Noble Oak has the strongest family violence policy in the life insurance industry.

This was the finding of a desktop audit undertaken to evaluate the family violence policies of the 15 subscribers to the Life Insurance Code of Practice required to have a family violence policy.

The 2023 Life Insurance Code of Practice introduced new provisions requiring subscribers to have family violence policies available online for their customers by 1 July 2023.

The desktop audit examined whether subscribers family violence policies in August and September 2023 met the 11 areas required to be addressed by the Life Insurance Family and Domestic Violence Policy. Policies were judged as to whether they met the requirement, partly met the requirement or did not meet the requirement at all.

Only Noble Oak achieved an 11 out of 11 score. The policy was found to have definitive language and specific measures that detail how they will help those subject to family violence. One insurer (Metlife) achieved 10 out 11, and one insurer (Resolution Life) achieved a 8 out of 11.

“We are pleased to see Noble Oak stepping up and other insurers making solid commitments to assisting Australians subject to family violence,” said Karen Cox.

“Family violence is a scourge and life insurance can unfortunately be intentionally or unintentionally used by perpetrators to harm victims. Perpetrators can, for example, take out life insurance policies on those they are perpetrating against, or can provide inaccurate information to insurers to jeopardise the policy. Survivors of family violence can also be exposed to further risk by insurance claims handling processes, including being required to contact a perpetrator.”

“Strong, clear and effective family violence policies, implemented well, can go a long way to start addressing the issues family violence victims face. But it is critical that these policies be backed up by a strong culture of supporting vulnerable consumers and putting the appropriate systems in place to not just talk the talk but to walk the walk.”

Disappointingly a little over half the subscribers scored 5.5 out of 11 or less. Five insurers scored less than 4 or less out of 11.

“We hope this research can highlight to all life insurers where they can improve and learn from each other’s policies to better serve family violence victims. Ideally, we would prefer the provision of strong protections for victims of family violence not be an area of competitive tension between insurers. The inclusion of all key elements of the policy as minimum standards under the Code, rather than mere “good practice” that is voluntary and aspirational in nature, is essential to ensure that consumers are not left in the lurch just because they chose one insurer over another.”

The full desktop audit can be obtained on the Financial Rights publications page: https://financialrights.org.au/publication/

Background

Clause 6.6 of the 2023 Life Insurance Code commits all subscribers who provide retail insurance products to:

… have a publicly available policy on our website about how we will support you if you are affected by family violence .

The accompanying Life Insurance Family and Domestic Violence Policy recommends that:

Each insurer should develop and implement a customer focussed family and domestic violence policy that covers the following areas:

1. making sure that safety is paramount for customers affected by family and domestic violence through the protection of private and confidential information. These measures include taking the customer’s reasonable communication preferences into account with mechanisms to ensure adherence to these and using technology to improve customer safety
2. training to ensure employees are equipped to respond appropriately to customers affected by family and domestic violence. This includes enabling early recognition of customers who are affected by family and domestic violence
3. minimising the number of times a customer affected by family and domestic violence needs to disclose information about their abuse
4. promoting, enabling and arranging access to financial hardship help
5. informing customers and employees directly and regularly with updated online and printed material about information and assistance available to customers experiencing family and domestic violence
6. referring customers and employees to specialist support services; and
7. supporting employees who:
   1. are affected by family and domestic violence, and/or
   2. experience vicarious trauma after serving affected customers or assisting affected colleagues
8. Commitment to the customer that their family and domestic violence situation will have no adverse effect on their claim if applicable
9. taking family and domestic violence into consideration when designing products
10. outlining a complaints procedure for customers to lodge any complaints with respect to compliance with the customer family and domestic violence policy
11. regular monitoring of the customer family and domestic violence policy, its associated procedures, and how it is working in practice in support of customers experiencing family and domestic violence

To achieve a best practice family violence policy, Life Insurance Code subscribers should:

• adopt the approach of the Noble Oak policy which sets out why each of the 11 areas are important and puts specific measures in place to address each issue: see commentary under Noble Oak in Appendix A; and
• in addition, include the following specific commitments found in other subscriber family violence policies that provide further protections for vulnerable consumers:
• for safety reasons, include a large button to navigate quickly to another website: see the Allianz, Resolution Life, and TAL policy;
• specifically state that employees will be supported if vicariously affected after helping affected customers: see the AIA, Allianz, Metlife, Resolution Life and TAL policies;
• do not require notification to the police of about a perpetrator of family or domestic violence: Noble Oak and Resolution Life.

Financial Rights also recommends that the Council of Australian Life Insurers (CALI) examine the commitment made under the Code and accompanying guide to:

• remove ambiguity from the list of requirements for a Family Violence Policy;
• examine specific issues that arise with respect to the interaction of family violence and life insurance, including life insurance product and service design features that may empower perpetrators to hold life insurance policies over those they are perpetrating against;
• include key elements of the Family Violence Guide in the Life Insurance Code itself to empowers the Life Code Compliance Committee (LCCC)to monitor and assess subscriber policies and compliance.
• CALI or the LCCC maintain a central page providing links to each subscriber’s family violence policy for ease of access.

Contact

For further information contact Drew MacRae media@financialrights.org.au or 0404 604 978