Responsible sales

The PZU Group has adopted and applies top standards of communication with its stakeholders. This approach is tremendously important when dealing with intangible products such as financial services.

Open communication and contact with the media - “We provide precise and needed information to all the parties with whom we cooperate. We make every effort to ensure that reports and documents published or transferred to inspection or regulatory authorities are complete and comprehensible.

We comply with information policy standards applicable to public companies. We provide information about our business, products and intentions in a reliable and efficient manner to all market players who thus may receive comprehensive information about the PZU Group’s companies.

We publish detailed financial reports on a regular basis. We provide the media with information regarding our current matters in a professional and responsible fashion. At the same time, we pay special attention to the protection of our company’s image. Only the company’s authorized representatives may make statements in the media, and they are required to maintain the confidentiality of information regarding our operations.”

PZU’s Best Practices define what specific activities are in compliance with the Company’s key value of “We play fair”. They require that information about the offering must be conveyed in a reliable and comprehensible manner with special attention paid to removing any potentially misleading understatements or omissions. Such information must also present the actual benefits but also reliably describe any existing risks that accompany the offering.

Responsibility is the key - “We honestly inform our clients about PZU’s offers. We diligently describe the benefits, we honestly detail the risks associated with the offer, we take full responsibility for it and we deliver on our promises. We do our best to ensure that any problems our clients may have are addressed by PZU in a reasonable and diligent manner and any complaints are handled without undue delay. Should any disputes emerge, we employ mediation and make every effort to resolve them amicably.” 

In order to ensure the provision of a reliable and ethical message, the Group’s communication is based on the following:

• Best Insurance Practices,
• Code of Ethics in Advertising,
• Rules for Advertising Insurance Services (KNF).

All the above actions are intended to reduce the risk of selling the client a product that he or she does need or understand, including the risk of misleading the client intentionally or unintentionally. Counteracting the practice of unethical sales is a matter of importance from the perspective of the PZU Group’s development. If incidents occur, they may contribute to a long-term erosion of confidence in the services offered by the Group. They might also expose the companies involved to regulatory procedures and the imposition of sanctions by administrative authorities.

Professionalism all along the way - “Our success and strong brand have been achieved thanks to the knowledge and experience of each one of us. Our continuous strive for perfection allows us not only to keep up with the world’s development but also look into the future. Therefore, we gladly welcome any novel ideas.

The solutions that have already been verified can be used many times over and serve as a basis for the development of new products. We employ our knowledge and creativity to earn profits and accumulate savings. This has a positive impact on the image of our company which is always at the center of it all.”

In order to find out which products are best matched to a particular client, the sales process is supported by the Client Needs Assessment Questionnaire (“ADPK”) (mandatory for all insurers in Poland). The purpose of the questionnaire is to determine the client’s needs in the context of his or her intention to enter into an individual life insurance agreement or enroll in a group life insurance agreement if the agreement in question is for a unit-linked or structured product. The assessment is intended to scrutinize the client’s knowledge, needs and experience in the domain of life insurance as well as his or her financial situation. Based on the results of such analysis, products are proposed to clients that are most suitable for them. The purpose of this exercise is to protect clients against entering into long-term agreements that would provide products inconsistent with their needs and entail the acceptance of a long-term commitment. Moreover, while completing the ADPK form, the client is each time required to provide answers to the questions contained in the Anti-Money Laundering and Terrorism Financing (AML) Questionnaire.

Compliance with laws and regulations - “PZU makes every effort to ensure that applicable laws and standards are complied with in all areas of its business.

In its dealings with the regulatory authority, the Polish Ombudsman for the Insured and other external institutions, PZU respects and recognizes all statutorily defined duties of such entities. PZU also provides them with assistance in the pursuit of their main task, i.e. protection of the insureds’ interests.

The basic rights and duties of every employee should be precisely defined. However, should doubts emerge as to whether a decision is reasonable or when a situation seems questionable or there is a suspicion that the law or any of the adopted principles or standards may have been breached, the company’s relevant units must be informed about it.”

The systemic approach to sales management is also applied to PZU’s own branches. The implemented Client Service Standards systematize the day-to-day work in the branches and explain how to serve clients and conduct the sales process professionally while building trust and a long-term relationship with the client. Special emphasis is put on recognizing the client’s actual needs, which the client may sometimes have problems articulating properly. Consequently, it becomes possible to suggest the best solutions and eliminate the risk that the client might purchase a product that he or she does not really need. The document also contains various other guidelines, including those concerning identity verification and the updating of personal data with a view to preventing actual abuses. 

When underwriting risks for hospitals and clinics, TUW PZUW conducts engineering and medical audits the deliverables of which are recommendations issued for the company’s clients. Audits of medical centers often result in issuing recommendations regarding safety, hospital infections and patient rights. The implementation of post-audit solutions suggested by TUW PZUW is beneficial to patients of the audited entities. Furthermore, in specific cases, medical centers may apply for cofunding of necessary capital expenditures from PZU’s prevention fund.

For a number of years, the Pekao Group has been guided by the principle of caring for its clients’ interests. The staff are under the obligation to ensure that each client, when purchasing a product or service, is aware of both the benefits and risks associated with it. The duty to protect clients against the taking of excessive risk in investment decisions results from the bank’s complete implementation of the Markets in Financial Instruments Directive (MiFID). Once completed by the client, the questionnaire serves the purpose of evaluating the adequacy of the service involving the acceptance and forwarding of the client’s instructions on participation units in mutual funds or other investment products. The adequacy questionnaire contains a list of questions concerning the client’s knowledge and experience in the area of investing in financial instruments or other investment products. On the basis of the outcome of such evaluation, the client obtains feedback as to the adequacy of the proposed service in his or her situation. This helps the client make a conscious investment decision.

At the same time, with a view to conducting responsible sales, a host of internal regulations have been introduced, including a policy for managing conflicts of interest, a policy for classifying and reclassifying clients and a policy for selling investment products.

The Alior Bank Group makes efforts to ensure that its clients’ decisions are responsible and always based on their full understanding of the products and technological solutions offered by the group’s member companies. These companies have in place the rules for using a simple and comprehensible language enabling people who are not finance specialists to understand the information conveyed to them.

The policy of preventing dishonest sales is intended to counteract the practice of misselling. The document lays down the rules that must be applied in the process of designing and distributing products. The Alior Bank Group’s competent units continuously monitor its sales processes looking for any misselling threats. Rules are also in place for dealing with any identified cases of misselling. All employees have also been trained in the principles of transparent sales, and their sales bonuses depend on the quality of the sales process, which is subject to regular inspections. The fundamental mechanism in this area takes the form of post-sale calls applied to those clients and products that are under the highest risk of misselling. This mechanism is supplemented by evaluating the quality of documentation, complaints and early lapses. 

In case of PZU Zdrowie, which is responsible for management of medical services, including the medical center chain, the specificity of the operations determines a slightly different management approach to social issues. Its key aspects include primarily: ensuring the protection character of the health products, patient service quality standards, ensuring clinical safety, protection of personal data, in particular sensitive medical information, and conducting educational and prophylactic health-related activities.

The following should be considered of key importance:

• Organizational bylaws of the healthcare entity,
• Patient handling standards book,
• Customer flow management procedure,
• Principles of handling patients’ and clients’ opinions (complaints),
• Clinical incident handling instruction,
• Rules of proceeding with sensitive results,
• Personal data processing security policy,
• Procedure for selection of suppliers of goods and providers of services.

In the main stream, health products are distributed through PZU’s sales and service network and are subject to the rules prevailing in that network.

The distribution through PZU’s network of the investment products based on investments in participation units of mutual funds is regulated primarily by the Regulation of the Minister of Development and Finance of 23 March 2017 in the matter of proceeding of the entities conducting the activities related to intermediation in sale and redemption of participation units and participation titles, and the investment consultancy related to such instruments. The internal requirements related to designing products are the same (CHAPTER 2.1 RESPONSIBLE PRODUCTS).

TFI PZU as well as Pekao TFI belong to the Chamber of Fund and Asset Management “IZFA”. As part of their participation, they actively take part in, among others:

• representing the environment of mutual fund companies,
• supporting the development of mutual fund companies in Poland,
• disseminating knowledge of mutual funds,
• development and improvement of professional ethics rules for the mutual funds management specialists.

PTE PZU actively participates in shaping the social awareness in the pension system area. It promotes the solutions aiming at increasing that system’s effectiveness and protecting the insureds’ interests through participating in the Pension Fund Companies Economic Chamber (industry self-government). In addition, it takes part in campaigns promoting the pension and educational products, and it emphasizes the significance and role of voluntary insurance that increases the future pension benefits.