04/12/2002, UK: This morning’s £1 million fine levied by the Financial Services Authority (FSA) at Abbey Life for the mis-selling of mortgage endowment policies – and the allocation of £165 million to pay compensation claims – might have been dramatically reduced had the company invested in effective corporate policy management, suggests PolicyMatter today.
PolicyMatter, which specialises in the electronic management of corporate policies, believes that a lack of communication and understanding between the employer and its sales force on the subject of sales practices could have been a major contributing factor in the resulting penalties.
In a press release issued today, the FSA stated that the “…action against Abbey Life results from deficiencies in Abbey Life’s compliance procedures and controls…” – an accusation likely to be levelled at a number of other life assurers over the coming months.
According to Nathan Millard of PolicyMatter: “All employers have a responsibility to ensure that employees are aware of their obligations and what behaviour is expected of them. Using a policy management solution such as PolicyMatter, organisations can create legally-sound policies which meet relevant industry regulations, distribute them to employees electronically and automatically record the acceptance of policies.”
PolicyMatter can even test an employee’s understanding of policy through the use of carefully-structured questions, which must be answered before the employee accepts the policy. Where a member of staff fails to correctly answer policy questions, or indicates that they have an issue with a policy statement, this can be automatically flagged to the HR department or line manager for further action.
When faced with the threat of action by a regulatory body or other agency, a priority for organisations is to consider how any sanction can be avoided or at least reduced. Potentially vital evidence can be close at hand where the organisation can demonstrate with confidence that it has both communicated what behaviour was expected of employees and recorded the acceptance of individual employees to abide by the relevant corporate policies.
As PolicyMatter’s Mark Hobson outlines, this can be a frustrating and inaccurate process: “Many organisations still rely on paper and email distribution for their policies and guidelines – both of which are difficult to manage and audit. Bits of paper get lost, and emails go unread, so it’s no surprise that organisations’ records of whether policies have been read and understood are patchy.”
To ensure that policies don’t go unread, PolicyMatter presents employees with new information and policy statements when they log-on to their computers, and records their acceptance of the policy automatically – making it simple for HR managers and Boards to assess compliance across the organisation and to place liability in the case of legal action.
With a number of life assurers facing possible fines from the FSA plus large compensation claims from policy holders, Nathan Millard suggests organisations need to rethink how they manage corporate policy: “We’re seeing legislation and industry regulations getting tighter and more complex each year. To ensure that they are not a victim of the next scandal, organisations need to improve governance and compliance – central to which is the effective management and auditing of corporate policies.”
PolicyMatter is a joint venture between leading UK law firm, Morgan Cole, and independent software vendor, Extend Technologies. More information about PolicyMatter can be found at
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