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As a licensed life insurer in NZ, we operate under regulations set by the Financial Markets Authority (FMA). The regulations include an obligation to establish, implement, and maintain a programme that ensures our compliance with the FMA’s fair conduct principles. This page outlines the key aspects of our Fair Conduct Programme and provides more insight into Pinnacle’s approach to good conduct and customer outcomes.

The Fair Conduct Principle is the requirement to treat customers fairly.

Pinnacle Life’s Fair Conduct Programme includes the policies, processes, systems, and controls we use to ensure the fair treatment of our customers. This covers the service we provide and the products we offer.

What do we mean by Good Conduct?

At Pinnacle Life, we believe that good conduct is founded on five key pillars - Capability, Conflict, Culture, Control and Communication.

Pillar	What it means for our customers
Capability	That Pinnacle Life has the skills and resources to competently provide a suitable service or product and meet professional standards of care.
Conflict	That the interests of Pinnacle Life’s customers are of priority and are not affected by Pinnacle Life’s business interests or that of any related parties.
Culture	That Pinnacle Life acts in our customer’s interests, treats them honestly and fairly and fulfils its duties and obligations.
Control	That Pinnacle Life has checks and balances (controls) to support good conduct, and we identify and address poor conduct or customer concerns.
Communication	That Pinnacle Life listens to our customer’s needs and that our customers can easily understand our products and services.

We support the Pillars through our values (Belief, Care, Value, Ease, Challenge, and Protection), which are focused on the customer experience we aim to provide and achieving good customer outcomes.

Value	What it means for our customers
Belief	We believe in the products we sell and that they meet the needs of our customers. We have a deep passion to help our customers in the best way we can when they need it the most.
Care	We are a people-to-people business. Our staff are at the centre of our organisation, our customers at the centre of our business. The care and support of people is at the centre of our service.
Value	We keep value and affordability at the forefront of everything we do, ensuring we provide a competitive advantage and keeping costs low with a pricing structure to beat the market for best value.
Ease	Effortless, efficient and effective. We provide insurance that is accessible and easy.
Challenge	We challenge ourselves, and we challenge the status quo. We are always asking, “Is there a better way?” It means being bold, taking risks and stepping out.
Protection	We come alongside people and help them understand what needs protecting. We deliver on our promises, providing a safety net to our customers and protecting them when they need it the most.

With over 95%* of claims paid, our policies ensure we provide the financial protection our customers expect when they need it most. Pinnacles' conduct commitments are approved and endorsed by its Board of Directors.

*(as at 14th August 2024))

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Pinnacle Life’s Fair Conduct Programme

Our approach to managing conduct risk is detailed in a framework called our Fair Conduct Programme (‘FCP’).

The basis of our Fair Conduct Programme is an impact assessment which helps us identify potential sources of conduct risk. This ensures our FCP is appropriate for the size and nature of our business.

Pinnacles FCP outlines the risk management framework we applied to identify, analyse, evaluate, treat, and monitor conduct risks. It includes how our conduct risk is governed, ensuring adequate resources are available.

Several business policies and frameworks referred to in our Fair Conduct Programme all work together to meet our goal of ensuring customers are treated fairly. These include, but are not limited to;

• Conduct Policy - Outlines our approach to conduct risk, including how our values align with good conduct, sets the pillars for good conduct and establishes our conduct commitments.
• Customer Engagement Rules - These rules guide customer-facing staff on our expectations for customer interactions and experiences, including a prohibition on pressure selling.
• Vulnerable Customer Policy - This policy provides guidance for identifying vulnerable customers and includes suggested strategies for ensuring the best possible outcomes.
• Quality Assurance Framework - Establishes robust processes for reviewing customer interactions to ensure compliance with the customer engagement rules and assess interactions for good conduct and customer outcomes.
• Product Design and Management Policy - This policy considers customer needs, how those needs are met in the market and how Pinnacle Life products and their pricing can be suitable and appropriate to meet those needs. It explains the ongoing review of Pinnacle Life products and their pricing to ensure they still provide good customer outcomes and value for money.
• Distribution Channels Policy - This policy considers how our products are distributed and assesses the conduct risk associated with each distribution channel.
• Intermediary Policy - This policy sets out how we monitor the conduct and outcomes delivered by intermediaries. This includes providing appropriate training on products, our conduct expectations, and regular reviews of these parties' practices and processes.
• Conflict of Interest Policy - This policy details the fundamental obligation of staff to act in good faith in the best interests of Pinnacle Life and its customers.
• Incentives Policy - Ensures that any incentive or commission structures are aligned with regulatory requirements. Our incentives for staff are linear (i.e., they do not require any volume, value targets, or hurdles to be achieved)and require that staff pass a conduct gateway before they can receive and incentive payment. Through this structure of incentives, we mitigate risks of conflicts of interest and possible harm to customers caused by incentives.
• Compliance Assurance Programme - Our independent checks assure the Board and Senior Managers that Pinnacle Life’s processes and controls are adequate and contribute to our good conduct objectives.
• Training Policy - Ensures our staff have strong product knowledge to assist customers and that all staff know their commitments, our expectations regarding conduct risk, and our Fair Conduct Programme.
• Communications Policy - It is important that our customers understand their policy documents and any other communications from Pinnacle Life. We use Plain English to ensure our documents are clear, open, accessible, and attractive. We favour simplicity over complexity.
• Risk Management Framework - Enables the consistent, proactive and effective monitoring and management of risk throughout the organisation, in accordance with our values and strategy, and with reference to our Risk Appetite Statement. The framework provides guidance and helps to clarify expectations regarding attitude, awareness and accountabilities relating to risk management.
• Remediation Policy - Outlines how Pinnacle identifies and addresses issues that require remediation for a customer or groups of customers. This policy aims to enable early detection of issues and prioritisation of investigations, leading to quick remediation or corrective action and contributing to better customer outcomes.
• Complaints Policy - Provides a documented framework for our complaints handling process to ensure customers are treated fairly and in a timely manner throughout the complaints process and that we learn from each experience.

Complaints are an opportunity to strengthen our relationships with our customers, increase their overall satisfaction, and show that customer feedback is important. For more information on how to make a complaint, please click here.

Monitoring and Assurance of our Fair Conduct Programme

We monitor the effectiveness of our Fair Conduct Programme through an internal Conduct Committee. The Committee meets monthly and reviews various conduct metrics comprising lead and lag measures. It also reviews any complaints or dissatisfactions received and addressed during the period and the outcomes of our Quality Assurance work.

The Fair Conduct Programme's assurance is multifaceted and includes quality assurance, compliance assurance, and internal audit functions.

The outcomes of the Conduct Committee meetings and our assurance activities are reported to our Audit and Risk Committee and the Board of Directors.

Final note

Our customers' interests are our priority. Our Fair Conduct Programme aims to ensure that our customers are treated fairly. To do this, we;

• make sure our staff have the skills and resources to provide suitable products and services competently. 
• act in our customers’ interests, treating customers honestly and fairly and fulfilling our duties and obligations.
• have checks and balances (controls) in place to support good conduct, which allows us to identify and address poor conduct or customer concerns.
• Ensure that our communications with customers are clear so they can easily understand our products and services.
• provide mechanisms for customer complaints and have remediation plans in place for when things go wrong.