We’re focused on delivering good outcomes for all our customers

As a UK based Managing General Agent, AXA Global Healthcare (UK) Limited are authorised and regulated in the UK by the Financial Conduct Authority (FCA). As you may be aware, last July, the FCA, published its policy and final guidance for the new Consumer Duty regulations coming into force on 31st July this year. These new regulations apply to all firms regulated by the FCA and apply to all activities by those firms undertaken to service and support retail customers. 

Not all of our AXA – Global Healthcare businesses are regulated by the FCA however we are choosing to adopt these principles across all our business activities because we think it is the right thing to do for all our customers. 

We welcome the new Consumer Duty and its focus on delivering good outcomes for all customers. We firmly believe that this customer-centric approach will benefit us all and, that by working together ahead of its introduction, we can help each other to be ready.  

We’ve been working hard to review our processes to ensure we continue to deliver good outcomes for all our customers and the customer experience they expect. We’re now ready to share what you can expect from us over the coming months. 

What are the Consumer Duty requirements? 

The Consumer Duty requires that businesses take action to deliver ‘good outcomes for retail customers’ throughout the customer journey by understanding their needs, financial objectives and characteristics, including any vulnerabilities. In this context “retail customers” includes those who consume our products such as members of large corporate schemes. This applies across the customer journey and specifically for the following four outcomes identified by the FCA: 

• products and services
• price and value
• consumer understanding
• customer support 

All companies regulated by the FCA must also satisfy the ‘cross-cutting rules’ which require them to act in good faith to deliver good outcomes, help customers to achieve their financial outcomes and, act to avoid ‘foreseeable harm’ to customers.  

Companies also need to show evidence that they are delivering good outcomes in these areas. You can find more information about the new Consumer Duty regulations from the FCA. 

We’re already getting ready 

As with other AXA entities, we’ve dedicated resources to ensure we’re ready for the deadline and have made great progress in the four outcomes highlighted by the FCA:  

• Products and services – regular product and service reviews will consider suitability for the needs of all customers on an ongoing basis
• Price and value – fair value assessments are made to assess whether good value is received by all customers including vulnerable customers
• Customer understanding – review of our communications and documentation through a customer lens to maximise clarity, accessibility and overall experience
• Customer support – reviewing of FAQs, website content, claims and complaints processes plus, service standards to assess appropriateness and accessibility for all customers. 

Where we identify enhancements could be made to customer experience, we’re making changes and investing in relevant training to support you and our teams. 

Frequently asked questions 

Q1. What types of changes can we expect to see post July? 

We’re already doing a lot to drive positive customer outcomes at AXA – Global Healthcare by keeping our customers central to our business. 

We’ve reviewed our existing products and services to consider how well they meet our customers’ needs. We’ve also considered whether they represent fair value for all customers, including vulnerable customers.

We’re working to meet the needs of our customers by investing in simplified, accessible, multi-channel communications, staff training and adapting processes and products based on customer insight. We’re also developing new management reporting to evidence that we are delivering good outcome for customers.   

Full details of the changes required are available in the FCA’s final published guidance. 

Q2. Can I expect my commission payments to change?  

We’ll continue to work with our intermediaries to maintain existing commission arrangements. AXA – Global healthcare do not anticipate any changes to commission levels because of the introduction of Consumer Duty. If this changes in the future, we will let you know as soon as possible. 

Q3. Do I need to do anything differently for vulnerable customers?

We’ll need your continued help to recognise vulnerable customers at point of sale and throughout their policy lifecycle. This means identifying any customised support or reasonable adjustments the customer may need. Capturing these needs as soon as you identify them is key to delivering the seamless, customer centric experience we’re aiming for. 

More information on how to to treat vulnerable customers  has been published by the FCA (Financial Conduct Authority).  

Q4. How do I support clients’ in financial difficulty?  

The Financial Conduct Authority is still consulting with the financial services industry on how to manage customers who are in financial difficulty. They published draft guidance in January on supporting customers in financial difficulty which we’re using to review our current processes. The FCA’s final guidance on supporting customers in financial difficulty is expected to be published in Q2 and introduced alongside Consumer Duty in July 2023.  

Q5. Where can I find more information?  

We’ll continue to use our existing communication channels with all our intermediary partners and where required, we may publish additional information online.  

The Financial Conduct Authority has published information on all aspects of the new Consumer Duty. The Consumer Duty final guidance was published in July 2022 and they have published other guidance on specific aspects of the Duty.

Working together 

We’re committed to working closely with our valued intermediary partners to meet the July 2023 deadline and we truly believe that by working together, we can achieve the superior customer experience and, deliver the required good outcomes for all our customers. 

If you’re also bound by the FCA’s regulations, you’ll be preparing for the new regulations too. If we do need any specific input from you, we’ll aim to contact you in due course.

If you have any queries, please do contact your AXA representative. 

The information in this article is correct at the time of publishing.

^{A new Consumer Duty Feedback to CP21/36 and final rules   
FG21/1 Guidance for firms on the fair treatment of vulnerable customers     
CP23/1: Insurance guidance for the support of customers in financial difficulty (fca.org.uk)  
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CP23/1: Insurance guidance for the support of customers in financial difficulty (fca.org.uk)}