Compliance - it's also a personal responsibility

Businesses operating within general insurance are very much aware of their compliance responsibilities and have (1) governance & frameworks; (2) people & culture; (3) process & procedures; & (4) systems & reporting in place to enable compliant outcomes to be produced.

However, every person working in General Insurance also has a personal responsibility to operate within the boundaries of the law and industry Codes. Generally, senior people fill the roles of directors, officers, fit & proper people, accountable persons and responsible managers however, this does not reduce the obligation that we all have to ensure general insurance products and services are provided ethically, efficiently, honestly and fairly.

The influence on compliance by individuals is both direct (through their own conduct) and indirect (through discussions, raising matters and speaking out)

Let's explore this influence in greater detail

Tips for individuals

1. Be informed and aware - financial firms must ensure their representatives (such term includes employees) are trained and competent to provide the financial servcices. Individuals must personally ensure they are aware of the obligations (legal and Code) that apply to the area they work within. Think of driving a car, as a driver you have certain personal responsibilities in operating the vehicle in accordance with the road rules. This is no different if you work in sales, underwriting, broking, claims, finance, risk & compliance, human resources, admin servcies, loss assessing, repairer, expert etc. It is incumbent upon you to know the obligations that apply to your area. Part of this obligation is not only attending mandatory training but genuinely ensuring that you understand what is required of you to be compliant
2. follow the Company's rules and procedures the Company's compliance arrangements are designed to protect by providing a safe environment within which to do business. They are designed to protect you as an individual, in addition to the customer, company and other stakeholders. It follows that you should act in accordance with company policies, procedures, guidelines and processes. If you think the process is cumbersome or does not provide a great customer outcome you simply can't not adhere to the process. You must understand the purpose of the process and if it needs to be changed, do something to enable the change
3. keep your promises - this has 2 limbs: firstly, if you tell a customer that you will do something - do it. Return their call, provide the additional information or documentation within the timeframe promised. Secondly, if your company promises something, ensure that it is done. How do you know that the customer has received a '10% discount for having multiple policies'. This leads to the next tip...
4. be curious - as a corollary to 'keep your promises', if something doesn't look right or sound right, don't shrug it off or leave it to someone else. Be curious & dig deeper or raise the incident or complaint. However if the responsibility to investigate is with someone else don't wash your hands and say 'I've passed the baton', there is a customer(s) relying on you to be their advocate. This leads to the next tip...
5. be accountable - in the above example you've identified a potential incident or complaint as it appears that a customer didn't receive their 10% discount (as promised). I would be saying to myself, if this customer didn't get their discount, what about others? Accountability means ensuring that action is being taken even if outside your area of responsibility. Who is responsible? What are they doing? Who is speaking to the customer?
6. hold others accountable - it's a team effort to be compliant. if you need someone to do something to enable you to provide compliant services and products to customers then ask that person what are they going to do and by when. This is when influencing and empathy skills come to the fore. However, you can't simply stand-by, do nothing and watch a non-compliant event unfold. This is when you must engage your team leader or a senior person. Additionally, if a process or system is outdated or no longer meets customers requirements - do something about it.
7. ignore organisational hierarchy - a person may be more senior than you but you have an overarching obligation to your company to ensure that the company is compliant and does not breach laws or Code. Don't be afraid to go outside reporting lines to raise concerns (after you have exhausted all other avenues).
8. challenge decisions - if a decision doesn't sit right with you because it may lead to detrimental or unethical outcomes you need to ensure your voice is heard. If the behaviour or conduct that you observe amounts to misconduct there are options open to you such as whistleblowing (however seek legal advice first before going down this path). Always ask yourself, how comfortable would I be if this conversation, decision etc became publicly known? Don't allow yourself to be involved in a situation because you simply did nothing. Being aware creates an obligation on you to react - how you react is your choice, choose wisely and seek advice from a mentor.
9. what is the customer not telling me? this could be renamed 'customers experiencing vulnerability.' Poor communication continues to be the number 1 root cause of complaints. Why is the customer feeling this way? Why is the customer frustrated? What is happening in the customers life that I'm not aware of? are all good questions to ask yourself before responding to the customers frustrations. Take the time to better understand the customer's position. this leads to the next point...
10. be an advocate for your customer - be in the moment. The customer that you are dealing with at any one point in time sees you as the organisation. How you respond influences the customers view of the firm. Refer to points 4 and 5. If you rely upon others internally to enable you to deliver awesome customer experiences then you need to be that customers advocate internally. This is vital for complaints. Who is representing the voice of the customer when making decisions as part of internal dispute resolution?
11. be mindful of the shadow you cast - each one of us, not just leaders, has a reputation. What do you want to be known for? What are your personal ethics and what would you do if your firm crosses your ethical boundaries? If you think something is wrong, it most likely is. Be open to justification but be careful not to allow yourself to justify an otherwise bad decision. There is a balance between meeting the needs of the customer and meeting the needs of the firm. Ethical considerations must be part of that balance.

People as a key control

Compliance frameworks, governance, process, procedures, training and systems are only as good as the people who deliver the products and services. People are critical to creating and maintaining a compliant environment, however it goes beyond merely identifying and raising incidents and complaints.

People must be aware of the laws and codes that impact the area they operate within and ensure, through their own actions or their observation of the actions of others, that products and services are delivered in a manner that meets the customers needs and requirements and does not lead to harm or detriment.

This is when compliance becomes 'part of the way that we do things around here'.