Learn more about our:
- Modern Slavery Policy
- Product Development & Distribution Policy
- Customer Vulnerability and Financial Hardship Policy
Modern Slavery Statement and Policy
Our Modern Slavery Statement
Last Updated: 1 July 2021
To read our latest Marsh McLennan Modern Slavery Statement, please download a copy here.
Our Modern Slavery Policy
Last Updated: 1 July 2020
This Policy operates in Australia and covers Marsh Pty Ltd and its related entities (“Marsh”). It complements Marsh’s code of conduct, The Greater Good, which sets out the standards weexpect of our colleagues and business partners.
Modern slavery can occur in various forms, including forced or compulsory labour, discriminatory employment practices, human trafficking, debt bondage or bonded labour, or child labour.
We are committed to conducting our activities fairly, honestly and with integrity, in accordance with the applicable laws. We do not tolerate modern slavery in any part of our business, or in the business of our upstream or downstream business partners. We are committed to ensuring that these type of activities do not take place in our supply chains.
How do we identify Modern Slavery Risks?
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all colleagues working for Marsh. Colleagues are required to avoid any activity which might lead to a breach of this Policy.
If you believe or suspect that slavery is occurring, you must notify your manager as soon as possible, or report the matter via ethicscomplianceline.com.
If you are unsure whether a particular act, the treatment of workers or their working conditions may constitute modern slavery, you should still raise the matter so that it can be investigated.
We aim to encourage openness. We will not tolerate retaliation against any colleague who raises a concern in good faith as a result of reporting their suspicion that modern slavery may be taking place in our business or supply chains.
Members of the public or people not employed by Marsh should write to: The Chief Compliance Officer, Marsh Pty Ltd, One International Towers Sydney, 100 Barangaroo Avenue, Sydney NSW 2000 or email email@example.com to raise any concern or suspicion of modern slavery in any part of our business or related supply chain.
How do we enforce the Policy?
If an issue is identified in the business of our upstream or downstream business partners, we will work with them to prepare a corrective action plan and resolve the matter within an agreed timeframe.
We reserve the right to terminate commercial relationships with any business partner if they are found to be involved in modern slavery.
Any colleague who breaches this Policy will face disciplinary action which could result in dismissal for misconduct.
How do we raise awareness of this Policy?
A copy of this Policy is available on our website and on our internal intranet pages for colleagues.
General awareness training is provided to all colleagues when they join Marsh.
Those colleagues closely involved in recruitment and procurement are trained in this Policy.
Our approach to modern slavery must be communicated to all our upstream or downstream business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Who is responsible for the Policy?
Responsibility for this Policy rests ultimately with the Board of Directors of Marsh Pty Ltd.
Managers at all levels are responsible for ensuring those reporting to them not only understand but also comply with the Policy.
Product Development & Distribution Policy
This Policy sets out the JLT Risk Solutions Pty Ltd (JLT) approach to developing and distributing retail insurance products for its appropriate target markets where JLT is acting on behalf of insurers. This Policy aims to support JLT’s customer focussed approach by aiming to provide our customers with products that are consistent with their likely objectives, financial situations and needs.
To ensure our design and distribution obligations are met, our customers’ needs will remain at the centre of our product lifecycle including:
1. The product design stage;
2. The product delivery stage;
3. The product review stage; and
4. The product modification or decommission stage.
In further supporting this objective, JLT will have in place Target Market Determinations (TMDs) which will guide the distribution of our products for appropriate target markets. These TMDs will be available on JLT’s and/or the relevant insurer’s website for all relevant products from 5 October 2021.
2. Product Design
The first stage of a product’s lifecycle is the design stage. JLT is committed to ensuring our products are designed so as to be consistent with the likely objectives, financial situations and needs of our customers for whom they are intended.
We recognise that we have a range of customers with different complex and multifaceted interests that should be considered in the development and design of our products.
When new products are developed or our current products are updated, we will start by assessing the likely objectives, financial situations and needs of the target market. This assessment may include:
- market research and feedback to assist us in understanding the customers likely objectives;
- needs analysis of internal and external data, industry data and other metrics; and
- our own experience and expertise.
From 5 October 2021, TMDs will be available for retail products describing the type of customers comprising the target market for the insurance product.
3. Product Delivery
After a product has been appropriately designed, the product will be assessed to ensure that we identify the distribution channels and arrangements that are reasonably likely to result in our products reaching consumers in the target market.
We will take all reasonable steps to ensure our retail products are distributed in accordance with the TMDs including: assessing the most appropriate distribution channels for each individual product; setting distribution conditions that our distributors must follow including distribution in line with TMDs; obtaining information about the distribution from distributors; customer feedback and taking appropriate action in response; and adherence to our regulatory requirements.
4. Product Design and Delivery Review
Regular reviews will take place to ensure that our retail products are operating the way they were designed to operate and that they continue to meet our customers’ needs. Regular reviews are also important to ensure our products are distributed in a way that is likely to reach our designated target market.
Product reviews may include measuring complaints, customer feedback and other claims data and market conditions whilst also drawing on the experience of our own staff.
Commencing from 5 October 2021, product design and delivery reviews may also occur in response to TMD review triggers.
5. Product Modification or Decommission
Following a product review, it may be assessed that the product or its distribution channel require modification to ensure they remain consistent in achieving the likely objectives, financial situation and needs of our customers.
Our products may also require modification in response to regulatory changes. If following a review it is identified that a product is not delivering customer value and cannot be enhanced or distributed in a manner consistent with achieving the likely objectives, financial situation and needs of our customers, it may be decided that the product be decommissioned.
This Policy has been developed by JLT in conjunction with Marsh Legal, Compliance & Public Affairs team and will be reviewed on an annual basis or as required.
Date of next review: 1 July 2022
JLT Product Development and Distribution Policy v.1.0.
Customer Vulnerability and Financial Hardship Policy
Last updated: 15 November 2021
This policy applies to the following companies:
- Marsh Pty Ltd (ACN 004 651 652);
- Marsh & McLennan Agency Pty Ltd (ACN 000 668 584);
- Victor Insurance Australia Pty Ltd (ACN 161 243 198);
- Marsh Advantage Insurance Pty Ltd (ACN 081 358 303);
- Mercury Insurance Services (ACN 007 332 461);
- JLT Risk Solutions Pty Ltd (ACN 009 098 864);
- Echelon Australia Pty Ltd (ACN 085 720 056);
- Victor Insurance Pty Ltd (ACN 146 607 838);
- JLT Group Services Pty Ltd (ACN 004 485 214); and
- The Recovre Group Pty Ltd (ACN 003 330 167).
All references to Marsh, we, our, us etc. should be construed as a reference to the relevant entity.
Marsh recognises that a customer’s vulnerability can impact their interaction with Marsh and Marsh is committed to helping and supporting people experiencing vulnerability by taking ‘extra care’ with them through such interaction. The purpose of this policy is to:
- outline Marsh’s internal processes and procedures which have been implemented to help minimise the risk of harm in Marsh’s interactions with customers who are experiencing vulnerability; and
- help ensure that Marsh provides those customers with timely, consistent and targeted assistance.
For the purposes of this policy, ‘customer’ includes an individual insured, or a third party beneficiary, or member of an insurance product or other financial product Marsh issues, arranges or deals in. It also includes a client or customer or potential client or customer of Marsh, or an individual from which Marsh is seeking to recover money.
Marsh also recognises that family and domestic violence is one aspect that can particularly impact upon a customer’s vulnerability. For this reason, whilst all the procedures outlined within this policy apply equally to those experiencing family or domestic violence, Marsh also has specific procedures it implements to assist customers experiencing family and domestic violence. Where relevant, those procedures are outlined within this policy.
A vulnerable customer is a customer who, due to a certain factor or characteristic they possess, can experience harm or disadvantage in their interaction with Marsh or in their insurance arrangements more generally. A person’s vulnerability may be due to a range of factors such as: age; disability; mental health conditions; physical health conditions; domestic or family violence; language barriers; literacy barriers; cultural background; Aboriginal or Torres Strait Islander status; remote location; or financial distress. This is not an exhaustive definition.
As noted above, experiencing domestic or family violence is a specific type of vulnerability. Domestic violence refers to acts of violence by a family member. This violence can include threats and intimidation and may be sexual abuse, financial or economic abuse, emotional or psychological abuse, social abuse and/or damage to property. The Family Law Act 1975 (Cth) defines ‘family violence’ as ‘violent, threatening or other behaviour by a person that coerces or controls a member of the person’s family… or causes the family member to be fearful’.
Marsh Employees who deal with vulnerable customers as defined by this policy will receive mandatory training. This training module helps our employees:
- identify and understand if a customer may be vulnerable;
- decide how best and to what extent we can support that customer;
- take account for a customer’s particular needs in relation to their vulnerability; and
- engage with a vulnerable customer with sensitivity, dignity, respect and compassion.
Identification of vulnerable customers
At Marsh, we understand that customers may be reluctant or unable to disclose that they are experiencing vulnerability. As outlined above, Marsh employees receive training to teach them to identify certain signs that may indicate a customer is experiencing vulnerability. It will also teach them techniques to facilitate an environment where customers experiencing vulnerability feel comfortable to disclose their circumstances, as well as other techniques to improve the customer’s experience. In particular, our employees must not require evidence of vulnerability, such as an intervention order or medical certificate, from the customer before they enact the procedures set out in this policy. Instead, we utilise these procedures if a customer self-identifies as experiencing vulnerability or we recognise signs or otherwise identify that the customer may be vulnerable. Having adequate identification processes in place also allows Marsh to best select the course of action appropriate to the vulnerable customer as outlined within this policy. For example, employees can treat claims as a matter of priority, organise/provide financial hardship help, escalate an issue to a more senior person, or refer the customer to specialist services for further guidance.
Interaction with vulnerable customers
Once we identify customers who may be experiencing vulnerability, we interact with them in a supportive manner. Therefore, we aim to always engage in careful and sensitive conversations with vulnerable customers. We keep such conversations confidential and ensure the confidential handling of all private and confidential information collected about a customer who may be experiencing vulnerability. This is particularly important in relation to customers experiencing family and domestic violence so that we do not disclose to the perpetrator of such violence that we are aware of the violence or other personal details of the customer that may enable the perpetrator to continue the family violence The training provided to our employees covers methods to interact with customers who have been identified as vulnerable to ensure that support, sensitivity and confidentiality are always maintained in our communications with them.
In our communications with customers affected by family or domestic violence, we aim to minimise the amount of times a customer has to disclose their family violence situation. We do not wish for customers to have to repeat their disclosures as we understand that reliving the experience can be uncomfortable and even traumatising. To do this, we may flag a customer’s account when we have identified that they may be affected by family violence. This also allows us to maintain that customer’s confidentiality and privacy more effectively, and implement specific security measures. We have internal procedures addressing confidentiality, privacy and security in relation to customers experiencing vulnerability. For example, before we communicate with customers about such issues, we will need to be sure of their identification and we do adopt security measures to ensure this.
We would like to make our customers aware of some strategies that can help us in our interactions with those who are affected by vulnerability. Specifically please:
- let us know if you would prefer to speak to a specific employee. We understand that, if you have opened up to an employee about your circumstance in the past, it would likely be more comfortable for you to make any further communications about your circumstances to them. We also understand that you might want to open up about these issues to an employee of a specific gender only;
- tell us if you need additional support from someone else (for example, a lawyer, consumer representative, interpreter or friend) in your interaction with us. As we are aware customers experiencing vulnerability may need a support person, we will recognise this and allow for it in all reasonable ways. Customers who need an interpreter can use a free government phone interpreting service called the TIS National interpreting Service available at https://www.tisnational.gov.au/. This link and further information about interpreting services is available on our website.
- tell us if you find it difficult to adhere to our identification processes. We are aware people from an Aboriginal or Torres Strait Islander community or a non-English speaking background might not have the identification documents that we require from them in certain circumstances. In such circumstances, we will take reasonable measures to support those customers by ensuring our processes for identification and verification are flexible; and
- also let us know if, when we are communicating with you about issues relating to family or domestic violence, you are not in a position to talk about such issues. This may be the case because the perpetrator is present or may be monitoring your calls or mobile phone usage. We will not communicate with you about these issues over email or over the internet generally because of the sensitivity of the matter and the possibility that other people within your family (the perpetrator or otherwise) may have access to your email account or internet browser.
Financial hardship help
Some customers may be vulnerable because they are experiencing financial hardship. A customer is experiencing financial hardship when they have difficulty meeting their financial obligations to us or their insurer. If a customer is experiencing financial hardship they may be entitled to financial hardship support. The support that we provide does not include support with paying the premiums under an insurance policy, but we will refer this matter to the insurer. A customer also has a right to ask us to fast-track a claim if they have an urgent financial need to have that claim paid. We must do what is reasonably possible to accommodate this.
For a customer to apply for financial hardship support, they must fill out a form located here. Once complete, this form will be sent to the Marsh Customer Vulnerability Officer who can be contacted at:
Phone: (02) 7252 2450
We will notify the customer in writing of our decision on their financial hardship support application, unless we have asked them for additional information. If we do ask for additional information, the customer has 21 calendar days from the date of that request to provide the information, unless otherwise agreed. If the customer provides the requested information, we will, within 21 calendar days of receiving that information, provide written notice communicating our decision on the customer’s financial hardship support application to the customer. If the customer does not provide all the information within the designated 21 calendar days, then we will communicate our decision on the customer’s financial hardship support application in writing within 7 calendar days of that deadline passing. If we are taking action to recover an amount from a customer, we will put that action on hold while we are assessing the customer’s application for financial hardship support.
Where it is decided that a customer is to receive financial hardship support, then we will work with that customer (and, where relevant, the insurer) to implement an arrangement that could include any one or more of the following:
- waiving our service fees;
- our release or discharge of the customer’s debt to us;
- delaying the date on which a payment must be made by the customer;
- the customer paying us in instalments;
- the payment of a reduced lump sum amount;
- the delay of one or more instalment payments for an arranged period;
- deducting the excess from the claim amount;
- waiving the excess; and/or
- expediting a claims payment.
We make no guarantee that any application for financial hardship support will be accepted and, in many cases, where we are not the issuer of the product or acting on their behalf, we will not be able to grant the type of assistance sought. For example, if we are not acting on behalf of the insurer, any help in relation to premium payments will be granted at the discretion of the insurer and we will refer your application to the insurer.
We are also aware that customers who experience family or domestic violence may also experience financial hardship, particularly where they are a victim of financial abuse. We will aim to determine whether, due to a customer’s circumstance of experiencing family or domestic violence, a customer is experiencing financial hardship. If a customer is experiencing financial hardship due to family violence, we will work with them (and the insurer) with the aim of formulating options so that they can retain their policy if they cannot pay their premium. These options may include:
- changing the benefit structure or the sum insured of the policy;
- reducing the benefits of the policy; and
- pausing premium payments, without cancelling the policy.
Where we are assessing a request for financial hardship assistance for a customer experiencing family or domestic violence, and the perpetrator is a joint policy holder, we will not need the consent of the perpetrator to conduct the assessment. If a customer cannot obtain the relevant documents usually required to undertake a financial hardship assessment due to their circumstance of experiencing family violence, we will take this into account.
In certain circumstances, we will not be well-placed to provide help or support to persons experiencing vulnerability, particularly outside the scope of the financial relationship Marsh has with the customer. Where employees identify that this is the case, they will refer the customer to external legal or support organisations. A list of external organisations which may be helpful to customers experiencing vulnerability is provided below.
- Kildonan UnitingCare
- 1800 RESPECT
- Lifeline (13 11 14)
- Beyond Blue
Australian Capital Territory
- Legal Aid ACT
- Aboriginal Legal Service ACT
New South Wales
- NSW Health Education Centre Against Violence
- Women’s Domestic Violence Court Advocacy Service
- Gendered Violence Research Network, UNSW
- Ask LOIS (Women’s Legal Service NSW)
- LawAccess NSW
- Legal Aid NSW
- Aboriginal Legal Service NSW
- Northern Territory Legal Aid Commission
- Queensland Centre for Domestic and Family Violence Research
- Legal Aid Queensland
- Legal Services Commission of South Australia
- Legal Aid Commission of Tasmania
- Domestic Violence Resource Centre Victoria
- Victoria Legal Aid
- Women’s Council for Domestic and Family Violence Services
- Legal Aid WA