the target market as well as the characteristics of the product.

We will monitor the product, when it is released and while it is used, to make sure it works as we and our Customers expect.

If necessary, we will revise the product information or the applicable insurance policy to reflect its purpose and use, and communicate changes to those affected, as soon as practicable

5. Fair Treatment of Customers Through Distribution Strategies

Western Financial Group distribution strategies are tailored to each product it offers, these strategies consider the interests of target Consumer groups and ensure that Consumers are treated fairly. Western will train and support its Representatives on our products and the interests of the targeted Consumer groups for the product.

Western ensures that Representatives have the knowledge and ability to provide advice which meets Customer needs at the time they are considering coverage, throughout the term of a purchased product, and at the time of a claim if applicable.

Western will monitor Representative conduct activities toward our Customers on an ongoing basis and will deal with a major concern immediately when it comes to our attention.

6. Fair Treatment of Customers by Providing Disclosure to the Customer

Western ensures that Customers are given appropriate information in order to make an informed decision before purchasing a product. This information is accurate, clear, easy-to-understand and it does not mislead or over promise. Western will provide all necessary disclosures required in accordance with all Applicable Laws and Regulations.

Insurance knowledge, experience, and needs differ from Customer to Customer. Therefore, Western Representatives help Customers to understand any feature of the product that could influence their decision. As the complexity of the product or sophistication of the market segment increases, especially when it comes to tax laws and financial guarantees, the Customer is provided with all the outcomes, including the potential downside of selecting products Western offers.

Western provides a breakdown of the key features of the product as well as the rights and obligations of the Customer, including the rights to cancel, claim benefits and complain.

Our agreements with our Representatives require that they provide clear disclosure to the Customer that meets the CCIR and CISRO expectations outlined in their ‘Guidance Conduct of Insurance Business and Fair Treatment of Customers’ and the Principles of Conduct for Insurance Intermediaries.

Western discloses to the Customer the types of business which it is authorized to conduct, the services provided, including whether products are offered from a full range or insurers or from a limited range from an exclusive insurer and what their relationship is with the insurers with whom they contract. Western also discloses if the Representative receives compensation for the sale of insurance products, if there are any conflicts of interest (as outlined in section 2) and all other fees that are charged in addition to the premium.

Western ensures that appropriate disclosure has been made to the Customer in writing before proceeding with an application for insurance.

All documents are accessible in a written format, identify the insurer and provide contact information.

After a policy is purchased, Western will ensure that Customers are provided information which allows them to make informed decisions throughout the lifetime of their contracts.

Western will send notice to the Customer if we change coverage, policy terms or conditions, replace the policy with another, cancel the policy or decide not to renew it. We will follow the law and provide notice to allow the Customer time to take appropriate action. We will notify the Customer of their rights and obligations related to changes in terms and conditions and obtain the Customer’s consent, if required.

We will notify Customers when Western makes changes in ownership, name, address of the head office or operations.

7. Fair Treatment of Customers in Product Promotion

Western is committed to product promotion that is accurate, clear, not misleading and is consistent with what the Customer reasonably expects from the product

Western identifies the insurance company providing a product and provides the contact information on its advertising or promotional materials. These materials are reviewed by Western before they are released to ensure it is appropriate.

Western provides information in a format that is easy-to-read and easy-to-understand, is consistent with the coverage offered, identifies the Insurer and prominently states the basis for any benefits and any significant limitations of the product. If statistics or testimonials are used, they will be truthful, based on fact, and not exaggerated.

Promotional materials will be reviewed by the Marketing, Brand & Customer Experience team before they are released to ensure that the message matches the information and Customer expectations. Western will withdraw and/or correct materials it finds misinterprets or misinforms Customer and will advise all Customers who might be affected as soon as practicable.

Western encourages Customers who have questions or concerns regarding promotional material and their product to contact its Representatives.

8. Fair Treatment to Customers in Providing Relevant, High Quality Advice

Western Customers are provided with recommendations which help them to obtain the coverage best suited for their individual needs.

Giving Customers advice goes beyond providing product information and should include a personalized recommendation on a product based on the disclosed needs of the Customer, so that the Customer can make an informed decision at the time of sale.

Western considers the Customer’s financial knowledge, experience, needs, priorities, situation, ability to pay, and the risks when providing personalized advice that is clear, so the Customer can make a rational and well-informed decision.  

Western provides advice in a written format and documents the basis on which a recommendation is made for each of its Customers in the Customer’s file. Western will, on occasion, review the Customer files for issues. If there are any issues notes, Western will take corrective measures.

Our agreements with our Representatives require that they make recommendations based on the best interest of the Customer and meet the CCIR,CISRO and regulatory expectations related to giving advice, as outlined in CISRO’s ‘Guidance Conduct of Insurance Business and Fair Treatment of Customers’ and the Principles of Conduct for Insurance Intermediaries.

Because Western is ultimately responsible for the fair treatment of Customers, Western provides its Representatives with ongoing training so they are familiar with products and services that are offered as well as changes in the insurance industry, and Applicable Laws and Regulations.

9. Fair treatment of Customers in Claims Handling and Settlement

Western will ensure that claims are handled in a timely and fair manner.

Western will post claim submission processes on our website and will make them available upon request.

Western will implement claims processes that are simple, easy to access, and include all steps from the claim being made up to and including settlement.

Western makes reporting a claim easy and user-friendly, shows empathy and guides its Customers through the process while discussing what benefits are available immediately, timeframes and the steps in the claim process. We will tell claimants about procedures, formalities and common timeframes for claims settlement.

Western encourages and co-operates with Customers to gather all information and documents within a reasonable time.

When Western processes claims, it uses only qualified claim adjusters and examiners. Where it is in the Customer’s best interests, Western will use outside specialists. These claims are examined using transparent and accessible processes and procedures. We will give claimants information about the status of their claim in a timely and fair manner.

We will settle claims based on all coverage or benefits provided by the policy, using fair and reasonable methods to determine values. When applicable, we will illustrate how we have determined a claim payment and explain it in simple language.

Whether a claim is paid or denied, Western provides the Customer with an explanation of the result in easy-to-understand language. If an issue is raised, dispute resolution options are made available to claimants which are balanced, easy to follow and impartial.

Western’s dispute resolution procedures follow a balanced and impartial approach, considering the interests of all parties involved, and have mechanisms in place to review claims disputes to promote fairness and objectivity in decisions.

In uncertain circumstances, Western will look to its Guiding Principles for direction. Western will work with its Customer and others who can help do the right thing in making decisions.

10. Fair Treatment of Customers in Complaints Handling and Dispute Resolution

Western is committed to addressing and resolving Customer concerns in a timely, fair and professional manner. We will use written policies, procedures, and guidelines for fair and consistent handling of complaints.

Our Complaint’s process is posted on our website and will be made available upon request. The process includes clear and accurate information outlining the steps to take and the information needed to report a concern or complaint.

Western will promptly acknowledge receipt of a complaint and provide an estimate of the time required for the review or investigation. We will keep complainants informed about the handling of their complaints throughout the process.

Our processes include keeping a record of each complaint and the measures taken for its resolution. We will analyze complaints received to identify trends and recurring risks and to determine root causes and correct common issues.

We will provide clear, transparent and easy to understand information about independent dispute resolution processes.

11. Fair Treatment of Customers in the Protection of Personal Information

Western takes the information security and privacy of Customers very seriously and we fulfil our legal obligations by collecting personal information appropriately, treating it responsibly and protecting it from unauthorized release.

Western will strive to provide its Customers with a level of comfort regarding the security of personal information it is entrusted with and will maintain safeguards, policies and procedures to protect the privacy of Customer information.

Western uses written policies and procedures for safeguarding our Customers' personal information, which are up-to-date and reflective of best practices to ensure compliance with the provisions of the federal Personal Information Protection and Electronic Documents Act or provincial privacy legislation, as applicable.

Western’s current Privacy Policy is posted on our website and will be made available to Customers upon request.

Our policies and procedures have mechanisms in place to ensure that the Board of Directors and senior management are made aware of the challenges relating to the protection of Customers’ personal information and to demonstrate that privacy protection is part of our business culture.

Western will provide privacy training to all employees and guidance on privacy breach procedures and access to information requests.

For more information, please see the Western Financial Group Inc. and Affiliates Privacy statement at https://westernfinancialgroup.ca/Privacy

Canadian Insurance Services Regulatory Organizations (“CISRO”) 

Registered Insurance Brokers of Ontario (RIBO)