Fair value products for our customers

Purpose

This review assesses whether the product provides fair customer value as required under FCA Policy Statement (PS21/5), which includes feedback to CP20/19 and the final rules, and the updated governance requirements in section PROD 4.2 of the FCA handbook and the requirements of Consumer Duty PS22/9.

Scope

The following policy types have been grouped together for the purposes of this assessment, as they are intended to provide similar cover and outcomes for customers, and the target markets are consistent other than for the minimum number of employees as described below. Where there is potential for a product variant to have a different impact on value, this has been considered within the review:

• Standard employer-funded policies
• Pay direct policy: a policy which gives the option to pay basic benefit to a former employee after they have left service
• Flexible policies: includes a core benefit funded by the employer with the option for employees to increase their cover
• Simplicity Income Protection: an Income Protection policy with simplified options and administration
• Policies arranged through a special agreement with one of our distributers or a bespoke policy with non-standard terms
• Policies arranged through a special distribution or Introducer Appointed Representative (IAR) agreement.

Overall value rating: Provides fair customer value.

Date published: September 2023.

1. Product description

Group Income Protection cover meets the demands and needs of an employer who wishes to provide financial support to their employees if they cannot work due to illness or injury beyond the period outlined in their policy (the deferred period), by paying a proportion of their salary as a monthly benefit.

Product features 

• Where appropriate Unum provides absence management support to help employees stay at work or return to work following illness or injury.
• The product allows employers the option to cover additional costs such as pension contributions and National Insurance Contributions.
• The employer can choose for the policy to provide additional lump sum benefits to be used at the policyholder’s discretion.
• Simplicity Income Protection provides a flat benefit of £12,000 p.a.
• Products distributed through IARs are typically marketed at a fixed price and a flat level of cover.
• Our Group Income Protection customers have immediate access to a range of value-added services (VAS) providing health and wellbeing support at no additional cost, including virtual GP appointments, mental health support and a fully integrated Employee Assistance Programme. 

Key exclusions

• Policies provide a non-medical limit to eligible employees, above which cover is subject to providing satisfactory medical evidence and may therefore be restricted as a result
• Initial lump sum benefits, where provided, are subject to a pre-existing conditions exclusion.

2. Target market

• The target market is employers with 3 or more employees based primarily in the UK who want to protect their employees’ incomes in the event they are unable to work due to accident or illness. 
  • An employee can be a permanent or fixed-term employee, a director, equity partner, member of a limited liability partnership (LLP) or a barrister who is a member of the set of chambers
  • An employee who is based overseas must have a contract of employment with a UK resident employer.
• On occasion we will offer policies to employers with fewer than 3 employees under a special arrangement.
• Simplicity Income Protection is aimed at employers wishing to give a basic level of cover with simplified options and administration. The minimum number of lives for this product is 20.
• Flexible policies are available to employers with 250 or more eligible employees.
• Any special distribution or IAR agreements typically apply to policies covering between 3 and 100 employees.

We aim to have a balanced book of business across small, medium, and large employers.

The product is not suitable for:

• Employers not based in the UK, or do not have a UK branch registered at Companies House
• Employers with fewer than the required number of employees
• Non-commercial customers (i.e. individual retail customers)
• Flexible policies are not available for equity partners, LLP members or barristers.

3. Value assessment

The product is shown to continue to provide good value to our target customers in each of the following measures of customer value:

• Suitability for the target market
  • Target customers can use the cover at the appropriate time
  • The extend of the cover appropriately mitigates risks as would normally be expected
  • Underwriting rules create inclusivity for the target market
• Price and value for money
  • Appropriate balance between loss ratio, distribution, and administration expenses
  • Profits are reasonable with a long-term view
• Customer understanding
  • Customers understand the product for the peace of mind it gives should an insured event occur
• Customer support
  • The policy meets a clearly defined need
  • The customer can use the policy under the circumstances they expect.

This rating is based on metrics and data including:

• Customer feedback and research findings
• Numbers and causes of complaints
• Sales and persistency
• Underwriting outcomes
• Claims acceptance rates
• Benefit ratios
• Broker remuneration and commission
• Utilisation of VAS
• Performance against service level agreements (SLAs).

Learn more about Group Income Protection

Purpose

This review assesses whether the product provides fair customer value as required under FCA Policy Statement (PS21/5), which includes feedback to CP20/19 and the final rules, and the updated governance requirements in section PROD 4.2 of the FCA handbook and the requirements of Consumer Duty PS22/9.

Scope

The following policy types have been grouped together for the purposes of this assessment, as they are intended to deliver similar cover and outcomes for customers and the target markets are consistent (other than for the minimum number of employees as described below). Where there is potential for a product variant to have a different impact on value, this has been considered within the review:

• Standard employer-funded policies.
• Flexible policies: includes a core benefit funded by the employer and gives the employees the option to increase their cover.
• Spouse and Partner Cover: allows employees to buy Life Insurance which pays them a lump sum if their spouse or partner dies.
• Simplicity Life: a Life Insurance policy with simplified options and administration.
• Dependants’ pensions: provide a pension for the member’s dependants on the death of a member.
• Voluntary policies arranged through our Benni distribution channel: employees choose whether to join the policy and their level of cover within the policy limits. 
• Policies arranged through a special agreement with one of our distributors or a bespoke policy with non-standard terms.
• Policies arranged through a special distribution or Introducer Appointed Representative (IAR) agreement.

Overall value rating: Provides fair customer value.

Date published: September 2023.

1. Product description

The policy meets the demands and needs of an employer who wishes to provide a lump sum payment, either a multiple of salary or a fixed amount for a member’s dependants if the member dies.

Product features 

• Registered Group Life policies (RGLPs) can insure schemes registered within the HMRC regulations for an occupational pension scheme, or set up under the rules for an Excepted Group Life Policy (EGLP).
• The policy is held by trustees, who will administer and maintain the trust, and distribute the proceeds to the member’s dependants.
• Voluntary policies arranged through our Benni distribution channel have a choice of five benefit amounts from £10k to £50k.
• Products distributed through IARs are typically marketed at a fixed price and a flat level of cover.
• Our Group Life customers have immediate access to a range of Value-Added Services (VAS) providing health and wellbeing support at no additional cost including virtual GP appointments, mental health support and a fully integrated Employee Assistance Programme.
• Group Life customers have access to ‘Cancer Assist’, which offers in-the-moment guidance from an experienced team of client navigators who can help at any stage of the cancer journey.

Key exclusions

• Policies provide a non-medical limit to eligible employees, above which cover is subject to providing satisfactory medical evidence and may therefore be restricted as a result.
• There may be a requirement for employees to be actively at work at the start of cover.
• Policies have an overall maximum benefit limit for multiple claims as a result of a catastrophic or travel event.
• Cover is not provided for the death of a member as a result of, or during business travel to, a country or region where the Foreign, Commonwealth and Development Office (FCDO) advises against all travel.
• A pre-existing conditions and suicide exclusion applies to voluntary policies arranged through our Benni distribution channel. 

2. Target market

• The target market is employers with 3 or more employees based primarily in the UK who want to provide life cover for their employees. 
  • An employee can be a permanent or fixed-term employee, a director, equity partner, member of a limited liability partnership or a barrister who is a member of the set of chambers. 
  • An employee who is based overseas must have a contract of employment with a UK resident employer.
• On occasion, we will offer policies to employers with fewer than 3 employees under a special arrangement.
• Simplicity Life is aimed at employers wishing to give a basic level of life cover to their employees for the first time.
• Flexible policies are available to employers with 250 or more eligible employees.
• The minimum number of eligible employees for spouse and partner cover is 250 and the minimum membership is 50.
• Voluntary policies arranged through our Benni distribution channel are available for employers with 50 or more employees. 
• Any special distribution or IAR agreements typically apply to policies covering between 3–100 employees.

We aim to have a balanced book of business across small, medium and large employers.   

The product is not suitable for:

• Employers not based in the UK or without a UK branch registered at Companies House
• Employers with fewer than the required number of employees
• Non-commercial customers (i.e. individual retail customers).
• Flexible and Simplicity Life policies are not available for equity partners, LLP members or barristers
• Simplicity Life is not available for certain high-risk industry types.

3. Value assessment

The product is shown to continue to provide good value to our target customers in each of the following measures of customer value:

• Suitability for the target market
  • Target customers can use the cover at the appropriate time
  • The extent of cover appropriately mitigates risks as would normally be expected
  • Underwriting rules create inclusivity for the target market
• Price and value for money
  • Appropriate balance between loss ratio, distribution and administration expenses
  • Profits are reasonable with a long-term view
• Customer understanding
  • Customers understand the product for the peace of mind it gives should an insured event occur
• Customer support
  • The product meets a clearly defined real need
  • The customer can use the policy under the circumstances they expect.

This rating is based on metrics and data including:

• Customer feedback and research findings
• Numbers and causes of complaints
• Sales and persistency
• Underwriting outcomes
• Claims acceptance rates
• Benefit ratios
• Broker remuneration and commission
• Utilisation of VAS
• Performance against service level agreements (SLAs).

Learn more about Group Life

Purpose

This review assesses whether the product provides fair customer value as required under FCA Policy Statement (PS21/5), which includes feedback to CP20/19 and the final rules, and the updated governance requirements in section PROD 4.2 of the FCA handbook and the requirements of Consumer Duty PS22/9.

Scope

The following policy types have been grouped together for the purposes of this assessment, as they are intended to provide similar cover and outcomes for customers, and the target markets are consistent (other than for the minimum number of employees as described below). Where there is potential for a product variant to have a different impact on value, this has been considered within the review:

• Standard employer-funded policies
• Flexible policies: includes a core benefit funded by the employer with the option for employees to increase their cover
• Voluntary policies: employees choose whether to join the policy and their level of cover within the limits set
• Simplicity Critical Illness: designed for employers with 50 or more employees who want to give a more basic level of critical illness cover to their employees for the first time
• Voluntary policies arranged through our Benni distribution channel: employees choose whether to join the policy and their level of cover within the policy limits
• Policies arranged through a special agreement with one of our distributers or a bespoke policy with non-standard terms
• Policies arranged through a special distribution or Introducer Appointed Representative (IAR) agreement.

Overall value rating: Provides fair customer value.

Date published: September 2023.

1. Product description

Group Critical Illness cover meets the demands and needs of an employer who wishes to provide a tax-free lump sum benefit if a member is diagnosed with one of the defined medical conditions or undergoes (or, where applicable, is placed on an official UK waiting list for) one of the surgical procedures covered under the policy.

For benefit to be payable:

• The condition or surgical procedure must meet the policy definition, and
• The member must survive for at least 14 days after the critical illness event.

Product features 

• Member’s children are automatically covered at no additional cost from birth until their 18th birthday (or 21st birthday if they are in full-time education).
  • Member’s children are provided with the same type of cover as the member and are covered for a number of children’s specific critical illnesses.
  • Children’s benefit is 25% of the member’s benefit up to a maximum of £25,000.
• Provides the option of covering the spouses and/or partners of employees included in the policy for an additional cost.
• Offers a choice of base cover which insures against some of the most common critical illnesses, or a base and extra cover, which includes a number of additional conditions.
• Voluntary policies arranged through our Benni distribution channel have a choice of five benefit amounts from £10,000 to £50,000.
• Simplicity Critical Illness provides a flat benefit of between £10,000 and £60,000 for 10 of the most common critical illnesses.
• For Simplicity Critical Illness, members’ medical histories will not prevent claims for events arising after they join.
• Products sold through special distribution IAR are typically sold at a fixed price and a flat level of cover.
• The product complies with the Association of British Insurers’ (ABI) Guide to Minimum Standards for Critical Illness Cover 2018.
• Our Group Critical Illness customers have immediate access to a range of value-added services (VAS) providing health and wellbeing support at no additional cost, including virtual GP appointments, mental health support and a fully integrated Employee Assistance Programme.
• Every employee (and their insured partner) covered by a Unum Group Critical Illness policy can access the cancer support service, which is provided by Reframe Cancer. Those covered can contact Reframe Cancer as soon as they are diagnosed for immediate support.

Key exclusions

• A pre-existing conditions exclusion applies to members’ and children’s benefits up to the automatic entry limit. 
  • Where a member has experienced a critical illness before joining the policy, or when they have made a claim under the policy, they will not be able to claim for a recurrence of that condition (other than for cancer: second and subsequent) or certain other critical illnesses. 
  • A member will not be able to claim for a critical illness where they were aware of, or being treated for, a related condition on or before cover started. Some related conditions are disregarded once the member has been covered under the policy for at least 2 years.
  • The pre-existing and related conditions exclusions apply:
    • From when the member joins the policy;
    • After a successful claim; and
    • To all increases in benefit that are not related to an increase in salary. 

^{* For Simplicity Critical Illness, members’ medical histories will not prevent claims for events arising after they join.}

2. Target market

• The target market is employers with 3 or more employees based primarily in the UK. 
  • An employee can be a permanent or fixed-term employee, a director, equity partner or a member of a limited liability partnership (LLP).
  • An employee who is based overseas must have a contract of employment with a UK resident employer.
• On occasion we will offer policies to employers with fewer than 3 employees under a special arrangement. 
• Flexible policies and voluntary are available to employers with a minimum of 150 eligible employees.
• Policies arranged through our Benni distribution channels are available for employers of 50 or more employees.
• Simplicity Critical Illness is available for employers of 50 or more employees.
• Any special distribution or IAR agreements typically apply to policies covering between 3 and 100 employees.

We aim to have a balanced book of business across small, medium, and large employers.

The product is not suitable for:

• Employers not based in the UK or without a UK branch registered at Companies House. 
• Employers with fewer than the required number of employees.
• Non-commercial customers (i.e. individual retail customers)
• Flexible policies are not available for equity partners or LLP members.

3. Value assessment

The product is shown to continue to provide good value to our target customers in each of the following measures of customer value:

• Suitability for the target market
  • Target customers can use the cover at the appropriate time
  • The extent of cover appropriately mitigates risks as would normally be expected
  • Underwriting rules create inclusivity for the target market
• Price and value for money
  • Appropriate balance between loss ratio, distribution and administration expenses
  • Profits are reasonable with a long-term view
• Customer understanding
  • Customers understand the product for the peace of mind it gives should an insured event occur
• Customer support
  • The policy meets a clearly defined real need
  • The customer can use the policy under the circumstances they expect.

This rating is based on metrics and data including:

• Customer feedback and research findings
• Numbers and causes of complaints
• Sales and persistency
• Underwriting outcomes
• Claims acceptance rates
• Benefit ratios
• Broker remuneration and commission
• Utilisation of VAS
• Performance against service level agreements (SLAs).

Find out more about Critical Illness

Purpose

This review assesses whether the product provides fair customer value as required under FCA Policy Statement (PS21/5), which includes feedback to CP20/19 and the final rules, and the updated governance requirements in section PROD 4.2 of the FCA handbook and the requirements of Consumer Duty PS22/9.

Scope

The following policy types have been grouped together for the purposes of this assessment, as they are intended to deliver similar cover and outcomes for customers, and the target markets are consistent (other than for the minimum number of employees as described below). Where there is potential for a product variant to have a different impact on value, this has been considered within the review:

• Standard employer-funded policies
• Flexible and voluntary policies: employees choose whether to join the policy and their level of cover within the limits set
• Policies arranged through our Benni distribution channel
• Policies arranged through a special agreement with one of our distributors or a bespoke policy with non-standard terms
• Policies arranged through a special distribution or Introducer Appointed Representative (IAR) agreement.

Overall value rating: Provides fair customer value.

Date published: September 2023.

1. Product description

Dental Cover meets the demands and needs of an employer who wishes to provide employees and their dependants (where covered) reimbursement towards the costs of routine and essential dental treatment.

Product features

• Clear policies provide up to 6 levels of cover with increasing amounts of benefit against fixed treatments.
• Radiant policies provide up to 5 levels of cover, divided into preventative care, major treatment and minor treatment.
• Policies include:
  • Cover for pre-existing conditions (excluding mouth cancer)
  • Worldwide cover
  • 100% reimbursement of National Health Service (NHS) charges
  • Immediate cover from the day the policy starts
  • Visit any NHS or private dental practice.
• Cover can be extended to the employee’s adult and child dependants.
• Policies arranged through our Benni distribution channel include 3 levels of cover to choose from: ‘Essential’, ‘Standard’ and ‘Premium’.
• Products distributed through IARs are typically marketed at a fixed price and a specified level of cover.
• Members of the policy have access to BenefitHub, a platform which offers a range of discounts, rewards and perks on a range of brands across a variety of categories.

Key exclusions

• The policy will not cover:
  • Cosmetic treatment
  • Mouth cancer which existed prior to joining the plan
  • Prescription fees
  • Treatment carried out before cover starts and after cover ends
  • Benefits for overnight hospital stays in the Republic of Ireland (ROI).

2. Target market

• The target market is employers with 4 or more employees based primarily in the UK who want to provide their employees access to reimbursement towards the costs of routine and essential dental treatment.
  • An employee can be a permanent or fixed-term employee.
  • An employee who is based overseas must have a contract of employment with a UK resident employer.
• On occasion we will offer policies to employers with fewer than 4 employees under a special arrangement.
• For flexible and voluntary policies, the minimum number of lives is 150.
• Voluntary policies arranged through our Benni distribution channel are available for employers with 50 or more employees. 
• Any special distribution or IAR agreements typically apply to policies covering between 3–100 employees.

We aim to have a balanced book of business across small, medium, and large employers.   

The product is not suitable for:

• Employers not based in the UK or do not have a UK branch registered at Companies House.
• Employers with fewer than the required number of employees.
• Non-commercial customers (i.e. individual retail customers). 

3. Value assessment

The product is shown to continue to provide good value to our target customers in each of the following measures of customer value:

• Suitability for the target market
  • Target customers can use the cover at the appropriate time
  • The extent of cover appropriately mitigates risks as would normally be expected
  • Underwriting rules create inclusivity for the target market.
• Price and value for money
  • Appropriate balance between loss ratio, distribution, and administration expenses
  • Profits are reasonable with a long-term view
• Customer understanding
  • Customers understand the product for the peace of mind it gives should an insured event occur
• Customer support
• The policy meets a clearly defined real need

The customer can use the policy under the circumstances they expect.

This rating is based on metrics and data including:

• Customer feedback and research findings
• Numbers and causes of complaints
• Persistency
• Participation
• Customer satisfaction (CSAT) scores
• Underwriting outcomes
• Claims paid
• Benefit ratios
• Broker remuneration and commission.

Learn more about Corporate Dental Insurance

Purpose

This review assesses whether the product provides fair customer value as required under FCA Policy Statement (PS21/5), which includes feedback to CP20/19 and the final rules, and the updated governance requirements in section PROD 4.2 of the FCA handbookand the requirements of Consumer Duty PS22/9.

Scope

The following policy types have been grouped together for the purposes of this assessment as the products are intended to deliver similar cover and outcomes for customers and the target markets are consistent (other than for the minimum number of employees as described below). Where there is potential for a product variant to have a different impact on value, this has been considered within the review.

• Standard employer-funded policies.
• Voluntary and flexible cover.
• Policies arranged through a special agreement with one of our distributers or a one-off policy with non-standard terms.
• Policies arranged through a special distribution or Introducer Appointed Representative (IAR) agreement.

Overall value rating: Provides fair customer value.

Date published: September 2023.

1. Product description

Optical Cover from Unum Dental can help employees and their dependants maintain good eye health by providing cover towards regular eye exams, as well as providing help towards the cost of frames and lenses, including contact lenses.

Product features 

• In 2021, Unum enhanced its Optical Cover to offer greater choice and better coverage.
• The previously (pre-2021) policy provides:
  • 1 level of cover
  • Benefit for a member’s first set of glasses/lenses, or where there has been a change in prescription.
• The current policy provides:
  • Cover towards examinations, lenses and frames, including contact lenses, off-the-shelf reading glasses and digital protection lenses
  • A choice of up to 4 levels of cover
  • The option to insure family members at an additional cost
  • A single lump sum benefit of £10,000 in the event of accidental loss of sight, which can only be claimed once by an insured adult in their lifetime under the optical policy.
• Both policies include:
  • Free choice of optician, including outside the UK
  • Immediate cover — claims can be made from the policy start date
  • Members of the policy have access to BenefitHub, a platform which offers a range of discounts, rewards and perks on a range of brands across various different categories.

Key Exclusions

• The previous policy does not provide cover for:
  • Optical expenses relating to the cost of replacing spectacles or contact lenses due to loss, theft, scratching, breaking or accidental damage
  • Any optical procedure which is purely cosmetic and not necessary to maintain claimants’ optical health.
• The current policy does not provide cover for:
  • Optical sundry items or consumables such as cleaning solution and carry cases
  • Optical expenses relating to the cost of repairing lenses or frames.
  • Laser eye surgery
  • Any optical procedure or purchase which is purely cosmetic and not necessary to maintain, restore, or correct your vision
  • Loss of sight as a result of an accident when already claimed for previously under any optical policy with Unum
  • Loss of sight for any reason other than as a result of an accident as described in this policy
  • Eye examinations, purchases, or any accident which occurs before cover starts or after cover ends.

2. Target market

• The target market is employers with 4 or more employees based primarily in the UK who want to provide optical cover for their employees. 
  • An employee who is based overseas must have a contract of employment with a UK resident employer.
• On occasion, we will offer policies to employers with fewer than 4 employees under a special arrangement.
• For flexible and voluntary policies, the minimum number of employees is 150.

We aim to have a balanced book of business across small, medium and large employers.

The product is not suitable for:

• Employers not based in the UK or do not have a UK branch registered at Companies House
• Employers with fewer than the required number of lives
• Non-commercial customers (i.e. individual retail customers).

3. Value assessment

The product is shown to continue to provide good value to our target customers in each of the following measures of customer value:

• Suitability for the target market
  • Target customers can use the cover at the appropriate time
  • The extent of cover appropriately mitigates risks as would normally be expected
  • Underwriting rules create inclusivity for the target market
• Price and value for money
  • Appropriate balance between loss ratio, distribution and administration expenses
  • Profits are reasonable with a long-term view
• Customer understanding
  • Customers understand the product for the peace of mind it gives should an insured event occur
• Customer support
  • The product meets a clearly defined real need
  • The customer can use the policy under the circumstances they expect.

This rating is based on metrics and data including:

• Claims acceptance rates
• Numbers and causes of complaints
• Persistency
• Customer satisfaction (CSAT) scores
• Benefit ratios
• Broker remuneration and commission.

Purpose

This review assesses whether the product provides fair customer value as required under FCA Policy Statement (PS21/5), which includes feedback to CP20/19 and the final rules, and the updated governance requirements in section PROD 4.2 of the FCA handbook and the requirements of Consumer Duty PS22/9.

1. Product description

Sick Pay Insurance meets the demands and needs of an employer who wishes to provide short-term financial support to their employees if they cannot work due to illness or injury beyond the period outlined in their policy (the deferred period), by paying a proportion of their salary as a monthly benefit. 

This product was closed to new employers from 1st May 2022 but allows new employees to join existing employer policies and for employers to renew cover.

Existing customers were migrated from a self-serve administration platform to our core operating platform in January 2023.

Overall value rating: Provides fair customer value.

Date published: September 2023.

Product features 

• The policy allows an employer when taking out the policy to choose:
  • Who to insure
  • The level of income benefit to provide (between 50% and 80% of an employee’s salary
  • How soon after the employee is absent payments start (with 1, 2 or 4-week deferred periods)
  • How long the income benefit is paid (between 13 and 52 weeks).

Key exclusions

• The policy does not provide cover for employees who are required to hold a license or certificate only issued when they meet certain medical standards.

2. Target market

• The target market is employers with 10 or more employees based primarily in the UK who want to protect their employees’ incomes in the event they are unable to work due to accident or illness. 
  • An employee can be insured if they satisfy the conditions of eligibility defined in the policy, meet the definition of being Actively at Work, and successfully complete Evidence of Insurability, if required.
  • An employee who is based overseas must have a contract of employment with a UK resident employer.
  • Once in force, the number of insured employees may fall below 10.

We aim to have a balanced book of business across small, medium and large employers.   

The product is not suitable for:

• Employers with fewer than the required number of employees
• Individuals subject to Schedule D taxation
• Non-commercial customers (i.e. individual and retail customers).

3. Value assessment

The product is shown to continue to provide good value to our target customers in each of the following measures of customer value:

• Suitability for the target market
  • Target customers can use the cover at the appropriate time
  • The extent of cover appropriately mitigates risks as would normally be expected
  • Underwriting rules create inclusivity for the target market
• Price and value for money
  • Appropriate balance between loss ratio, distribution and administration expenses
  • Profits are reasonable with a long-term view
• Customer understanding
  • Customers understand the product for the peace of mind it gives should an insured event occur
• Customer support
  • The product meets a clearly defined real need
  • The customer can use the product under the circumstances they expect.

This rating is based on metrics and data including:

• Claims acceptance rates
• Numbers and causes of complaints
• Sales and persistency
• Benefit ratios
• Broker remuneration and commission.

Purpose

This review assesses whether the product provides fair customer value as required under FCA Policy Statement (PS21/5), which includes feedback to CP20/19 and the final rules, and the updated governance requirements in section PROD 4.2 of the FCA handbook and the requirements of Consumer Duty PS22/9.

Scope

The following policy types have been grouped together for the purposes of this assessment as they are intended to deliver similar cover and outcomes for customers and the target markets are consistent (other than for the minimum number of employees as described below). Where there is potential for a product variant to have a different impact on value, this has been considered within the review.

• Continuation options: policies taken out by members when leaving corporate dental plans (Clear and Radiant)
• Dencover Boost: individual policies chosen by members though a corporate distribution

Overall value rating: Provides fair customer value.

Date published: September 2023.

1. Product description

These policies are individual (retail) products, which provide the policyholder and their dependants (where covered) reimbursement towards the costs of routine and essential dental treatment.  

Product features 

• Continuation options provide the same cover as the Corporate Dental policy under which the member was previously covered: 
  • Clear provides a choice of up to 6 levels of cover with increasing amounts of benefit against fixed treatments
  • Radiant provides a choice of up to 5 levels of cover, divided into preventative care, major treatment and minor treatment.
• Dencover Boost provides a choice of up to 5 levels of cover, divided into preventative care, major treatment and minor treatment.
• Continuation members have access to BenefitHub, a platform which offers a range of discounts, rewards and perks on a range of brands across a variety of categories.
• Policies include: 
  • Visit any dentist of the policyholder’s choice — National Health Service (NHS) or private
  • Worldwide Cover (Continuation only)
  • 100% reimbursement of NHS charges (Continuation only)
  • Immediate cover from the day the policy starts
• Cover can be extended to the policyholder’s adult and child dependants.

Key exclusions

• We will not cover:
  • Cosmetic treatment
  • Mouth cancer which existed prior to joining the plan
  • Prescription charges, missed appointment fees, and dental sundries and consumables such as toothbrushes and dental hygiene products
  • Treatment carried out before cover starts and after cover ends
  • Benefits for overnight hospital stays in the Republic of Ireland (ROI)
  • Orthodontics for insured adults.
• For Dencover Boost we will not cover:
  • Treatment arising from, traceable to or caused by a pre-existing condition
  • Treatment which was identified, started or completed during any applicable qualifying period
  • Injury caused to the teeth, gums or mouth during any type of hospital procedure.

2. Target market

• The target market for Continuation options are former employees of an employer with either a Clear or Radiant policy who are within 30 days of leaving that employer at the time of taking out the policy and wish to continue their cover on leaving their employer.
• The target market for Dencover Boost is employees of large employers who have chosen to offer Dental Cover to their employees without being the Group Dental policyholder.

3. Value assessment

The product is shown to continue to provide good value to our target customers in each of the following measures of customer value:

• Suitability for the target market
  • Target customers can use the cover at the appropriate time
  • The extent of cover appropriately mitigates risks as would normally be expected
  • Underwriting rules create inclusivity for the target market
• Price and value for money
  • Appropriate balance between loss ratio, distribution and administration expenses
  • Profits are reasonable with a long-term view
• Customer understanding
  • Customers understand the product for the peace of mind it gives should an insured event occur
• Customer support
  • The product meets a clearly defined real need

The customer can use the product under the circumstances they expect.

This rating is based on metrics and data including:

• Claims acceptance rates
• Customer feedback and research findings
• Numbers and causes of complaints
• Sales and persistency
• Performance against service level agreements (SLAs)
• Benefit ratios
• Broker remuneration and commission.

Purpose

This review assesses whether the product provides fair customer value as required under FCA Policy Statement (PS21/5), which includes feedback to CP20/19 and the final rules, and the updated governance requirements in section PROD 4.2 of the FCA handbook and the requirements of Consumer Duty PS22/9.

Scope

The following policy types have been grouped together for the purposes of this assessment as the products are intended to deliver similar cover and outcomes for customers and the target markets are consistent (other than any differences described below). Where there is potential for a product variant to have a different impact on value, this has been considered within the review.

• Executive Income Protection (EIP): designed for small- and medium-sized enterprises (SMEs) providing selected employees the benefits of an extended sick pay arrangement.
• Individual Income Protection (IIP), including:
  • All versions of the product sold between 1977 and 2012 including Personal Income Replacement Plan, Primary Income Protection Plan and Taxguard policies
  • Products sold through a private label arrangement
  • Essential Abilities Cover (EAC).

IIP business closed to new business in 2012 and EIP closed to new business in 2022.

Overall value rating: Provides fair customer value.

Date published: September 2023.

1. Product description

Income Protection meets the demands and needs of an individual who wishes to protect their income if they cannot work or lose essential abilities due to illness or injury beyond the period outlined in their policy (the deferred period) by paying them a monthly benefit.

Product features 

• Insured benefits can include inflation-linked increases in line with the retail prices index (RPI).
• Policies can include automatic benefit increase options which allow the customer to increase their benefit without the need for medical underwriting.
• If the policyholder is not working, policies can include:
  • Cover while not in occupation offering an alternative definition of incapacity for up to 60 months
  • A career break for a maximum of 12 months.
• The EIP product also includes:
  • Portability of cover:
    • If the employee leaves the employment of the policyholder, cover can be transferred to a new employer
    • If the new employer does not wish to continue the plan or the employee becomes self-employed, the employee can transfer ownership to themselves. 
  • Employers can choose to cover additional costs such pension scheme contributions and National Insurance Contributions.
• Additional Disability Plus option for 20% more benefit to be paid.
• The definition of incapacity for EAC is a physical or mental health test.

Key exclusions

• Cover is subject to providing satisfactory medical evidence and as a result may be subject to underwriting restrictions or exclusions.
• During a career break, we will not consider a claim or pay benefit and we will not collect premiums.

2. Target market

The target market for IIP prior is anyone who: 

• Works and needs an income to cover their regular outgoings, and  
• Is not fully covered under a group income protection policy.   

The target market for EAC is higher risk occupations (where traditional Income Protection is not available or may be prohibitively expensive) or those who do not have an occupation. 

The target market for EIP is:

• Single employee limited companies who want to arrange income protection cover through their business
• SMEs looking to provide cover for selected employees.

The product is not suitable for:

• Individuals or employers not based in the UK or without a UK branch registered at Companies House.
• Individuals whose non-UK taxable earnings arise in the currency of any country not in the following list: Australia, any member state of the European Union, Canada, Channel Islands, Gibraltar, Iceland, Isle of Man, Japan, New Zealand, Norway, Saudi Arabia, South Africa, Switzerland, United States of America.
• EIP is not suitable for individuals wanting to protect an income that does not come via the named policyholder
• IIP may not be suitable for those who would qualify for means tested benefits.

3. Value assessment

The product is shown to continue to provide good value to our target customers in each of the following measures of customer value:

• Suitability for the target market
  • Target customers can use the cover at the appropriate time
  • The extent of cover appropriately mitigates risks as would normally be expected
  • Underwriting rules create inclusivity for the target market
• Price and value for money
  • Appropriate balance between loss ratio, distribution and administration expenses
  • Profits are reasonable with a long-term view
• Customer understanding
  • Customers understand the product for the peace of mind it gives should an insured event occur
• Customer support
  • The product meets a clearly defined real need
  • The customer can use the product under the circumstances they expect

This rating is based on metrics and data including:

• Claims acceptance rates
• Numbers and causes of complaints
• Persistency
• Underwriting outcomes
• Benefit ratios
• Broker remuneration and commission.

Purpose

This review assesses whether the product provides fair customer value as required under FCA Policy Statement (PS21/5), which includes feedback to CP20/19 and the final rules, and the updated governance requirements in section PROD 4.2 of the FCA handbook and the requirements of Consumer Duty PS22/9.

1. Product description

The product provides a guaranteed cash lump sum if the policyholder is diagnosed with a medical condition or undergoes one of the specified surgical procedures and survives the event by at least 14 days.

For benefit to be payable:

• The condition or surgical procedure must meet the policy definition; and
• The member must survive for at least 14 days after the critical illness event.

The product closed to new business in 2012.

Overall value rating: Provides fair customer value.

Date published: September 2023.

Product features 

• Policyholders can choose different levels of benefit to match the relative severity of three different types of critical illness event.
• Once a claim has been paid for a critical illness event, no further claims can be made for that category. Any remaining cover in other categories is reduced by the amount of benefit paid.
  • Once the overall maximum benefit has been paid, then plan will end.
• Member’s children are automatically provided with the same type of cover as the member, excluding Total Permanent Disability and Loss of Independent Existence.
  • Children’s benefit is 25% of the member’s benefit up to a maximum of £25,000.
• Other features include:
  • Waiver of premium benefit
  • Option to increase benefit amounts 
  • Inflation-linked increases
  • Reducing cover in line with a repayment mortgage.

Key exclusions

• Cover is subject to providing satisfactory medical evidence and as a result may be subject to underwriting restrictions or exclusions.
• Children’s cover excludes Total Permanent Disability and Loss of Independent Existence.

2. Target market

The target market is individuals between the ages of 16-65 who require Critical Illness Cover.

The product is not suitable for:

• Employers looking to provide group cover for their employees (i.e. commercial customers).

3. Value assessment

The product is shown to continue to provide good value to our target customers in each of the following measures of customer value:

• Suitability for the target market
  • Target customers can use the cover at the appropriate time
  • The extent of cover appropriately mitigates risks as would normally be expected
  • Underwriting rules create inclusivity for the target market
• Price and value for money
  • Appropriate balance between loss ratio, distribution and administration expenses
  • Profits are reasonable with a long-term view
• Customer understanding
  • Customers understand the product for the peace of mind it gives should an event occur
• Customer support
  • The product meets a clearly defined real need
  • The customer can use the product under the circumstances they expect.

This rating is based on metrics and data including:

• Numbers and causes of complaints
• Customer feedback and research findings
• Claims acceptance rates
• Persistency
• Benefit ratios
• Broker remuneration and commission
• Performance against service level agreements (SLAs).