TCF Policy

1. INTRODUCTION

E Geldenhuys and Associates CC (Registration number 1996/006934/23 trading as Renaissance Insurance Brokers (RIB) is a registered financial services provider, operating as a broker which has agency agreements with all major insurers.

RIB adopted a Treat Customers Fairlay (“TCF”) frameword to ensure that the the management of the company are able to provide relevant and prudent management oversight over the activities, procedures and processes of RIB, especially in respect of our application of the TCF principles and is filtered through applicable training to all employees of RIB.

Treating Customers Fairly (TCF) is an outcome based regulatory approach that seeks to ensure that specific, clearly articulated, fairness outcomes for financial service consumers are delivered by regulated firms.

This TCF policy and manual is centered on the guidelines provided by the Regulator to ensure that we consistently deliver fair outcomes to our policyholders. A culture of openness and transparency is vital to succeed with TCF compliance and accordingly we participate in the required reporting in respect of our compliance with TCF.

Our focus on client satisfaction has become deeply entrenched in our business philosophy,ethos, and culture. The focus is boldly demonstrated through the integration and embedding of the principles of Treating Customers Fairly (TCF) in RIB and our relationship with stakeholders.

The responsibility in ensuring that the principles of TCF are always practiced, in any form of client engagement vests with every employee within RIB and each binder holder that we have contract with.

We are a client-based business with the end customer being the forefront of all decisions and product development.

2. THE FSCA AND TCF

The Financial Services Conduct Authority (FSCA) formed the basis of the TCF framework. All organizations, specifically those authorized under the FSCA, are required to embed the TCF principles in governance processes, frameworks and furthermore to demonstrate that they measure their behavior against these key principles, to manage conduct risk and protect their clients.

3. THE OUTCOMES OF TCF

The 6 TCF principles have been adopted within RIB across all business practices, governance and day to day processes.

Outcome 1: Company Culture

Policyholders are confident that they are dealing with companies where the fair treatment of policyholders is central to the company culture and governance.

Outcome 2: Products and Services

Products and services marketed and sold to policyholders are designed to meet the needs of identified client groups and are targeted accordingly.

Outcome 3: Point of Sale

Policyholders are given clear information and are kept appropriately informed before, during and after the time of contracting.

Outcome 4: Advice

Where policyholders receive advice, the advice is suitable and takes account of their circumstances and needs.

Outcome 5: Product and Services Performance

Clients are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and what they have been led to expect.

Outcome 6: Post Sales Barriers

Clients will not face unreasonable post-sale barriers to change products, switch providers, submit aclaim or make a complaint.

4. TCF STANDARDS PER OUTCOME

OUTCOME 1: COMPANY CULTURE

Customers are confident that they are dealing with service providers where the fair treatment of customers is central to our culture

  • To ensure that the business practices of RIB are fully governed with a culture of TCF, management has adopted the TCF framework and is specifically responsible to ensure that it is embedded throughout RIB.
  • All employees of RIB are trained on the TCF framework annually and the embedding thereof in RIB is ensured by the entrenchment thereof in the performance management system of RIB.
  • At RIB we treat our clients as we would want to be treated.
  • Through its client interaction and service delivery, RIB will ensure that it renders services to the client that is honest and fair, with skill, care, and diligence and in the best interests of the client and integrity of RIB.

OUTCOME 2: PRODUCTS AND SERVICES

Products and services marketed and sold to policyholders are designed to meet the needs of identified client groups and are targeted accordingly.

  • RIB has made changes to simplify the product and policy wording.
  • Our representatives ensure that they understand the client’s financial product need by performing a needs analysis for each client in order to obtain information from the client regarding their financial position, product need and objectives.
  • Our products target specific markets.
  • Monitoring tools inform us if a product has shortcomings which we then address immediately.

We ensure that all representatives have a thorough knowledge of the products offered. We further ensure that all new representatives are trained in the products offered.

OUTCOME 3: POINT OF SALE

Policyholders are given clear information and are kept appropriately informed before, during and after thetime of contracting.

  • RIB subscribes to the most meticulous standards in relation to “disclosures” as per the Policyholder Protection Rules of Short-Term Insurance requirements and in line with the prescribed rules of the Insurers. In addition to the PPR, the FAIS Act and The General Codes of Conduct associated with various categories of licenses also governs the RIB way of engagement with our customers. We have documented procedures and minimum requirements to ensure all representatives align with the company conduct.
  • Our representatives are encouraged to explain products using plain language to avoid confusion,provide information which is factually correct and adequate and appropriate in the circumstances.
  • We have addressed excess structures which were previously raised as an issue. We have alsointroduced excess alternatives, i.e., option to reduce or excess waiver.
  • Clients are provided with a comprehensive policy pack which includes the policy schedule and wording.
  • Records of the sale proposal are maintained by the broker and monitored by the insurer.
  • RIB has defined vetting strategies, plans and processes associated within customer engagement across all stages of the customer’s journey within binder holder and registered FSP relationships.

OUTCOME 4: ADVICE

Where policyholders receive advice, the advice is suitable and takes account of their circumstances and needs.

  • RIB’s registered representatives must always understand the client’s needs and their financial situation, to ensure that we are able to make appropriate recommendations to our clients in relation to the most appropriate risk solutions for their circumstances.
  • RIB is committed to ensuring that our representatives meet the requirements set out in section 7(1) (b) of the General Code of Conduct for Authorised Financial Services Providers “whenever reasonable and appropriate, provide to the client any material contractual information and any material illustrations, projections or forecasts in the possession of the provider;” as well as any fit and proper requirements prescribed under the FAIS Act, including but not limited to the FAIS product knowledge and competency requirements.

OUTCOME 5: PRODUCT AND SERVICES PERFORMANCE

Clients are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and what they have been led to expect.

  • Product Design & Product Performance Management
    Processes are in place to provide clients with products that meet their needs, and advises them of risks of particular actions on their part, service standards and processes are communicated to clients.
  • Marketing
    To ensure that customers are not provided with misleading information or misrepresented facts, clients are provided with the relevant documentation and disclosures to the policy and insurer.Policy documents and insurer guidelines govern the way of work within the business and set out the processes, regulatory requirements and minimum standards which need to be complied with by all stakeholders.
  • Governance
    RIB has implemented processes which facilitate the implementation of the TCF principles. These processes also ensure that the fair treatment of customers is prioritized and always at the forefront of staff’s mindset.

OUTCOME 6: POST SALES BARRIERS

Clients will not face unreasonable post-sale barriers to change products, switch providers, submit a claim or make a complaint.

The claims experience must be of a standard and quality which does not prejudice the customer in any manner whatsoever.

Customers are informed of their obligations, and the circumstances under which claims requests will and would not be processed. All clients are provided with policies which detail the terms and conditions related to cover, claim and complaints.

Within the RIB’s Claims department, we also have strong governance and review processes to ensure that customers are not treated unfairly.

Furthermore, we are fully transparent with our customers and ensure that we provide suitable channels for customers to contact us if they have complaints or queries. In addition, we monitor claims and complaint data to ensure that agreed turnaround times and minimum service standards are adhered to.

We are committed to ensuring that we continuously monitor management information relating to complaints and claims and to identify trends of poor customer treatment and to implement corrective measures to ensure that clients do not face any post sales barriers when dealing with RIB or our stakeholders.

The complaints policy is intended to provide guidance pertaining to the handling of complaints.

We are committed to abide by this document and provide service excellence and fairness.

Our Complaints Policy takes cognizance of the following South African legislation and Industry Codes:

  • Consumer Protection Act, 68 of 2008
  • Financial Advisory and Intermediary Services Act, 37 of 2002
  • Financial Services Ombud Schemes Act, 37 of 2004
  • Long-term Insurance Act, 52 of 1998 and Short-term Insurance Act, 53 of 1998 (Policyholder Protection Rules)
  • Association for Savings and Investment in South Africa (ASISA): TCF Best Practices Guideline and Standard on Complaints Resolution
  • Financial Planning Institute (FPI): Professional Standard
  • South African Insurance Association (SAIA): Code of Conduct
  • Training and On-Going Compliance

The business must ensure that all staff and representatives are appropriately educated and comprehensively trained on the principles of TCF. To ensure this, annual training is provided for all staff. As part of our on-going compliance function, all employees and directors will be provided with copies of the TCF policy and manual, which is made available on our intranet.

  • Stakeholder Inclusivity

Information regarding the implementation of and compliance with the TCF outcomes should be provided to management on a regular basis and should be accurate, timely, relevant and consistent.

All complaints must be recorded and reported by our Compliance Administrator acting as the complaints officer, which in turn will be analysed and reported to management, as well as our insurers.

  • Escalation

RIB’s governance framework makes provision for any employee to escalate TCF related concerns or any non-compliance with TCF to management.

COMPLAINTS MANAGEMENT

The complaints management process contains the procedures on how to lodge a complaint and to ensure that we are able to resolve all complaints.

In terms of FAIS, we are required to deal with complaints relating to a financial service that we have rendered.

Complaints dealt with in this process relate to advice rendered by representatives who are employed by the RIB.

Complaints that are not covered by FAIS

We are unable to deal with complaints relating to advice rendered by independent financial advisers, who are not representatives of RIB, financial products, repudiation of any claim, poor investment performance or any administrative service received from the product supplier.

RIB representatives operate under RIB’s financial services provider license (FSP), whereas independent financial advisers operate under separate financial services provider (FSP) licenses.

This means that we have no control over the advice rendered by independent financial advisers. Such complaints must therefore be directed to the independent financial adviser (broker), brokerage or the Financial Services Board (FSB).

How to submit a complaint

If you wish to submit a complaint relating to advice rendered by your financial advisor, we recommend that you firstly contact your financial adviser for assistance. Alternatively, you can direct your complaint to our Complaint Department by email to: ericka@renaissanceinsurance.co.za

RESPONSIBILITIES RELATING TO THE COMPLAINTS PROCEDURE

Client responsibilities:

  • Inform us of your compliant as soon as is reasonably possible
  • Please note that your complaint must be reduced to writing (refer to section “The Financial Advisory & Intermediary Services Act 37 of 2002 (FAIS) – What does FAIS say about complaints?” below).
  • Provide us with all information relating to your complaint (policy/investment number, nature of the complaint, which would include sufficient facts, dates and supporting documentation) to enable us to investigate the complaint

RIB’s responsibilities:

  • The Complaints Resolution officer will acknowledge receipt of the complaint.
  • The Complaints Resolution officer may ask additional information if required.
  • Keep records relating to such complaint for a minimum of (5) five years from when the complaint is received
  • Carry out a full investigation of the advice that your RIB representative has rendered to you and provide you with an objective finding.
  • Formally communicate the finding to you. The process takes approximately four weeks from the date that we receive your complaint (unless communicated otherwise) to complete. This means that you will only receive a resolution after such period.If you are not satisfied with our formal response, your complaint can be escalated to the Ombudsman for Financial Services Providers on
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