Fair Conduct Programme

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.