As the licensed insurer for Assurant’s insurance products and services in New Zealand, Virginia Surety Company, Inc. (New Zealand branch) (VSC) has developed and adopted a Fair Conduct Programme that details all the policies, processes, systems and controls it has in place to support the fair conduct principle.

The fair conduct principle ensures that we (including our employees and intermediaries) treat customers fairly at every touch point in their customer journey with us. This applies from product and service design, through to sales, distribution, claims, and complaints.

Our Fair Conduct Programme applies throughout the customer lifecycle, including product design, marketing, sales, underwriting, policy administration, claims handling, renewals, complaints management and remediation activities.

This summary is not designed or intended to provide customers with fundamental information to rely on when choosing a financial institution. The purpose of this summary is to assist customers to understand how they should be treated and to demonstrate our commitment to treating our customers fairly.

This summary provides information about VSC’s Fair Conduct Programme, which has been established, implemented and maintained in accordance with the Financial Markets Conduct Act 2013.

VSC’s Fair Conduct Programme is effective from 31 March 2025 and applies to all retail customers as defined in the Financial Markets Conduct Act 2013. It is not applicable to wholesale customers.

Fair Conduct Principle

At VSC we are committed to always treating our customers fairly by ensuring the five elements of the fair conduct principle are considered in everything we do. VSC will:

• Pay due regard to customers’ interests
• Act ethically, transparently, and in good faith
• Assist customers to make informed decisions
• Ensure that the relevant services and associated products we provide are likely to meet the requirements and objectives of customers (when viewed as a group or relevant customer segments)
• Not subject our customers to unfair pressure, tactics or undue influence.

Our Products and Services

VSC offers a range of products and services through its intermediaries including:

Our Commitment to You

We review our products, services and distribution methods regularly to make sure they are fit for purpose

We have governance frameworks in place to support regular reviews of the design, distribution, management and maintenance of our products and services. Regular and ongoing monitoring ensures our products and services remain fit for purpose, accessible to all customers and enables us to continually enhance and improve the products and services we offer.

We regularly assess whether our products and services continue to meet the needs, objectives and characteristics of the customers for whom they are intended and take action where improvements are identified.

We train our employees and intermediaries to ensure they have the skills and competency to provide our products and services

Our employees and intermediaries undergo regular training to ensure they know and understand our products and services and so they can effectively support you. Our Code of Business Conduct and Ethics establishes clear expectations and standards that all employees must abide by to support good customer outcomes. Our intermediaries are required to understand and abide by our Suppliers Code of Conduct.

We provide ongoing conduct and compliance training to employees and relevant intermediaries to ensure they understand their obligations under our Fair Conduct Programme and their role in supporting fair customer outcomes.

Our communications with you will be timely, clear and transparent

At VSC, we are here to help you. You can communicate with us by phone, email or post. We will use plain language in all communications with you including on our website and in our policy wordings. All communications with you will be timely, clear, concise and written effectively to ensure we are supporting you to make informed decisions. We make product information available on our website or you can contact us to request copies of your policy documents.

We proactively manage feedback and complaints

We acknowledge that sometimes things don’t go right and there might be times when issues connected with our product or services occur. At VSC we take feedback and complaints seriously and are committed to upholding the highest standards of fairness and transparency in our interactions with all customers.

VSC has established a complaints process designed to ensure that any concerns or issues raised by our customers are addressed promptly, effectively, and with the utmost respect.

Our approach to handling complaints emphasises clear, open communication, and a commitment to finding solutions that reflect our dedication to delivering good customer outcomes. All complaints and feedback are reviewed, managed, investigated and resolved in accordance with our internal complaints process.

If you have a complaint about our products or services, we encourage you to first speak to our staff or a manager directly responsible for that area. If your complaint cannot be resolved, you can refer it to our Internal Dispute Resolution Panel (IDR Panel) for review and the outcome of the IDR Panel review will be provided to you in writing.

You can refer your complaint to the IDR Panel in the following ways:

• By calling 0800 443 881 (Monday to Friday between 8:30am – 5:30pm New Zealand Standard Time)
• Send an email to customerfeedback@assurant.com
• Writing to us at Virginia Surety Company, Inc. PO Box 355, Christchurch 8011 New Zealand

If you remain dissatisfied with the outcome of your complaint, you can refer the matter to the Insurance and Financial Services Ombudsman (IFSO) scheme within 2 months from the date of the IDR Panel’s decision.

The IFSO can be contacted by:

• Calling 0800 888 202 (free call) (Monday to Friday between 8:30am – 5pm New Zealand Standard Time)
• Emailing your complaint to info@ifso.nz, or
• Completing the online complaint form at www.ifso.nz

We use complaints, customer feedback and complaint trends to identify opportunities to improve our products, services, systems and customer outcomes. Where appropriate, we take corrective action and provide remediation to affected customers.

Treating our Customers Fairly

Our customers are our priority, and our Fair Conduct Programme aims to ensure that our customers are treated fairly. We strive to do this by:

• Making sure our employees and intermediaries have the skills and resources to provide suitable products and services competently.
• Reviewing our customer communications to ensure they are clear, concise, transparent and easy to understand.
• Supporting customers in vulnerable circumstances.
• Designing our products and services to ensure they meet our customers’ requirements and objectives.
• Reviewing our distribution methods to ensure our employees and intermediaries always comply with our policies and procedures.
• Having policies and procedures in place to manage the distribution of our products and services through our intermediaries.
• Providing adequate mechanisms for customer complaints and having remediation plans in place for when things go wrong.
• Monitoring the conduct of our intermediaries through oversight activities, reporting, quality assurance reviews and other controls to help ensure good customer outcomes.
• Identifying, assessing and supporting customers experiencing vulnerability, including customers affected by illness, disability, financial hardship, bereavement, language barriers or other circumstances that may impact their ability to engage with us.
• Regularly monitoring customer outcomes and taking timely corrective action where conduct issues or customer harm are identified.
• Designing our commission, remuneration and incentives arrangements to support good customer outcomes and reduce the risk of inappropriate sales practices. Our remuneration and incentive arrangements are designed to comply with applicable regulatory requirements and are not based on sales volume or value.

Supporting Customers Experiencing Vulnerability

We recognise that some customers may experience circumstances that make them more vulnerable and may require additional support. We are committed to identifying and responding appropriately to customers experiencing vulnerability, including those affected by illness, disability, financial hardship, bereavement, language barriers, accessibility needs or significant life events. Our employees and relevant intermediaries are provided with guidance to help recognise and respond to vulnerable customer circumstances and to ensure those customers are treated with care, empathy and respect.

Oversight of Intermediaries

As many of our products are distributed through intermediaries, we maintain policies, processes and controls to oversee their conduct. This includes onboarding requirements, training expectations, ongoing monitoring, quality assurance activities and performance reviews, and oversight designed to ensure intermediaries comply with our Fair Conduct Programme and support good customer outcomes. Where issues are identified, we work with intermediaries to address them promptly and take appropriate action where required to protect customer interests and support good customer outcomes.

Governance of our Fair Conduct Programme

Our Fair Conduct Programme has been developed to be relevant and proportionate to the unique factors and characteristics of our business. Ultimate responsibility and accountability for oversight of compliance with our Fair Conduct Programme sits with the Chief Executive Officer for VSC. The Chief Executive Officer has delegated day-to-day oversight of compliance with our Fair Conduct Programme to the Head of Compliance, ANZ.

To enable VSC’s commitment to its Fair Conduct Programme and to treating customers fairly, regular monitoring and oversight is undertaken by our internal Compliance Committee and Product Governance Committee. Both these Committees meet regularly to review and consider various metrics including outcomes of internal and external quality assurance activities, compliance assurance activities, complaints reporting, incidents and breaches, and internal and external audit findings. Outcomes of the Committee meetings are reported through to our Audit, Risk and Compliance Committee.

We regularly monitor customer outcomes through complaints reporting, quality assurance reviews, compliance assurance activities, customer feedback, incidents, breaches, audit findings and other conduct risk indicators. The insights gained from this monitoring help us identify emerging risks, address issues promptly and continuously improve customer outcomes.

Our Fair Conduct Programme is reviewed at least annually by the Head of Compliance, ANZ and any major amendments are reviewed and approved by the VSC Board.

Last Reviewed: August 2026