Family and Domestic Violence Support Policy

Policy last updated 14th March 2025

Policy and Purpose

Assetinsure is committed to providing a supportive, safe and confidential environment for people experiencing Family and Domestic Violence (FDV). This policy establishes a comprehensive framework for identifying, responding to and supporting people impacted by FDV, while meeting our obligations under the General Insurance Code of Practice 2020. This policy is applicable to all internal staff and external agencies and representatives, including service providers.

This policy, and the benefits outlined, are available to any current or potential Assetinsure policyholder, whether they deal directly with Assetinsure or deal with one of our distribution partners or service suppliers, and any individual we are seeking to recover money from.

There is no requirement for evidence of FDV to be provided to us to trigger the application of this policy. A customer shall be treated under this policy if:
a) the customer self-identifies to our people as being affected by FDV; or
b) it is identified through observations of the indicators within this policy that the customer may be affected by FDV.

The purpose of this policy is to minimise the risk of harm in our interactions with people experiencing FDV by:

• Enabling Assetinsure employees and representatives to identify people experiencing FDV
• Providing a clear and sensitive approach for responding to and supporting customers experiencing FDV
• Protecting the safety and confidentiality of people experiencing FDV
• Enabling flexible service delivery and processes that prioritise customer wellbeing
• Meeting legal and ethical obligations with dignity and respect
• Defining clear responsibilities for Assetinsure and our Representatives
• Defining the requirements to implement, monitor and oversee this policy.

This policy applies mandatorily only to retail insurance customers. However, the Group will endeavour to assist with any requests for assistance in responding to FDV.

This policy operates in conjunction with our Customers Experiencing Vulnerability Policy, recognising that FDV may coincide with other vulnerabilities requiring comprehensive support approaches

Definition and Approach

Definition

FDV is a pattern of behaviour characterised by using violence, abuse, or coercion to control threaten or intimidate a member of the person’s family. It is often the case that the abuser is an intimate family member or current or former partner. This includes, but is not limited to:

• Physical violence, including damage to property
• Emotional and psychological abuse
• Financial and economic control and abuse
• Sexual violence
• Reproductive coercion
• Stalking and harassment
• Threats and intimidation.

We understand that FDV can occur across all demographic groups and impact people regardless of age, gender, cultural background or socioeconomic status.

Approach

Applying the Assetinsure framework for supporting customers experiencing vulnerability is underpinned by the following fundamental principles:

Identifying Family and Domestic Violence Indicators

Our people can play a role in identifying when a customer is experiencing FDV. Early recognition and support can help reduce the impact of the violence. Sometimes we may identify the person experiencing the violence and sometimes we may identify the perpetrator, either of whom may be a customer or an employee.

It is possible that our people could be involved in circumstances when indicators of FDV may be more likely to become apparent. For example, at claim time and particularly after a major disaster. As a result, training in identifying FDV and how to respond accordingly is important. In the event of a catastrophe, we will consider any additional support that could be provided to help.

People affected by FDV may be reluctant, or unable, to disclose their circumstances. Our people should be trained to enable them to be aware of the signs that may indicate a customer is affected by FDV.

The indicators captured below are cues, or signals, that mean you might need a moment to check in with the customers to understand how they are feeling and what support they may need. Remember that identification does not require proof or validation of the customer’s experience.

Supporting family violence

Our goal is to always engage with customers experiencing FDV with sensitivity, dignity, respect and compassion to facilitate the identification of FDV and improve the experience when dealing with us. We recognise that FDV is a complex and deeply personal experience that requires exceptional care, sensitivity and support.
Our people are not, and cannot be expected to be, social workers or experts in FDV. This section of the policy provides guidance on supporting customers which ensures we are prioritising customer safety, autonomy and wellbeing

Support Foundations

Supporting customers experiencing FDV requires a consistent, trauma-informed approach that prioritises safety, dignity, and respect. These principles form the foundation of all our interactions and support strategies..

General support strategies

• Believe the customer’s disclosure and take it seriously
• Create a safe and private environment for discussions
• Allow the customer to lead the conversation
• Recognise that each situation is unique
• Document interactions appropriately and confidentially
• Take a trauma-informed approach to all interactions
• Maintain professional boundaries while showing empathy
• Avoid making assumptions or judgments
• Consider intersecting vulnerabilities
• Focus on immediate safety needs first
• Offer and enable the need for additional support from someone else such as a lawyer, consumer representative, interpreter or friend
• Keep in mind a female impacted by FDV may prefer to speak with another female
• Consider that the request for proof of loss documents could create an unsafe process, or not be possible for people going through FDV.

General Communication Approaches:

• Use active listening techniques
• Demonstrate empathy through verbal and non-verbal cues
• Speak clearly and calmly
• Ask open-ended questions when appropriate
• Allow silences in the conversation
• Avoid language that could be perceived as victim-blaming
• Check understanding regularly
• Validate the customer’s experiences
• Use phrases that empower rather than direct
• Maintain a supportive, non-judgmental tone.

Prioritise safety

It is of paramount importance that whenever FDV is identified or suspected, the safety of the customer affected by FDV and their family is protected.

everal of the activities outlined in this policy contribute to this goal, including the early recognition of FDV and the protection of personal information.

If a customer is in an emergency, or not feeling safe, they should call emergency services on 000. Our public FDV policy will advise customers of this.

If there is something reasonably within our power to do that will maintain or increase the safety of a policyholder, then we must undertake that action on a best endeavours basis.

Support strategies:

• Implement strict confidentiality measures, including not providing contact information to a customer for joint policy holders
• Offer secure, private communication channels
• Avoid contact methods that could compromise customer safety
• Provide flexible options for processes to be completed
• In cases where a motor claim involves damage that compromises the customer’s safety, such as tampered locks, broken windows, or a vehicle being inoperable:
  • Facilitate access to temporary transportation options, such as a hire car or ride-sharing vouchers, to ensure the customer has mobility and can access safe locations.
  • Prioritise expedited repairs or towing services to secure the vehicle and restore its usability.
  • Where the damage may be linked to family violence, ensure sensitive handling of the claim, avoid sharing information that could compromise safety, and refer the customer to specialist support services if appropriate.
• In cases where a home claim involves damaged doors or compromised entry/exit points, prioritise the customer’s safety by:
  • Assess whether the lack of secure entry/exit points poses a safety risk, and, if so, escalating the matter for urgent resolution.
  • Offering immediate assistance to facilitate temporary repairs or securing the property, such as emergency locksmith services or temporary barriers.
  • Ensuring clear communication with the customer about the steps being taken to restore safety and providing regular updates on progress.

Communication Approaches:

• Ask the customer their preferred communication methods allowing them to control the situation asking questions such as:
  • When is a good time to talk?
  • Is it safe to send messages or leave voicemails?
  • Are there contact details or methods we should avoid? (mail or landline details that may be on file)
• Avoid voicemails or mail to shared postal addresses without explicit consent
• Demonstrate understanding without pressure
• Respect the customer’s choices and autonomy
• Consider ASIC Legislation Instrument 2022/809 which provides an exemption for insurers from certain obligations that carry the risk of family violence, including the exemption to send Cash Settlement Fact Sheet and transaction evidence, to joint policy holders in the instance.

Protecting information

While the proper handling of private information is always important, it is recognised that there are situations, such as where FDV is involved, where information must be handled with heightened sensitivity. Customers need to have confidence that we will protect critical information, particularly a physical address, and there is no risk of deliberate or accidental disclosure.

We are committed to maintaining the highest standards of privacy and confidentiality for customers experiencing FDV, recognising the potential risks associated with information disclosure, especially when there is a joint policy holder.

Support strategies:

• Be aware that an abuser can often pass a privacy, or three-point ID check, to get updated addresses or contact information
• Implement robust information protection protocols
• Implement strict confidentiality measures, including not providing contact information to a customer for joint policy holders
• Flag policies and claims for sensitive cases
• Obtain consent for any information exchange
• Provide options for communication preferences
• Treat all information about the customer as sensitive information
• Proactively search for other policies or claims that may need to be flagged, noted or updated
• Provide access to personal information held about them within a timely manner.

Communication approaches:

• Ask the customer if they have multiple policies or claims to update
• Discuss confidentiality measures up front and check with the customer for their comfort and approval for contact methods and details
• Clearly explain how information will be used, protected and in cases of joint policy holders what may be shared
• Ask the customer what information they are comfortable with us sharing with third parties, especially service providers etc.
• Offer anonymity where possible.

Tell us once

We aim to reduce the emotional burden on customer’s by minimising the number of times they need to disclose the details of traumatic experiences as it can make them relive the experience, and they may not be in a safe space to talk about it.

Support strategies:

• Consider how to adapt processes to require minimal detailed disclosure when possible
• Offer alternative verification methods
• Respect customer’s comfort levels
• Where possible ensure the customer only deals with one person to avoid repetitive questions
• Provide copies of documents without charge as needed
• Training staff in trauma informed approaches.

Communication approaches:

• Use gentle, non-invasive questions allowing the customer to share only what they feel comfortable with
• Provide clear information about support options in the process
• Reassure customers their circumstances will be handled discreetly.

Sensitive claims handling

We are committed to handling claims with sensitivity, understanding the potential complexity and emotional challenges customers may face during the claims process. It is especially important to be aware when there are joint policy holders, or the perpetrator has caused the claim. Be aware that the claims process itself may trigger violence for a customer.

Support strategies:

• Provide dedicated support for sensitive claims with adequate authority to make decisions
• Offer flexible claims submission methods and documentation requirements
• Expedite claims related to FDV, where appropriate and possible
• Look to reduce the administrative burden where possible
• Allow extended timeframes for claims processing
• Avoid requiring the customer to contact the perpetrator or lodge a police report about them
• Ensure the correct person is being paid, which can be complex in cases of FDV and family law disputes
• Consider if sending a Cash Settlement Fact Sheet, or transaction confirmations, to a joint policy holder would carry a risk. Remember that the ASIC Legislation Instrument 2022/809 does provide an exemption for insurers from certain obligations that carry the risk of family violence.

Communication approaches:

• Remember a survivor of violence may appear incoherent or scattered in their communication – be patient and allow extra time
• Use compassionate and supportive language
• Check in on the customer’s emotional wellbeing, offer support services if needed
• Provide clear, step-by-step guidance on processes and what is expected of them
• Follow up conversations via email if the customer authorises the use of email
• Allow time for replies to emails or requests to be completed, a customer may not have access to phone or email all the time.

Collection arrangements

We recognise that customers experiencing FDV may face unique challenges regarding premium payments and collections. Our approach prioritises flexibility and understanding while maintaining customer dignity.

Assetinsure must consider the risks in attempting to recover debts in situations involving FDV, whether it be from the customer experiencing FDV or from the perpetrator.

We, as well as any collection agent or solicitor collecting money for us, are required to comply with the Debt collection guidelines: for collectors and creditors, published by the Australian Competition and Consumer Commission and the Australian Securities and Investments Commission.

Support strategies:

• Do not refer or sell debt to a third-party collection agency
• If debt has been sold to a third-party collection agency, we will work with the collection agency to provide the best outcome for the customer. The options may include:
  • Repurchasing the existing debt back
  • Taking back referred debt from the collection agency
• Offer flexible payment arrangements
• Provide alternative payment methods
• Pause or modify collection activities where appropriate
• Offer flexible payment plans tailored to the customer circumstances
• Avoid actions that could increase risk
• Enable confidential payment options.

Communication approaches:

• Discuss options sensitively and privately
• Explain available support, options and next steps clearly
• Avoid judgemental language and tone about finances
• Provide written confirmation of arrangements, following agreed communication methods and details

Financial hardship

We understand that FDV often intersects with financial hardship and requires a coordinated, compassionate approach to supporting customers experiencing financial difficulties.

Assetinsure is committed to supporting customers that are experiencing all forms of financial hardship. Please review our Financial Hardship Support Policy for more information.

Support strategies:

• Identify signs of financial abuse or control
• Handle financial hardship discussions or applications with flexibility and care:
  • Remove the need for joint policy holder authority
  • Reluctance to discuss financial hardship with a joint policy holder may indicate financial abuse and should be considered in the review process
  • Minimise information and documents required
  • Fast track any application review and decision
• Offer premium payment alternatives
• Consider policy adjustment options such as:
  • Changing benefit structures or sum insured
  • Review benefit options and discuss reducing, removing or altering the policy to create a reduction in premium
  • Pause premium payments, without cancelling a policy
• Enable independent financial decisions
• Connect with financial counselling services.

Communication approaches:

• Use supportive, non-judgmental language
• Ask open and gentle questions to understand more about the customer’s financial situation
• Explain options clearly and simply
• Provide written information when safe, following agreed communication methods and details
• Maintain confidential communication
• Offer regular support check-ins.

Joint policy holders

Joint policies require exceptional care as two people named on a policy may be the perpetrator and victim involved in FDV. The perpetrator may continue to be involved in the victim’s life, or the victim may have recently managed to remove themselves from any involvement. In either situation we need to prioritise the safety and wellbeing of customers experiencing FDV and avoid any action that could put the victim’s safety in jeopardy.

Support strategies:

• Implement robust privacy protocols, separating access to details of affected individuals if possible
• Be aware that an abuser can often pass a privacy, or three-point ID check, to get updated addresses or contact information
• Assess safety implications of actions and sharing information
• Establish contact methods where the victim and perpetrator
• Consider policy separation options, creating a new policy if needed
• Document decisions and rationale clearly
• Where there are children involved be aware of the extra sensitivity this brings and seek supporting legal advice, where considered necessary.

Communication approaches:

• Ensure the customer is informed about information that must be shared with the perpetrator so they can plan accordingly
• Outline available options sensitively
• Maintain strict confidentiality protocols
• Provide clear documentation of choices.

Supporting our people

We recognise that supporting customers experiencing FDV can impact our staff, and that our own team members may be experiencing FDV. Our commitment to support extends to ensuring the wellbeing and safety of our people.

Support strategies:

• Access to debriefing sessions after difficult interactions
• Regular check-ins with team leaders
• Professional counselling services through Employee Assistance Program (EAP)
• Clear boundaries and expectations about personal responsibility
• Regular breaks between complex cases
• Access to quiet spaces for decompression
• Flexible workload management
• Regular training and skill development
• Clear escalation pathways for complex situations
• Protect the details of employees where they may have to contact the perpetrator
• Ensure staff, including anyone interviewing, investigating or attending a home where a customer may be affected by FDV is:
  • Aware of the possible danger they may be in
  • Is trained under the Investigation standards of the General Insurance Code of Practice
• Provide awareness and access to specialist support services
• Recognise signs of staff distress.

Information and specialist services

Information

Customers affected by FDV need to be able to quickly access information about the policies they hold and the support available to them. They are more likely to be comfortable disclosing FDV to our people if they are aware of the support systems that we have in place and the fact that we can refer them to specialist services.

We will ensure that information regarding our Family and Domestic Violence Support Policy and Financial Hardship Support Policy is widely available for our people and our customers and their representatives.

Specialist services

Our people are not experts in identifying or working with FDV, nor are they professional social workers. They have, however, been trained in relation to insurance and financial matters.

For specialist support services they have been trained and provided access to resource materials, so that they may provide support by suggesting that the customer contact relevant external support organisations.

A list of support organisations is made available through our Customer Support Services information on our website.

Responsibilities

Roles and Responsibilities

Training

All representatives dealing with retail customers, including Sales and Claims, are required to complete relevant training that supports them in their roles and meeting our obligations in dealing with customers experiencing vulnerability. The training outcomes should ensure participants:

• Can better identify customers affected by FDV
• Are aware of the appropriate policies and procedures when they are engaging with someone experiencing family or domestic violence
• Deal appropriately and sensitively with customers affected by family or domestic violence
• Apply the Family and Domestic Violence Policy, and related policies and procedures, relevant to their role in dealing with customers affected by family or domestic violence
• Know about the Support Services available to customers on the Assetinsure website.

Training requirements and expectations:

• Read all policies relating to vulnerable customers:
  • Customers Experiencing Vulnerabilities Policy
  • Family and Domestic Violence Support Policy
  • Financial Hardship Support Policy
• Undertake a training course on Australian vulnerability requirements by a recognised content provider before engaging with a customer who has been identified as being a vulnerable customer.
• Complete refresher training periodically to maintain knowledge and requirements that is by a recognised education content provider.
• The content, date and names of participants of training must be kept in a training register, which must be kept for 7 years

While each customer facing team may structure their personnel differently for dealing with vulnerable customers, it is encouraged for each team to nominate a team member to lead responses to vulnerable customers. The nominated team member may receive additional training and act as a knowledge centre and through repeated involvement in responding to vulnerable customers, they are expected to build a base of experience which can be drawn upon.

Monitoring and oversight

• The Assetinsure Risk Partners team is responsible for ensuring that adequate monitoring and oversight is conducted to ensure compliance with this policy. The monitoring and oversight must include arrangements to assess compliance with the concepts set out in this Policy by Assetinsure distribution partners and claims management service providers. This should include:
• Confirming the service providers have policies with aligned principals
• Periodic reporting on data for customers experiencing vulnerability
• Questionnaires confirming up to date training, processes and policies
• Internal audit and quality assurance processes.
• The Line 2 Risk function will provide review and challenge in targeting compliance with this policy

Non-compliance with this Policy

All breaches of this Policy must be reported to the Assetinsure Risk Partners team within 24 hours of identification of the breach and be captured as an incident in Assetinsure’s GRC Platform.

Non-compliance with this Policy by staff will be subject to the Assetinsure Consequence Management Framework. For service providers, non-compliance would be managed in accordance with the requirements of the relevant agreement, with consideration given to terminating the arrangement in cases of serious non-compliance.

Policy Maintenance

This policy shall be updated at least every 2 years and shall also be updated when there is a regulatory change impacting our obligations to assisting customers experiencing FDV or where community expectations have changed.

Version Control

Key Reference Material

• General Insurance Code of Practice, Part 9
• Insurance Council’s Guide to helping customers affected by family violence, issued July 2021 (12 pages), to support the General Insurance Code of Practice
• Legislative instrument, ASIC Corporations (Cash Settlement Fact Sheet and Confirming Transactions) Instrument 2022/809, issued 20 September 2022 (1 page)

  Provides relief from requirement to provide a Cash Settlement Fact Sheet (CSFS) and transaction confirmation to joint policyholders when a cash settlement is offered for a claim, where doing so creates risks of FDV. Those notifications may contain information that could place victims of FDV at risk of harm (eg. it may identify the location of the victim or provide an opportunity for the perpetrator of violence to interfere with the cash settlement).

  The relief is available where it is reasonably believed that providing the notifications would pose risks of family violence. Records are required to be kept for 3 years capturing the reasons for the belief that providing a CSFS and transaction confirmation would pose risks of family violence.

  The relief will expire in 2027. ASIC will review the operation and appropriateness of the instrument before it expires.

• The AFCA Approach to joint accounts and family violence, issued June 2022 (18 pages)

Appendix: Public Policy

Assetinsure is required to have a publicly available policy about how we will support policyholders if they are affected by family violence. This policy is required to be published on our website [GICOP(95)].

Publication:

The content of this appendix, excluding this cover page, is to be loaded onto the Assetinsure website as a script formatted per the Assetinsure website protocols to maximise readability.

The webpage should have a “fast exit” feature where a customer can click on an icon which redirects them to an agreed upon website (weather, news page or something similar) to allow for safety of reading the content. A disclaimer should be included to ensure customers understand that browsing history is not deleted.

Family and domestic violence support

Our commitment to you

At Assetinsure, we understand that family and domestic violence is a complex and sensitive issue that can affect anyone and create unique needs which require additional support when dealing with insurance.

We are committed to supporting customers experiencing family or domestic violence with care, dignity, and respect while providing a safe, confidential, and supportive environment for all our customers. Our goal is for you to be provided empathetic, consistent and timely assistance by people who are authorised to make every effort to accommodate your unique needs.

If you are experiencing family or domestic violence, we encourage you to let us know. If we can help in any way, please ask us.

How can we help You?

If you are affected by family or domestic violence, there are a range of things we may be able to do to try to support you. We will ensure employees, agents, partners, distributors and suppliers are appropriately trained so that we can help by:

• Prioritising your safety
  The safety and wellbeing of you and your family members comes first. If there is something reasonably within our power to do that will maintain or increase your safety, then we will do it.
  If you are in an emergency situation, call 000.
  For additional information and support call 1800 RESPECT, who are available 24/7.
  You can also access their website https://www.1800respect.org.au/
• Responding to your disclosure of family or domestic violence with sensitivity and respect
• Referring you to specialist services
  There are a range of support services available to people affected by family or domestic violence. Descriptions for some of those community services, and how to contact them, are available on the Customer Support Services page.
• Minimising how often you need to disclose information to us.
  Where possible, we will try to ensure that you deal with the same person each time so that we minimise the information we ask you to provide and efficiently capture the information we need.
• Working with your representatives
  We will make it as simple as possible for you to appoint an agent or representative who we will then work with.
• Handling collection arrangements with sensitivity
  If you have an outstanding debt to us and are involved in a situation of family or domestic violence, then we will be open to discussing with you how this can be managed as flexibly as possible.
• Assisting to arrange access to financial hardship help
  If you have been impacted by family or domestic violence you may be eligible for financial hardship support such as deferred, reduced or waived payments for claims excesses or outstanding debts owed to us. For information on financial hardship please refer to our Financial Hardship Support Policy available on our website.
  Sometimes you may need extra help to get your finances back on track during a difficult time. For free, confidential, independent financial advice you can call the National Debt Helpline on 1800 007 007.

How we protect your privacy

We recognise that privacy and confidentiality may be critical to your safety, and we will treat any information you give us about your situation and your personal circumstances with confidentiality. We are bound by the Australian Privacy Principles which are set out in the Privacy Act 1988. For further information please refer to our Privacy Policy.
Depending on your personal circumstances, we can:

• keep your contact information on our systems secure and confidential
• help you manage how your personal information is shared with other parties and discuss safe ways to communicate with you.

Precautions we take when communicating may include:

• finding a mutually appropriate time to talk on the phone
• assessing whether it’s safe to send text messages or leave voice messages, and
• sending information separately – if you’re a joint policy holder, we may need to send information to two different mail or email addresses.

How we handle joint policy holders

If you are a joint policyholder, meaning someone else is named on your policy as well as you, we recognise that this is particularly important, and we will:

• consider the potential risks to your personal safety and act according to our obligations relating to joint policy holders
• where needed to protect your safety we can help you set up a new policy
• explain any limitations regarding policy changes
• offer a sensitive claims handling process that provides you confidentiality and safety.

How we help with claims

If you make a claim and you are affected by family or domestic violence our people will handle the claim with sensitivity, flexibility and care. We will ensure an appropriate and sensitive claims handling process is followed by training our employees to:

• be aware that events resulting in insurance claims can trigger violence
• not require you to make direct contact with an alleged perpetrator or notify the police about an alleged perpetrator
• minimise the need for you to retell your situation
• be flexible in our approach to accommodate your needs
• where possible look to accelerate claim decision outcomes.