Treating Customers Fairly Policy

Effective Date: September 1st, 2022


The Directors and Senior Management at battleface are committed to ensuring that the key principles of treating customers fairly (TCF) are a centre focus in all areas of business activity.

This statement outlines battleface’s commitment to the TCF principles along with its key objectives for applying them across all areas of the business.

Alongside this Mission Statement, battleface has a number of policies and procedures which further promote the fair treatment of its customers including its Complaints Handling, Family Violence, Data Protection and Conflicts of Interest Policies.

As part of the monitoring process we follow “local regulatory publications and guidance on TCF and other conduct issues as well as news and commentary from industry and trade bodies. TCF monitoring is the responsibility of the Compliance Director reporting directly to the Managing Director and Chief Executive Officer.

The governance structure for monitoring the company’s TCF compliance is small but appropriate for the scale and nature of battleface’s business activities.

battleface is committed to promoting positive customer outcomes by subscribing to the objectives of the General Insurance Code of Practice (GICOP) as identified by the Insurance Council of Australia:

  1. The objectives of the GICOP are:
    1. to commit us to high standards of service;
    2. to promote better, more informed relations between us and you;
    3. to maintain and promote trust and confidence in the general insurance industry;
    4. to provide fair and effective mechanisms for resolving complaints you make about us; and
    5. to promote continuous improvement of the general insurance industry through education and training.
  2. We will pursue the above objectives of the GICOP with regard to the law and acknowledging that every contract of insurance is a contract based on the utmost good faith.

In adopting the TCF principles we recognise that fair treatment of our customers is about adding value to the service we offer by aiming to:

  • protect the interests of our customers at each stage of the product life cycle, from promotion right through to after sales service
  • meet as best we can the unique needs of each customer by offering a transparent, efficient and professional service, and constantly reviewing our service to identify areas for improvement

In practical terms for the different areas of our business this means:

  • ensuring that promotional material is clear, compliant, jargon free and appropriately targeted by regular review of all customer documentation by the compliance team
  • completing product oversight and governance reviews and checklists during the product manufacturing process to ensure that the correct target market is identified
  • ensuring that all staff have thorough training on all products manufactured by battleface and understand who they are and aren’t suitable for. Staff are encouraged to challenge products where they spot inconsistencies, ambiguities or potential unfairness in the product literature or product features. Changes to product can be made almost immediately and can be tracked through battleface systems.
  • operating remuneration systems which assure fairness to the customer as well as customer satisfaction
  • keeping detailed records of customer instructions and of any correspondence before, during and after a sale – to help ensure we treat customers fairly and can deal with any complaints that may arise swiftly and fairly
  • follow up with after sales contact with clients where appropriate to correct or improve on the service already offered.
  • ensuring that customer complaints are assessed fairly, promptly and impartially, and in line with all local regulatory deadlines and rules.
  • ensuring that staff are kept up to date with relevant training in relation to competence, data protection and other matters directly affecting the quality of service offered to customers
  • regular monitoring and reporting on the company’s TCF activities as part of its statistics/Management Information (see Appendix One), in order to assess TCF performance across the business and recommend changes where appropriate
  • ensuring that TCF values, which are set and communicated by Senior Management, are supported by all staff and understood in the same way


  • Any sign of customer complaint or dissatisfaction will be escalated to the Complaints Officer and handled in accordance with the company’s complaints procedures.
  • Any action taken by the business which causes customer detriment will be addressed as soon as possible by the Senior Management team.
  • Action points for future improvements will be identified and notified to staff as appropriate.

Alongside its commitment to the TCF principles, battleface understands the importance of recognising signs of vulnerability in its interactions with customers. battleface provides all customer services staff with training on how to identify a customer who may be suffering some detriment, to act with empathy and provide additional assistance if required.

battleface recognises that there are many personal circumstances which might lead to a vulnerability from literacy and numeracy issues, a language barrier, learning difficulties, problems with disability or mental health, to a lack of understanding caused by inexperience, generation gap, remote location, financial distress, cultural background or family violence. In order to help address these vulnerabilities, battleface staff are able to offer additional support in a number of ways, with multilingual staff, 24/7 customer services and assistance and a choice of communication methods. We design our products to be clear and jargon free and provide comprehensive Q&A guides. Most importantly we listen to our customers and act on their feedback, striving to continuously improve our products and services.

Further to this, if you require the assistance of the Translating and Interpreting Service (TIS National), we will accept the cost of calls to use this service.

For anyone who has hearing or speech difficulties, you can contact the National Relay Service (NRS) on:

Phone: 1800 555 660
Email: [email protected]

We also understand that discussing customer vulnerabilities may result in the handling and recording of a customer’s sensitive personal data. battleface ensures the protection of this data in line with data protection law.

Providing a safe and supportive environment for our customers experiencing family violence is of vital importance to battleface. To this end, our staff are trained to treat all customers with respect and dignity by ensuring that appropriate and sensitive consideration is given to every interaction.

Our Family Violence Policy can be found here.

We understand that experiencing financial difficulty is challenging so if you are in urgent financial need of the benefits under your policy or are concerned that you cannot pay an amount you owe to us, please make this clear to us at your earliest opportunity.

To support you in any financial hardship you are experiencing, we may look to:

  • Expedite the assessment and resolution of your claim, where possible; and/or
  • Facilitate a financial hardship arrangement appropriate to you to help ease your urgent financial need.

In the assessment of your request for financial hardship support, we will ensure consideration for all reasonable evidence — for example:

  • Evidence of a serious illness that prevents you from earning income;
  • Evidence of a disability, including a disability caused by mental illness;
  • If you are a Centrelink client, your Centrelink statements; and
  • Evidence of your unemployment.

The above information will be requested from you only if we deem it reasonably necessary to use it to assess your application for financial hardship support.

For assistance, you can contact the National Debt Helpline on 1800 007 007.



Adherence with the TCF principles is measured both quantitively and in qualitative terms. This is achieved through monitoring statistical data and customer outcomes through the following sources:

Statistical data:

Sales data (including policies sold, premium income, average premiums and customer demographics), claims volumes and complaints data (including reasons for complaint and resolved/open complaints) is reported and presented in an internal report on a monthly basis.

The Management Information report is reviewed by Senior Management and circulated to all staff to demonstrate achievements for the period and to highlight any areas of concern.

Qualitative data:

battleface operates an online customer review scheme via ‘Trust Pilot’ which collects customer feedback and satisfaction ratings.

Customers are also invited to contact battleface 24/7 using the online chat service Purechat or by a dedicated email address or telephone number with any concerns or queries. All positive and negative feedback is recorded, escalated to management and/or circulated to staff where appropriate.

In addition to customer feedback channels, battleface regularly engages in proactive customer research and user experience research to ensure that we can meet evolving customer needs, solve customer problems in innovative ways, and optimise our products for successful customer outcomes.

Senior Management and staff assess the output of this research and integrate its results into both near-term tactical planning and long-term strategic initiatives.