We are committed to providing support to Customers experiencing Financial Hardship. This Financial Hardship Policy Statement (“Policy”) sets out how we will support Customers who are affected by Financial Hardship and has been endorsed by our Board.
The Policy is maintained and reviewed regularly by Senior Management. Senior management
References to “you” means you as a director, employee or other person who works for us. For the purposes of this Policy, “Customer” means an individual insured, a third-party beneficiary or an individual from whom we are seeking to collect or recover money.
The purpose of this Policy is to set out:
This Policy applies to all products and services that we offer.
Our senior management are responsible for implementing this Policy and will also communicate the content of the Policy to staff and will ensure there is appropriate training and monitoring of compliance.
Senior management reports to the Board at least annually and at any such time as a matter of material concern arises (including in respect of any material breach of this Policy).
Our senior management understand the relevant legislation and regulations and have the full support of the Board in carrying out their responsibilities.
Senior management’s responsibilities include:
If you have any queries or concerns regarding any financial or domestic abuse issue you should contact us immediately and request the matter be referred to one of our senior management team.
Definition of Financial Hardship
For the purposes of this Policy, “Financial Hardship” means difficulty meeting financial obligations, including obligations you owe to us.
Financial hardship has the following characteristics:
All of the above characteristics must be present for there to be Financial Hardship.
Who is entitled to support?
The following Customers will be entitled to support under this Policy:
What are the causes of Financial Hardship?
Common causes of Financial Hardship include:
The above causes are indicators of Financial Hardship. The Customer will still need to meet all of the characteristics of Financial Hardship as described above (significant, urgent, unforeseen and temporary) to be eligible for support under the terms of this Policy.
Our Approach to Financial Hardship
Where a Customer requests assistance under the Policy, we will:
We may request any of the following documents from the Customer in order to make our assessment provided that they are reasonably necessary for us to make the assessment:
If further information is required from a Customer before a decision can be made, we must communicate this to the Customer as early as possible and be specific about the information required.
We must communicate with the Customer about their application and where possible, use their preferred method of communication. If the Customer has nominated a representative, then we must keep that person updated about the Customer’s request for Financial Hardship support, unless the Customer has requested otherwise.
What support IS AVAILABLE TO A Customer?
When determining what support will be provided to a Customer, we will adopt a case-by-case approach to dealing with the following:
When determining the most appropriate option for a Customer, we may consider a combination of the above options. Additionally, we will consider a release, discharge or waiver of a debt. Where we release, discharge or waive a debt, we may be asked by a Customer to notify a financial institution with an interest in their insurance policy that they are entitled to Financial Hardship Support and that we have released, discharged or waived a debt or obligation. We must agree to assist Customers who make such a request and provide the necessary information to the financial institution in writing.
Approval escalation process
Firstly, an application request is initially sent to a member of the senior management for consideration. Secondly, if required, senior management will then send the application to the Board of Directors or any relevant insurer involved for approval before providing the option to the Customer.
When must we respond?
We must inform the Customer in writing of the result of their application within 21 calendar days after receipt of the application, or where we have asked for more information and this has been provided to us within 21 calendar days (or such longer period as agreed), within 21 calendar days after we have received the additional information.
Senior management will maintain a register of relevant communications. If we have requested further information from the Customer and this has not been forthcoming within 21 days (or the agreed timeframe), we must inform the Customer within 7 days after such deadline passing, of the outcome of their application.
Where we have agreed a particular option with the Customer, the details of such option should be included in the communication with the Customer.
Where we have decided that the Customer is not eligible for Financial Hardship Support, we must provide the reasons for this decision when we inform them of the result of their application and about our Complaints process.
Where we have identified the Customer as being eligible for Financial Hardship support but are unable to agree on the terms of such support, we will inform them in writing of our Complaints process.
Where a Customer informs us that they intend to declare bankruptcy, we must work with them to determine the amount owed to us and provide written confirmation of such amount. If an amount cannot be agreed with the Customer, we will notify them of our Complaints policy.
Working with Insurers and other representatives
We will work with our insurers and ensure that they have policies in place to deal with Financial Hardship and training programs in place to handle the situation appropriately.
For any Collection Agents or Solicitors collecting money on our, we must ensure that:
Financial Hardship Application Form
Any Customers who are experiencing Financial Hardship are to complete the Financial Hardship Application Form which is available by contacting any of our offices by phone, email or in writing and requesting the form.
We believe that it is of critical importance that all our relevant members of staff receive an appropriate level of training on how to assist Customers in dealing with financial hardship.
This includes educating our people on how to recognise and address financial hardship and providing them with the tools and resources necessary to assist you wherever possible.