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Insurance in Superannuation Voluntary Code of Practice Transition plan

About our transition plan

The Insurance in Superannuation Voluntary Code of Practice applies to superannuation trustees. Colonial First State Investments Limited, the trustee, supports the Code and its objectives.

It is our intention to comply with various sections of the Code by the target compliance dates set in this transition plan. However, given current uncertainty surrounding the potential legislative changes impacting insurance provided through superannuation, it may be necessary to update the plan outlined below.

What super products will need to comply with the Code?

Insurance cover is available to eligible members through the following superannuation products:

Superannuation fund Superannuation products
Colonial First State FirstChoice Superannuation Trust
  • FirstChoice Personal Super
  • FirstChoice Wholesale Personal Super
  • FirstChoice Employer Super
  • Total Care Plan Super
Colonial First State Rollover & Superannuation Fund Colonial First State Rollover & Superannuation Fund
Commonwealth Essential Super Commonwealth Essential Super


Some of the standards in the Code relate to the provision of automatic insurance cover to members. FirstChoice Employer Super and Commonwealth Essential Super are the only products we issue that provide automatic insurance cover to eligible members.

How and when we’ll comply with the Code

We have commenced a review of our insurance arrangements including product design and our approach to member engagement and services to determine aspects that require change to comply with the standards in the Code. We will, however, prioritise the best interests of members and any law or regulation where it is inconsistent with the Code.

Although we have commenced our review, due to the complexity and volume of changes required, we intend to take a phased compliance approach with the full compliance expected, to the extent that it is in the best interests of members and consistent with the law, by the dates outlined in the table below. 

Standard in the Code How we'll comply Target compliance date*
Benefit design and premiums
(sections 4.1 to 4.17)

We have an insurance strategy, as required under superannuation law. We’ll review and update our insurance strategy for the requirements of the Code. Where our product provides insurance cover on an automatic basis, in assessing the level and type of automatic cover, we’ll consider several factors including member demographics, salary (actual or estimated) and how insurance premiums from super may reduce the money a member has to live on when the time comes to retire.

31 December 2020
Automatic end of cover
(sections 4.25(e) and (f), 4.27)
These standards apply to automatic insurance members. We’ll review our current end of cover processes and make amendments to meet the requirements of these standards. We believe potential changes to legislation commencing on 1 July 2019 will prevail over these standards.
31 March 2020
Reinstatement of cover, cancelling cover, communications about lack of contributions and duplicate cover
(sections 4.18 to 4.24, 4.25 (a) to (d) and (g), 4.26, 4.28 to 4.31)
 
We’ll review our current processes for cancelling insurance cover, communicating to members about not adding money (super contributions) and identifying whether members may have duplicate insurance cover. We’ll enhance our processes and implement new ways to meet the requirements of these standards. 30 June 2020
Helping members make informed decisions
(section 5)
We’ll review the quality and content of our current communications and will create new communications to meet the requirements of the standards to better help members make informed decisions. 30 June 2020
Supporting vulnerable customers
(section 6)
We’ll review our current processes for supporting vulnerable members. We’ll enhance our processes and implement new ways to meet the requirements of the standards to support members. 31 December 2019
Handling claims
(section 7)
We’ll review our current claims handling processes. We’ll then enhance the way we do things with new processes to ensure we meet the requirements of the standards for handling claims. We’ll also publish our claims philosophy on our website. 30 June 2020
Premium adjustments
(section 8)
We’ll publish on our website any material benefits received from our insurer or any premium adjustment payments (if applicable) 30 June 2019
Promoting our insurance cover
(section 9)
We’ll review our insurance communications to ensure they meet the requirements of the standards in promoting insurance cover. We’ll also work with any third parties (like advisers) who promote or distribute our products to ensure their commitment to compliance with this section. 31 December 2020
Changes to cover
(section 10)
We’ll review our current processes to ensure they meet the requirements of the standards for changes to insurance cover. 30 June 2020
Refunds
(section 11)
We’ll review our current refund policies. We’ll enhance our processes and implement new ways to meet the requirements of the standards for refunds. 30 June 2020
Staff and Service Providers
(section 12)
We’ll review our processes for the appointment and monitoring of staff and service providers. We’ll enhance our processes and negotiate with our service providers where required to comply with the standards about staff and service providers. 30 June 2020
Making enquiries and complaints
(section 13)
We’ll review our enquiries and complaints handling processes and will make changes to meet the standards around enquiries and complaints. 31 December 2019
Promoting, monitoring and reporting on the Code
(section 14)
We’ll prepare systems and processes to enable compliance with promoting, monitoring and reporting on the Code. 31 December 2020


*Changes to regulations or law may impact the target compliance dates. If required, we will update our transition plan accordingly.