Fair Conduct Programme.

At Momentum Life, we’re committed
to fair conduct, putting, you — our
customers — at the centre of
everything we do.

Understanding our Fair Conduct Programme.

This Fair Conduct Programme (FCP) summary is intended to assist you:

To be reasonably aware of how we will comply with the fair conduct principle.

To make informed decisions about your dealings and interactions with us in relation to the services and products that we provide.

To understand how to make a complaint about those services and products we provide.

What is the Fair Conduct Principle?

The fair conduct principle ensures that we treat you fairly at every touch point in your customer journey. This means you can expect Momentum Life to:

Pay due regard to your interests.
Act ethically, transparently and in good faith.

Assist you to make informed decisions.
Ensure that our services and products are likely to meet the requirements and objectives of consumers.
Not subject you to unfair pressure or tactics, or undue influence.

Learn more about the Fair Conduct Principle from the Financial Markets Authority here.

Our Commitment to Fair Conduct.

At Momentum Life, our Fair Conduct Programme is central to how we operate, ensuring fairness, integrity, and transparency in everything we do.

This programme includes policies, processes, systems, and controls that help us uphold the fair conduct principle in everything we do. These elements work together to promote good conduct across all aspects of our operations by:

  • Clearly defining roles and responsibilities to monitor and mitigate risks associated with poor conduct.

  • Providing an environment where our staff feel confident speaking up and reporting any unlawful or unethical behaviours and feel supported throughout the process, with clear and transparent protection for any disclosers.

  • Regularly reviewing our policies and procedures, and business operations, to promote good conduct and compliance with the relevant legal obligations and the fair conduct principle.

  • Ensuring our products and distribution are regularly reviewed, remain fit for purpose, and are likely to meet the requirements and objectives of our consumers.

  • Upholding our commitment to providing the highest standards of customer service, with policy administration and claims handling procedures formally documented and reviewed on a regular basis.

  • Providing employee induction and on-going training programmes for all our staff to ensure each employee has the necessary understanding and competency to carry out their respective tasks.
  • Implementing a formal ‘Quality Incentive Programme’ (‘QIP’) designed to support quality customer conversations and compliance outcomes, with no reference to any target or threshold related to the volume or value of our services or products purchased by our customers.

  • Establishing ‘Duty of Care’ processes and guidelines that are regularly reviewed and recognise our duty to provide additional support and care to customers in potentially vulnerable situations so that they are not disadvantaged in any way when interacting with us.

  • Maintaining a consistent, fair, timely and transparent approach to identifying, managing and resolving customer complaints and disputes.

  • Conducting regular reporting on matters relating to the FCP, to ensure our management team and the Board exercise their oversight responsibilities appropriately and effectively. This includes the reporting of any risks associated with conduct and any failures comply with the “fair conduct principle”.

  • Carrying out regular FCP assurance monitoring and testing by an independent Risk and Compliance team, including the monitoring of customer interactions, and testing of policies, processes, systems and controls.