Practical steps towards compliance

Sharna Thomson, Head of Customer, UK Claims, Zurich, took delegates through the practicalities of trying to meet Consumer Duty during a presentation at ILC’s inaugural Risk and Compliance event.

Held at etc venues, Manchester, the event was themed, ‘Customers – more than just a duty’, and sponsored by Albany Group, First Central, Gallagher Bassett and Padda Consulting.

“The bar has been raised,” Sharna said. “Consumer Duty is about delivering a higher standard of care, and good outcomes are expected.”

There is much to improve on throughout the industry.

The FCA Financial Lives Survey last year found that only 41% of consumers trust financial services firms, while motor insurance complaints surged 54% between the start of 2021 and end of 2022. Meanwhile, coming out of the pandemic, research by the Call Centre Management Association revealed that the customer perception of insurance service was that it had worsened between 2022 and 2023.

“So we have to change,” Sharna said. “Having a customer-centric culture used to be a choice, a strategic decision. It’s not a choice anymore.”


However, meeting Consumer Duty standards demands a forensic attention to detail. Every product, process and communication needs to be scrutinised in order to identify the areas where improvements can be made.

Zurich is focusing on the policyholder and putting itself in their shoes.

Sharna said the objective was to ensure that making a claim and going through the claims journey was as straightforward as taking out a policy in the first place, and that it was critical the customer was well-informed of all the options available to them at every juncture.

“How you communicate with the customer is so important,” Sharna said. “They need to understand what we’re offering them and what decisions they can make. So you need to review your written correspondence and make sure it’s fit for purpose. Remembering that communication is more than written correspondence; your handlers also need to communicate in the right way over the phone too.”

And, she added, the outcomes must be the same for vulnerable customers, and insurers need to find a way to evidence it.

Supply chain

However, getting your own house in order is just the first step. Consumer Duty puts the onus on insurers to ensure that good standards and fair value is being achieved throughout the supply chain.

Sharna said, “The high bar that we are working to needs to be set and met when our customer goes into the supply chain. There could be 100 other companies dealing with our customers and I can’t put my hand on my heart and say, ‘yes, they are all giving good outcomes.’ We have review meetings and metrics, but I don’t necessarily have the level of detail I need. So we need to be sharing data. We need the supply chain to know that we’re reliant on them and that because they’re not regulated by the FCA in their own right, we are accountable for their performance.”

All this brings cost at a time of inflation and financial pressure. However, Consumer Duty is not about cheaper premiums, but offering customers the right products at the right value.

Sharna concluded, “There is still more to do. It is very much about continuous improvement so we need to keep evolving. What should happen is that complaints should decrease and consumers should start to trust us more as an industry. If it doesn’t, I’m sure the FCA will have something to say about that.”


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