MAS has an effective programme of policies, processes, systems and controls in place to support fair treatment of Members. The key elements of that programme are outlined in the table below.  

If you are a Member and have a complaint about MAS or its products and services, you can access MAS’s complaints process by clicking here: Make a Complaint. 

Aspect of Fair Conduct Programme 

Summary of the key policies, processes, systems and controls MAS has in place to support fair treatment of Members 

Governance of our Fair Conduct Programme 

 
  • The MAS Fair Conduct Programme is approved by, and overseen by, the MAS Board.  
  • Various MAS governance groups support the fair treatment of Members, including the Board, Board Committees such as the Audit & Risk Committee, senior management and management governance groups through monitoring and reporting activity.  
  • MAS employs a Three Lines Model and maintains a regular cycle of internal assurance reviews across frontline processes based on risk. Those reviews are endorsed by management, the Audit & Risk Committee and the Board, who receive reporting on the reviews and actions arising out of those reviews. 

How we meet our legal obligations to Members. 

 
  • We have an in-house legal and compliance function, which is supported by external specialists where required. 
  • We administer compliance plans including obligations registers, training, and compliance assurance for various legislative regimes and licenses for MAS businesses.  
  • We conduct a regulatory scan to monitor the introduction of any new laws, regulations, and guidance from regulators.  
  • We administer an attestation process for senior managers at MAS to periodically review their key legal obligations and attest whether they comply or not. 
  • Oversight and governance of legal compliance is provided through reporting to senior management, the Board, and the Board Audit & Risk Committee.  
  • We maintain centralised registers for MAS policies and processes, and third-party contracts that MAS enters into with its partners. This supports awareness of, and compliance with, our legal obligations that arise outside of legislation and regulations. 

How we review our products, services, and distribution methods 
  • MAS products are distributed solely through MAS employees. MAS does not presently engage brokers, agents, or other intermediaries to provide advice or sell financial products to Members.  
  • MAS conducts a quality assurance programme. 
  • Product and pricing decisions are subject to a governance framework that applies to the whole product lifecycle. This supports MAS to: 
    - clearly identify its target market
    - understand Member needs (when considered as a group) when products are being designed
    - provide staff training on products 
    - consider whether reasonable value is provided to Members 
    - periodically review products to ensure they continue to meet Members’ needs.  

How we identify, monitor, and manage conduct risks 

 
  • Conduct risks are captured in MAS’s risk management processes, including in its Enterprise Risk Management Framework, and risk reports to senior management and the Board. Management provides reporting to the Board on risk appetite metrics and periodically conduct risk metrics.  
  • Frontline staff are supported in their identification, monitoring and management of conduct risks, via workshops with MAS’s Risk team and reporting. 
  • We maintain an incident management policy and process to support the identification, recording, escalation and reporting of incidents at MAS. That process is supported with the use of a centralised incident management system and support from MAS’s risk team. 

How we oversee the conduct of our employees and agents 
  • MAS hires people with relevant skills and experience for their role. Staff are supported in their roles with: 
    - relevant induction processes 
    - training 
    - supervision from their managers 
    - individualised development plans 
    - continuing professional development 
    - performance management where conduct falls short of MAS expectations. 
  • In addition, all MAS staff are expected to conduct themselves in accordance with MAS’s code of conduct. MAS also has a Whistleblower Policy and Process to support staff to call out conduct that they feel falls short of expected standards.  
  • MAS outsources certain functions in its insurance businesses. Outsourced functions are subject to contracts, and those contracts seek to control the conduct of the outsourced providers when acting as an agent for MAS. 

How we train our staff 
  • We provide specific topical and technical training to staff where that training is relevant for the competent and capable performance of their role.  
  • Training and training content is delivered both internally for some subjects, and via external training providers for others. 
  • We provide staff with training on the Fair Conduct Principle, our Fair Conduct Programme and how both apply to their roles at MAS.

How we manage sales incentives for staff who sell MAS products 
  • MAS has a Renumeration Framework, which applies across the organisation, including staff involved in distributing products to Members. The Framework is regularly reviewed to ensure staff are renumerated and incentivised in a manner that aligns with MAS’s obligations under all the financial services licences MAS holds.     

How we communicate with Members 
  • MAS communicates with Members by phone, letter, email, and in face-to-face conversations. Training and quality assurance is provided for conversations with Members.   We also use social media, our website and our Member magazine to communicate more widely.  
  • All advertising and marketing material is subject to a marketing sign-off process, which requires Legal and Compliance team input before that material is communicated to Members.  
  • Some communications with Members are also supported by standard scripting and templates.  
  • Interactions with Members are recorded in MAS systems and include call recordings for interactions with our call centre, email exchanges, and file notes from discussions between our staff and Members.  

How we conduct customer care and handle conflict with Members 
  • MAS has a Complaints Policy and a complaints process in place to support Members to make a complaint to MAS about its products and services. 
  • That process includes, if required, escalation to a senior management complaint committee, and to MAS’s independent external dispute resolution scheme, the Insurance & Financial Services Ombudsman, to resolve if necessary.  
  • Complaints provide useful feedback and insights to MAS management and are reported accordingly.  
  • MAS acknowledges that at various times certain Members may experience vulnerability and require extra care. MAS has an Extra Care Policy to have due regard to Members’ interests in these circumstances.