Sustainable sales and marketing
For an insurance company, it is important to gain the trust of customers by ensuring that the products and services offered are clearly explained and transparently marketed. The trust that customers have in the Sampo Group companies’ integrity is the foundation of the companies’ positive reputation.
Paying attention to the risks associated with sales and marketing is important to the Sampo Group companies. Such risks include inappropriate customer advice and product sales; lack of clarity in terms, prices, and fees; errors in claims handling; and errors in the complaint process. To minimise the risks and increase value for the customer, the Group companies continuously work to develop and improve customer service, and sales and marketing practices.
The Sampo Group Code of Conduct sets the group-level requirements for responsible sales and marketing practices. In addition, each Group company has adopted supplementary and more detailed policies, guidelines, and processes for their own purposes
To ensure compliance with laws, regulations, and internal policies, the Sampo Group companies have continuous training programmes that develop personal conduct and increase the competence of the companies’ sales teams and other customer representatives. Customer feedback channels are also offered to make it easy for customers to provide feedback on the products and services and complain if they are dissatisfied.
The Sampo Group companies aim to clearly inform customers of their complaint options, as well as to ensure a fair and transparent complaint process. In the case of a complaint, the Group companies’ priority is to discuss with the customer to find a solution that is satisfactory to both parties. If a consensus cannot be achieved, the customer is entitled to appeal to external complaints boards (ECBs) or similar, according to local practices in each operating country. In addition, as required by law, certain Sampo Group companies have internal customer representative functions that the customer can contact to submit a complaint. Regardless of the outcome of appeal cases, the Sampo Group companies always analyse how they can improve their sales and marketing practices.
Group goals and ambitions
The Sampo Group companies’ common goal is to act in the best interests of the customers using sustainable sales and marketing practices.
If’s sales and marketing practices focus on meeting the demands and needs of customers and providing customers with the information necessary to make well-informed decisions. If’s Distribution Policy includes instructions on responsible sales and marketing practices. According to the policy, If and its distributors shall always act honestly, fairly, and professionally, with due care, and in accordance with the best interests of customers.
The sales personnel involved in the distribution of insurance contracts continuously undergo comprehensive training in this area. Training is given according to annual plans on various topics such as insurance products, evaluation of risks and customer needs, legislation and guidelines, business ethics, and conflicts of interest. The training varies depending on the country and business area in question. If also provides training to its external distributors.
If continuously develops and improves the control mechanisms and follow-up routines regarding insurance product and service information, as well as marketing communications. If monitors that training requirements are fulfilled by external distributors and that products are sold to the right target group, in accordance with the company’s instructions.
In If’s remuneration structure, fixed compensation represents a sufficiently high proportion of the total remuneration to avoid employees being overly dependent on variable compensation and to ensure that they act in the best interests of customers. If does not remunerate or assess the performance of its employees in a way that conflicts with the duty to act in the best interests of customers. For example, there are no sales targets that could provide an incentive to recommend a particular insurance product to a customer when a different insurance product would better meet the customer’s needs. In addition, variable compensation programmes include a clause that gives the company the right to cancel, in whole or in part, the payment of variable compensation, if material, non-acceptable risk-taking or breaches of internal or external business rules have materialised.
Topdanmark wants its customers to have the right coverage to match their needs and wishes. The company is aware that this requires good and correct customer advice in sales and consulting situations, from competent employees.
Topdanmark has one central and several local compliance departments, ensuring that sales personnel meet quality requirements and follow agreed business procedures and applicable laws and regulations. There is a reporting system in place, which ensures that inappropriate situations are evaluated to improve customer service and avoid errors in the future.
Topdanmark provides customers with easily accessible information on products, price, and coverage. Therefore, customers can get an overview of what can be expected from the insurance policy. Furthermore, all text used in customer communication is always checked to ensure that the content is understandable to the average customer. Topdanmark improves product information continuously, based on customer feedback.
Topdanmark ensures the competence of employees by providing them with adequate training. All salespeople are trained at the Insurance Academy, and new employees are trained in Topdanmark's business and sales procedures. In addition, employees continuously receive training in professional and interpersonal skills.
In Topdanmark ’s remuneration structure, fixed compensation represents a sufficiently high proportion of the total remuneration to avoid employees being overly dependent on variable compensation and to ensure that they act in the best interests of customers. Most of the employees in Topdanmark have fixed compensation and no variable compensation. Topdanmark does not remunerate or assess the performance of its employees in a way that conflicts with the duty to act in the best interests of customers. For example, there are no sales targets that could provide an incentive to recommend a particular insurance product to a customer when a different insurance product would better meet the customer’s needs. In addition, variable compensation programmes include a clause that gives the company the right to cancel the payment of variable compensation, if material, non-acceptable risk-taking or breaches of internal or external business rules have materialised.
Hastings’ customers can purchase their products digitally or via the contact centre. Regardless of the channel, customers are provided with clear and transparent information prior to purchasing a policy, with full disclosure provided on product coverage, coverage limitations, exclusions, excess levels, and any fees connected to the ongoing management of their insurance policy.
At Hastings, the existing sustainable sales and marketing conduct framework is based on the Financial Conduct Authority’s (FCA) six best interest outcomes. The company also assesses each product at least annually to ensure it remains appropriate.
Hastings has robust controls in place to ensure that information provided to customers is clearly accessible, relevant, and timely before a customer commits to any purchase, and the company satisfies all regulatory and conduct obligations. The associated controls and measures are regularly assessed and reported to Hastings’ executive and board committees, whereby Hastings focuses on customer conduct. This includes outcomes, experience, and value measures with a focus on customer vulnerability.
For those customers in vulnerable circumstances, Hastings has a well adopted user experience and user interface design process. Design principles are used to deliberately avoid using dark patterns (a digital term whereby designs are used on websites and in apps that make users do things they did not mean to, like buying or signing up for something). This eliminates any risk or intent to deceive customers.
In accordance with the Sampo Group Code of Conduct and the company’s internal guidelines, Mandatum is committed to transparent, understandable, and not-misleading communication in both sales and marketing. The company is also committed to offering customers comprehensive and accurate product information, as well as information on costs, conditions, and product risks. Mandatum has internal instructions for marketing and customer communications, and specified groups of customers to whom certain products or campaigns may not be marketed.
Mandatum has an extensive permission structure to handle individual permissions related to marketing and customer communications, and the GDPR processes embedded into marketing processes (e.g. personal data deletion). Mandatum’s marketing and customer communications follow regulations and key principles and are reviewed by the company’s Legal department before publication.
When offering investment products, Mandatum always evaluates the customer’s risk profile. The risk profile is based on answers given in the investor profile survey. The survey gathers information on the customer’s investment experience, risk tolerance, and grounds and goals for investing. The offered investment product is always related to the customer’s risk profile, so it is certain that the customer can choose a product that suits their needs.
Mandatum offers mandatory training (minimum 15 hours/year/person) to all customer-facing employees. The training includes training on the needs-based sales model and sales process, new products and services, regulatory demands such as anti-money laundering, ESG, and the IDD, tools and systems used in sales, and customer data documentation. In addition, all customer-facing employees must complete certain product and policy training courses to gain a sales license. To secure the know-how of employees involved with sales, leaders take part in customer meetings during the year.
Responsible sales practices include annual sales commission negotiations. Mandatum’s sales commissions follow IDD demands to avoid any conflict of interests between the customer and a salesperson. To secure ethical sales, sales agreements also include ethical objectives, such as internally defined levels of customer satisfaction. In addition, Mandatum does not pay sales commissions before the demands set by the regulation have been met.