VULNERABLE CUSTOMER POLICY

This Family Violence, Supporting Vulnerable Clients and Financial Hardship Policy (Policy) has been developed to comply with National Insurance Brokers Association (NIBA) Insurance Brokers Code of Practice (the Code) and sets out how BCS Broking Pty Ltd identifies and supports vulnerable Clients, including those affected by Financial Hardship and Family Violence.

For the purposes of this Policy, any reference to “Clients” includes clients of BCS Broking Pty Ltd as well as any other individual entitled to Financial Hardship support under the Code. This could include individuals who we are seeking to recover money from as we believe they have caused damage to an insured Client.

BCS Broking Pty Ltd is committed to exercising greater care when dealing with vulnerable Clients. A person may be vulnerable due to a range of factors, including:
1. Age;
2. Disability;
3. Mental health conditions;
4. Physical health conditions;
5. Family violence;
6. Language barriers;
7. Cultural background;
8. Aboriginal or Torres Strait Islander status;
9. Remote location; or
10. Financial distress.
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1 POLICY STATEMENT

BCS Broking Pty Ltd has a long-standing commitment to conducting its business with honesty and integrity and remains committed to full compliance with the Code and informing Clients and employees about information and assistance available to vulnerable people, including those experiencing Financial Hardship and Family Violence.

This policy and the BCS Broking Pty Ltd internal policy and training programs assist employees to:

1. Identify and understand if a Client may be vulnerable;
2. Determine how best, and to what extent, they can support a vulnerable Client;
3. Take account of a Client’s particular needs or vulnerability; and
4. Engage with a vulnerable Client with sensitivity, dignity, respect and compassion. This may include arranging additional support and referring the Client to specialised people or services.

BCS Broking Pty Ltd may need to be flexible and vary the approach based on individual circumstances, including providing more personalised support to help navigate our processes.

2 FAMILY VIOLENCE
In Australian law, ‘Family Violence’ is defined as:

“violent, threatening or other behaviour by a person that coerces or controls a member of the person’s family or causes the family member to be fearful.”

‍Family Law Act 1975 (Cth), section 4AB.

‍Family Violence means much more than physical violence. It includes:

• Emotional abuse, psychological abuse, sexual abuse, financial or economic abuse; and
• Damage to property.
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The way employees deal with Clients who may be affected by Family Violence should facilitate, rather than act as a barrier to identifying Family Violence and improve the experience of those affected by Family Violence.

The aim of the Policy is to ensure that whenever Family Violence is identified or suspected, the safety of the Client affected by Family Violence and their family is protected.

BCS Broking Pty Ltd recognises that Family Violence is unacceptable in any relationship and Clients experiencing Family Violence will be treated with dignity and respect.

The support of Clients experiencing Family Violence and their family is the highest priority. Clients who indicate or disclose Family Violence are able to access support from BCS Broking Pty Ltd that is appropriate to their circumstances.

3 ASSISTING CLIENTS

BCS Broking Pty Ltd can assist vulnerable Clients, including those experiencing Financial Hardship or Family Violence by:

• Ensuring safe and confidential communication in light of individual circumstances;
• Helping to set up new insurance policies;
• Helping to arrange access to financial hardship support; and
• Referral to specialist support services.
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In circumstances where the issue is complex or unable to be dealt with by the primary person who took the call, it is to be immediately referred to the General Manager for consideration.

The Client must be informed of this action.

4 THIRD PARTIES

If BCS Broking Pty Ltd are advised, or we identify, that a client or potential client requires support from a third party (eg: lawyer, interpreter, or friend) we will make reasonable accommodations to allow for this.

5 FINANCIAL HARDSHIP

Financial Hardship occurs when Clients experience difficulty in meeting their financial obligations to BCS Broking Pty Ltd.

The support BCS Broking Pty Ltd can offer does not include support with paying the premiums under an insurance policy we have issued.

If a Client informs BCS Broking Pty Ltd, or we identify, that they are experiencing Financial Hardship, we will provide them with:

• Assistance in seeking alternative payment options such as:
Extensions for payment; or
Premium funding.
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• If appropriate, contact details for the National Debt Helpline – 1800 007 007.
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6 TRAINING

Training is tailored to all employee roles within the business and the degree of contact they have with Clients.

BCS Broking Pty Ltd will aim to ensure that all employees and have been trained and receive ongoing training so that they: • Are aware of BCS Broking Pty Ltd policies and procedures when they are engaging with vulnerable Clients;
• Identify vulnerable Clients, including those affected by Family Violence;
• Deal appropriately and sensitively with vulnerable Clients; and
• Apply the Family Violence & Supporting Vulnerable Clients policy and related policies and procedures relevant to their role in dealing with Clients.
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Training is aimed at assisting employees to reduce the impact of vulnerability and Family Violence on Clients.
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7 REPORTING

Any notification of Vulnerability or Financial Hardship received by a member of staff must be reported to the General Manager and recorded in the BCS Broking Pty Ltd CRM system.

The General Manager will then conduct periodic (no less than 6-monthly) reviews of those client/claim files to ensure that we are providing support to those suffering Vulnerability or Financial Hardship.

8 SUPPORT SERVICES AND RESOURCES