Consumer Duty comes down to culture 

Achieving Consumer Duty compliance is not a once-and-done task and requires buy-in from everyone in the business. 

Speaking during a panel discussion at ILC’s inaugural Risk and Compliance event, Andrew Jobling, Supply Chain Lead, Aviva; Dan Chesney, Director, Onyx PDA; and John Fern, Chief Client Officer, Gallagher Bassett, agreed that compliance demanded a company culture of putting the customer first, and that needed commitment and focus from both the top down and the bottom up. 

Sponsored by Albany Group, ILC Insurer Partner – First Central, Gallagher Bassett and Padda Consulting, the Risk and Compliance event took place at etc.venues in Manchester and attracted 100 leaders and influencers from across the sector. 


Andrew said, “Compliance means making the customer your top priority and focusing on delivering good outcomes. That is not straightforward as each customer is different and their requirements are different. The challenge is creating a solution that is convenient and appropriate to your entire customer base, rather than developing something that works for only one type of person.” 

John agreed. He said that delivering for the customer first and foremost needs to be engrained in the business and outcomes reviewed on a regular basis to ensure standards were being met.  

Fundamental to success, he continued, was consistency. Simple principles around what fair value and good service means need to be established and employees need to be empowered to meet these principles in their daily working life. 

He said, “Our focus is on treating customers fairly. That needs to be measured and evidenced because what is important is consistency. You can celebrate individual successes, and maybe we don’t do that enough, but Consumer Duty is really about consistency throughout the business and to achieve that you need to ensure that the right processes, procedures and support are in place.” 

Easy wins 

But while this can be a daunting challenge, there are easy wins available that can move a company a long way towards compliance. 

One of these is establishing realistic expectations among customers. Processing claims is not always aligned with a world where instant gratification has become the norm, meaning customers are often left feeling disappointed. 

However, realistic expectations can be set by being proactive at the start of the journey.  

John explained, “We don’t do enough to speak to customers before events and warn them of potential problems. We need to be proactive rather than reactive. If you have to come to me first then you’re already annoyed, but if I come to you then you are likely to be more receptive.” 

Dan supported this view. He said that what constitutes good value will be different for every customer and insurers need to communicate with them clearly to understand what matters most to them, and be transparent about what they should expect during a claim. 

He said, “The product may be the same but its value will be different for everyone. So whether policyholders are satisfied or not often comes down to expectations and you can prevent 80% of complaints by explaining the process clearly – and warning them of any potential problems or delays.” 


In many cases, insurers have already responded positively to the introduction of Consumer Duty and raised their game accordingly. 

For example, Andrew explained that following the fire at Luton Airport carpark Aviva had acted quickly to set up a dedicated helpline for policyholders and implemented a range of other measures to support those affected. This positive reaction had a direct correlation with Consumer Duty.   

But while this is encouraging, there is a sense outside the industry that by improving support and service insurers are only delivering what they should already be delivering. 

Dan suggested that returning policyholders to the position they were in before a claim is not going above and beyond – “That’s why they have insurance in the first place,” he explained – and instead insurers need to look to their supply chains for improvements that the customer will notice. 

He said, “Rebuilding trust and delivering extra customer satisfaction will only come when the claims experience improves, and that will come from the supply chain, who are the face of the claim and ones providing the service and the tangible delivery of it.”  


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