USLI - CANADA

Fair Treatment of Consumers Principles and Policy

Last modified: December, 2022

1. DEFINITIONS

Intermediary: Intermediary is given broad meaning, and will differ based on the applicable definitions within different jurisdictions across Canada. It encompasses adjusters, individual agents, brokers and representatives as well as business entities that distribute insurance products and services, including managing general agencies and third party administrators. It also applies to all distribution methods, including the internet.

Customer: Customer refers to policyholder (which itself, as the case may be, includes a certificate holder) or prospective policyholder with whom an insurer or intermediary interacts, and includes, where relevant, other beneficiaries and claimants with a legitimate interest in the policy.

2. GOVERNANCE AND BUSINESS CULTURE

All Branch employees, as well as Head Office employees, are subject to Berkshire Hathaway's - Code of Business Conduct and Ethics. The Code is distributed annually and all employees are required to review and acknowledge through ADP which is monitored by the Head Office Benefits team. Specifically, Section B addresses the Purpose of the Code, Section C - Ethical Standards, Section E - Violations of Ethical Standards including Reporting and Accountability, and Section F - Compliance Procedures.

All employees are required to participate in annual courses related to the following areas:

Service & Quality training related to general and community wide service standards, fundamentals and promises
Training related to the fundamentals of a shared value system with the Company known as the CARE2 values of Caring, Attitude, Respect, Energy and Empathy

3. CONFLICTS OF INTEREST

All Branch employees, as well as Head Office employees, are subject to Berkshire Hathaway’s – Code of Business Conduct and Ethics. The Code is distributed annually and all employees are required to review and acknowledge through ADP which is monitored by the Head Office Benefits team. Specifically, Conflicts of Interest are addressed under Section C – Ethical Standards.

4. OUTSOURCING

The Company publishes on its intranet site the Prohibited Business Practices Policy for Berkshire Hathaway subsidiaries. The Policy applies to all officers, directors and employees of Berkshire and each of its subsidiaries and is applicable to all intermediaries.
Additionally, the Company requires that the firms to which it outsources functions contractually affirm that they have adequate policies and procedures in place to ensure compliance with legislation relating to privacy protection; that they will adhere to high ethical and professional standards; and/or that their policies, procedures and processes are expected to result in fair treatment of Customer outcomes.

5. DESIGN OF INSURANCE PRODUCT

We are a product driven organization focused on underwriting competencies, a well-defined range of products and a clear definition/vision of what we know how to underwrite. Product teams are responsible for new product development and management of existing products. The Product Development team reviews and approves all new product proposals.

Individual products are overseen by Product Leaders. Product leaders are the company expert for their assigned product. Each product leader must provide leadership for their product through a business plan with defined action items with the expectation that they will monitor and adjust their plan throughout the year. They must exhibit technical knowledge, are responsible for driving coverage and pricing changes to keep the product competitive in the marketplace, and teach/educate other underwriters on underwriting the product correctly. Product leaders develop and maintain an in-depth knowledge of the industry with which the assigned product serves by joining appropriate association(s) and attending trade shows/conventions. They are expected to constantly monitor issues and emerging product exposures which aids in maintaining product relevancy for targeted consumer groups.

Additional product oversight:

Coverage forms and endorsements are reviewed by the Legal and Compliance team to ensure adherence to regulatory standards, laws and statutes along with ensuring clarity of meaning and underwriting intent.
Product leaders work with the Actuarial team to evaluate adequacy of current rates and adjust rates to maintain profitability while also adhering to Actuarial Standards of Practice.
Work closely with the Claims team to review and learn from individual claims situations.
The Underwriting and Claims Audit team is responsible for proactively auditing the company’s products and claims handling to improve overall performance and adherence to internal underwriting guidelines. They also evaluate how we do business on the web. Furthermore, they focus audit efforts on key issues to protect profitability, enhance product growth and improvement, and ensure appropriate endorsement usage.

6. DISTRIBUTION STRATEGIES

The USLI Experience was developed to build long-lasting business relationships with our agents. Focus is placed on what we consider the most important qualities of a sound business relationship: Service, Commitment to Growth, Efficiency/Quality, Expertise/Competency, Stability and Community. These six pillars are the foundation of each interaction that agents have with any of our USLI team members. Agents have three methods for obtaining quotes – email, online or over the phone. The Customer Distribution team is responsible for educating our agents about USLI through principal, regional and producer conferences along with sales training for producers.

Products tailored for specific niches such as individual professionals, small home based businesses and a wide variety of special events are offered through the CoverSmart Platform. The platform is designed for self-service via a web quote, bind and issue system. USLI may follow up with potential policyholders to help win the business. [Note: CoverSmart Platform is not yet available in Canada. This information is provided in case the platform becomes available in future.]

Additional product oversight:

The Administration team is responsible for binder processing and servicing, quality review and delivery for policy issuance, endorsement quote and processing, and legal notice processing and review of applicable regulations with regard to cancellation and reinstatement, nonrenewal and conditional renewal, and renewal premium. The team’s goal is to provide consistent and professional customer service. Within the team, the Instant Access Service Center has responsibility for direct bill servicing where trained service representatives work with policyholders on billing questions.

7. DISCLOSURE TO CUSTOMER

All Branch employees, as well as Head Office employees, are subject to Berkshire Hathaway’s – Code of Business Conduct and Ethics. The Code is distributed annually and all employees are required to review and acknowledge through ADP which is monitored by the Head Office Benefits team. Specifically, Fair Dealing is addressed under Section C – Ethical Standards.

8. PRODUCT PROMOTION

The Head Office Design team’s mission is to collaborate as a team to deliver accurate and consistent materials for all internal and external communications. The approval process for promotional material before publication includes the following steps:

Written content review by Corporate Communications
Editorial review of the draft by Corporate Communications
Editorial review and approval by the requestor in Underwriting

9. ADVICE

All Branch employees, as well as Head Office employees, are subject to Berkshire Hathaway’s – Code of Business Conduct and Ethics. The Code is distributed annually and all employees are required to review and acknowledge through ADP which is monitored by the Head Office Benefits team. Specifically, Fair Dealing is addressed under Section C – Ethical Standards.

10. DISCLOSURE TO POLICYHOLDER

All Branch employees, as well as Head Office employees, are subject to Berkshire Hathaway’s – Code of Business Conduct and Ethics. The Code is distributed annually and all employees are required to review and acknowledge through ADP which is monitored by the Head Office Benefits team. Specifically, Fair Dealing is addressed under Section C – Ethical Standards.

The Business Resource Center website maintained by the Company, www.bizresourcecenter.com, is available to all policyholders of the Company and provides services, tools and industry information to aid policyholders to reduce the likelihood of a claim, grow their organization and save money in the long run.

11. CLAIMS HANDLING AND SETTLEMENT

The Head Office Claims team maintains their own internal resource site which includes guidance on fair claims practices. All new hires are trained on the topic of Fair Claim best practices. The Underwriting and Claims Audit team conducts mini and full audits annually in addition to verification of compliance with service promises and internal guidelines. Any issues that arise that warrant coaching or a reminder are completed.

12. COMPLAINTS HANDLING AND DISPUTE RESOLUTION

The Branch has established procedures to ensure that complaints from its Canadian policyholders are handled in a timely and efficient manner. The procedures are posted on USLI’s (Canada) website at www.usli.ca/consumer-complaints.html. In addition, the procedures will be made available in writing to any person who requests them. Company oversight is the responsibility of the Chief Compliance Officer. Furthermore, if a customer is not satisfied with the Company’s response, the Company contracts with the General Insurance OmbudService (“GIO”) to provide independent review and assistance in resolving such complaints.

13. PROTECTION OF PERSONAL INFORMATION

All Branch employees, as well as Head Office employees, are subject to the Company’s Electronic Information Technology Policy. The Policy is distributed annually and all employees are required to review and acknowledge the Statement of Disclosure through ADP which is monitored by the Head Office Benefits team.

All Branch employees, as well as Head Office employees, are subject to Berkshire Hathaway’s – Code of Business Conduct and Ethics. The Code is distributed annually and all employees are required to review and acknowledge through ADP which is monitored by the Head Office Benefits team. Specifically, Confidentiality and Compliance with Laws, Rules and Regulations are addressed under Section C – Ethical Standards.

All brokerage and agency intermediaries doing business with the Company are contractually required to adhere to applicable legislation relating to privacy protection.

14. OVERSIGHT

The Fair Treatment of Consumers policies with respect to the Canadian Branch operations will be overseen and closely monitored by the Chief Agent and the Branch Management Team.

APPENDIX A

Related Guidance, Regulations and Acts:

Canadian Council of Insurance Regulators (CCIR)/Canadian Insurance Services Regulatory Organizations – Conduct of Insurance Business and Fair Treatment to Customers (September 2018)
Canadian Insurance Services Regulatory Organizations (CISRO) – Principles of Conduct for Intermediaries
Ontario Unfair or Deceptive Acts or Practices (effective April 1, 2022) – Unfair Discrimination and Unfair Claims Practices are prohibited under the Act