Purpose of this Document
Fast Cover Pty Ltd ABN 98 143 196 098, AFS Licence 538708 (“Fast Cover”) specialises in travel insurance, with a consumer-centric approach involving placing consumers' interests front and centre.
Our (in this Product Design and Distribution Policy, “we”, “our” and “us” means Fast Cover Pty Ltd) policies are arranged, administered and varied in accordance with the binder issued to us by the underwriters, and are underwritten by certain underwriters at Lloyd’s.
This Policy outlines the processes and procedures that we have implemented to ensure that our travel insurance products are designed, distributed, monitored, and reviewed to be consistent with and continue to meet our customers changing needs, objectives and financial situations.
Objectives of the Policy
The objective of this Policy is to:
- Ensure that our travel insurance products are designed to meet the needs and interests of our target market;
- Implement a robust product review process to ensure that our products remain appropriate for our target market throughout their lifecycle;
- Establish appropriate distribution strategies that are consistent with our target market and that do not result in serious harm;
- Ensure that we monitor the performance of our products and address any issues or concerns in a timely and appropriate manner;
- Ensure that whilst developing these products we align our company’s strategic goals, risk management policies and operational requirements with all relevant laws including legislation, regulations and binding codes of conduct.
Design and Approval
At the product design stage, using information available to us from past or similar products, and using the experience of an external travel expert to offer an objective analysis of our products, we assess whether our product has been designed in a way that is consistent with our customer’s likely objectives, financial situation and needs and the needs of the class of consumers for whom the product is intended.
During this stage, we specify distribution conditions to ensure that our product is directed towards the intended target market and take steps to ensure that distribution is consistent with the target market's needs.
We identify the target market for the product and develop a clear understanding of those consumers' likely travel needs such as their travel destination and activities, age, financial objectives and health status.
Prior to implementation and distribution, we have robust testing procedures in place, and then analyse the expected distribution methods for the product to determine whether it is reasonable to conclude that the product will be distributed to its target market.
An essential part of this phase is the training of all Fast Cover staff members, to ensure that there is ongoing oversight of this process to staff and that staff are aware, prior to the product obtaining final approval, of the types of customers our products would be suitable for.
Product Distribution Stage
During this stage, we design our marketing strategy, with consideration of the desired target market and how we can market and advertise our product to reduce the risk that our product will not be inconsistent with the likely objectives, financial situation and needs of the consumers who acquire them. This includes monitoring our distribution channels to ensure that they have the appropriate controls to distribute the product to the correct target market.
Our marketing and advertising staff, responsible for the distribution of the product, are also involved in the design of the product, to ensure that at all product governance stages, the intended consumer in the target market is considered.
Monitoring and Review Stage
During this stage, after our financial product has been launched, we monitor and regularly review our product performance by using information readily available to us about how consumers in the target market are using our product or similar products. This is achieved through analysing customer claims, reviews and complaints, as well as other events and/or circumstances which reasonably suggest that our product continues to be consistent with the likely objectives, financial situation and needs of consumers of the intended target market, and the distribution strategy remains consistent with the target market determination. Or, the information may suggest that the product needs to change.
Depending on the results of the review, our team will either:
- Continue with no change;
- Change the design of the product;
- Change the target market;
- Change the distribution of the product; or
- Cease offering the product.