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May 2020

1 Financial Services Guide WILLIS TOWERS WATSON

Introduction What are our services?
This Financial Services Guide (FSG) is designed to assist Where we act as your insurance broker, we will discuss with
you in deciding whether to use any of the financial services, you your insurance requirements, including the scope of
provided by Willis Australia Limited, ABN 90 000 321 237, cover and limits to be sought, and cost. Upon receipt of your
AFSL 240600 (Willis Towers Watson) that are described in instructions, whether written or oral, we will endeavour to
this FSG. satisfy your insurance requirements.
This FSG contains information on: During the course of the placement of your insurance we will
keep you informed of the progress of our negotiations and
■ The services we are authorised to provide to you identify any inability to obtain coverage sought by you. We
■ Our remuneration will use reasonable endeavours to implement your insurance
programme, subject to available insurers, before the
■ Our internal and external dispute resolution procedure intended date of inception, renewal or extension of cover
■ Other important information. (whichever is appropriate).
We will provide you with information about the insurance
cover that we will advise and recommend to you to enable
you to decide whether to accept the insurance cover
Other documents you may receive available. We will answer any questions you may have about
the available cover, its benefits, restrictions, exclusions and
from us conditions.
We do not offer advice in relation to tax, accounting,
STATEMENT OF ADVICE (SOA) regulatory or legal matters. You should take separate advice
as you consider necessary regarding such matters.
If you are an individual or small business and purchase retail
or personal insurance, we may provide you with personal
advice that takes into account your personal needs,
objectives or financial situation. If you receive personal How can you instruct us about your
advice, we will provide you with a Statement of Advice (SoA)
which will contain our advice, the basis of our advice, any insurance?
commission, fees and any other benefits, where possible, in
actual dollar amounts, and any associations we have with You may instruct us about your insurance by telephone or
Insurers or other parties which may have influenced the in person, by fax or email, or by other means as we agree
advice provided. We will give you this SoA before we with you.
proceed to act on your instructions.

PRODUCT DISCLOSURE STATEMENT Who do we act for?

If you are an individual or small business and purchase retail As an insurance broker we normally act for you as your
or personal insurance, where required, we will give you a agent. We will tell you if we are not acting for you in providing
Product Disclosure Statement (PDS) when recommending to any of the financial services.
you a particular insurance product. The PDS is prepared by
the Insurer and contains information about the product For example, for some insurance products, insurers grant us
recommended, to help you make a more informed decision a binding authority or similar facility to accept business on
about whether or not to purchase the product. their behalf. When we place your insurance under a binding
authority or similar facility, we act for you when we provide
you with advice or product recommendation, but we act for
the insurer when we issue the insurance contract.
What financial services are we We may also be granted an authority by insurers, for
authorised to provide? example under a binding authority, to settle claims on your
insurance. We act for the insurer when we settle claims
Willis Towers Watson has an Australian Financial Services within the terms and conditions of the authority granted. It is
Licence and the number is 240600. This license allows us to our policy to refer claims to insurers for settlement decision
provide advice on and deal in general insurance products, where we are not able to settle the claims on a 100% basis.
interests in owned managed investment schemes as an
insurance broker, and miscellaneous financial risk products
limited to mutual risk products, to retail and wholesale clients.
What if we have a conflict of
interest?
Circumstances may arise where we may find we have a
conflict of interest in, or otherwise have a material interest in
or related to, a matter in which we are acting. For example,
we may be asked to act on behalf of any insurer in the
appointment of a loss adjuster; or, we may find that the
interests of two of the clients for whom we act, conflict.
We have conflict management procedures and we seek to
avoid conflicts of interest but where a conflict is unavoidable
we will explain the position fully and manage the situation in
such a way as to avoid prejudice to any party.

1 Financial Services Guide WILLIS TOWERS WATSON

The insurance market is complex and there could be other
relationships not described here which might create conflicts
What is your Duty of Disclosure?
of interest. Whatever the circumstances, we will act in your In order to make our business relationship work, you must
best interests and, if a conflict arises for which there is no provide complete and accurate information and instructions
practicable solution, we will withdraw unless you wish us to in a timely manner, so that we can assist you fully.
continue to act for you and provide us with your written
consent to that effect. Please bear in mind that there is no duty on insurers to make
enquiries of you. You have a duty to disclose to the insurer
before a contract of insurance is entered into, every matter
that is known to you that is relevant to the decision of the
What are our Professional Indemnity insurer whether to accept the risk.
provisions? Failure to comply with your duty of disclosure may allow
insurers to avoid liability for a particular claim or to void the
Willis Towers Watson has Professional Indemnity cover in policy. This duty of disclosure applies equally on taking out
place in accordance with the provisions of the Corporations new insurance policies and on renewal or any change
Act 2001. Subject to the terms and conditions, this includes (variation, extension or endorsement) to your policies. We
coverage for existing and former employees for insurance will not be responsible for any consequences which may
services conducted as employees of Willis Towers Watson. arise from any delayed, inaccurate or incomplete information.

What should you do if you have a What if there is a change in your

complaint? circumstances?
Willis Towers Watson has a formal complaints procedure. You must advise us as soon as reasonably practicable of any
Should you have a complaint please contact your Willis changes in your circumstances that may affect the services
Towers Watson client advocate in the first instance. to be provided by us or the cover provided under your
insurance policy. We may need to give you advice as to the
Alternatively, you may contact our Complaints Officer:
suitability of the insurance for your changed circumstances to
T: (02) 9285 4000 ensure it remains appropriate for your needs, objectives and
E: [email protected] financial situation.

If a complaint cannot be dealt with immediately (within 24

hours of receipt), we will acknowledge your complaint within How do you pay for our services?
5 business day of receipt and will advise you of the person
dealing with it. Our remuneration will be either brokerage, which is a
We are a member of the Australian Financial Complaints percentage of the insurance premium paid by you and
Authority (AFCA), an external dispute resolution facility. allowed to us by the insurer with whom the insurance
If an issue has not been resolved to your satisfaction, contract is placed, a fee as agreed with you, or a
you can lodge a complaint with AFCA. AFCA provides combination of fee and brokerage depending on your
independent financial services complaint resolution that is programme and the various businesses within the Willis
free to consumers. Towers Watson Group of Companies that provide services
to you.
W: www.afca.org.au
A policy administration fee (on a per invoice basis) may also
E: [email protected] apply. We will advise you of the amount of the policy
T: 1800 931 678 (free call) administration fee when we provide you with the insurance
Australian Financial Complaints Authority, GPO Box 3, quote.
Melbourne VIC 3001 The range of brokerage we earn on the insurance products
You can also call Willis Towers Watson to comment upon our we place will vary depending on the product purchased but
service. The toll-free number can be found on our website at will generally range from 0% to a maximum of 35% for
certain products.
www.willistowerswatson.com
You can request further particulars in relation to the
remuneration we receive.
What about Privacy?
We respect your privacy and are committed to protecting What remuneration is received by
your personal information. Our Privacy Policy explains how
Willis Towers Watson collects, uses and discloses the
our Employees?
personal information you provide and what Willis Towers Our employees receive an annual salary that may include
Watson expects of you in this regard. discretionary annual bonuses based on pre-determined
By proceeding to deal with us, you confirm on your behalf business performance criteria such as client service
and/or on behalf of those you represent, agreement to the standards and business profitability. They may also from time
collection, use and disclosure of personal information to time be eligible to receive incentives or bonuses based on
described within our Privacy Policy. business retention or generation. In addition, employees may
Please contact your WTW client advocate or local WTW be eligible to participate in any Willis Towers Watson share
office or visit our website for a copy of our Privacy Policy. plan that may be offered on a discretionary basis from time
to time.
www.willistowerswatson.com/en-AU

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What other remuneration do we REFERRALS

receive? It may, at times, be appropriate (and for your benefit) for us

to use other parties such as wholesale brokers, excess and
surplus lines brokers, underwriter managers, managing
INSURERS general agents or reinsurance intermediaries. These parties
We may have contracts or other arrangements with various may also earn and retain commissions for their role in
insurers pursuant to which we provide certain services, such providing products and services for you. If any such parties
as performing risk management surveys or those under are part of Willis Towers Watson Group of Companies, we
binding authorities and delegated claims settlement will disclose the form of compensation they will earn before
arrangements (for example, providing statements of the insurance is purchased.
business accepted, issuing certificates of insurance cover
or settling claims on behalf of insurers). Under these
arrangements we may be paid by the insurers for the
services provided to them in addition to any brokerage What other Remuneration
we may receive for placing your insurance cover. arrangements are there within
PREMIUM FUNDING WTW Group of Companies?
You may also choose to use a Premium Funding Finance
company or other service provider in connection with the
PLACEMENT-SPECIFIC MARKET-DERIVED INCOME
insurance we place for you or the services we provide. If we We or other companies within Willis Towers Watson Group
receive any remuneration from any such provider by reason of Companies have contracts with various insurers under
of your use of their service, this amount is disclosed as part which Willis Towers Watson Group of Companies provides
of the Premium Funding Quote. certain services, such as those under binding authorities,
The remuneration we receive will be between 0% to 4% of managing general agency and line slip arrangements (for
the premium. The actual amount of remuneration received example, providing statements of the business accepted and
depends upon the premium payable. Please ensure you the issuance of certificates of insurance cover).
review this remuneration before you make a final decision to Willis Towers Watson Group of Companies may also provide
use that service provider. reinsurance broking services for insurers. We may also enter
into service agreements with certain insurers in order to
INTEREST assist the development of insurance products for our clients.
In the ordinary course of business we may also receive Under these arrangements Willis Towers Watson Group of
interest on client and insurer monies from the date when we Companies may be paid by the insurers for the services we
receive funds until we settle with those due to receive them. provide to them in addition to any fees or commissions Willis
We confirm that we shall retain that interest rather than pay Towers Watson Group of Companies may receive from you
it to you or the insurer (as the case may be). for placing your insurance cover.

REFERRALS CONTINGENT COMPENSATION

If you are an individual or small business and purchase retail Willis Towers Watson Group of Companies may accept
or personal insurance and you have been referred to us by certain forms of contingent compensation in locations where
someone else, we may pay the referrer a share of our fee or they are legally permissible and meet standards and controls
brokerage in relation to that referral, generally ranging from to address conflicts of interest. Because insurers account for
a minimum of 1% to a maximum of 50%. contingent payments when developing general pricing, the
price our clients pay for their policies is not affected whether
Willis Towers Watson Group of Companies accepts
contingent payments or not. If a client of Willis Towers
What association do we have with Watson Group of Companies prefers that we not accept
contingent compensation related to their account, we will
Related Service Providers? request that the client’s insurer(s) exclude that client’s
business from their contingent payment calculations.
When arranging cover for you, we may recommend that you
use the services of Richard Oliver Underwriting Managers
Pty Limited (ROUM), AFSL License Number 238334, a GLOBAL360 FACILITY – GLOBAL SPECIALITIES
member of Willis Towers Watson Group of Companies. CLIENTS ONLY
Willis Towers Watson may receive brokerage from this Willis Towers Watson Group of Companies has developed
company if one of their insurance products is purchased, a facility for business placed through our London Global
generally ranging from a minimum of 0% to a maximum of Specialties businesses called Global360, which offers
35%. underwriting capacity for specialised risks and under which
Willis Reinsurance and ROUM, both members of Willis Willis Towers Watson Group of Companies provides a range
Towers Watson Group of Companies, may act for insurers of services to participating insurers. A separate fee is paid by
with whom your risks are insured, in the placement and such insurers for the delivery of these services to them. This
administration of the insurer’s risks. These activities are fee is calculated within a range, depending on the scale of
separate contracts subject to their own terms and conditions services provided, further details of which we will identify to
including those relating to remuneration, between the insurer you prior to placement. Insurers have agreed that they will
and ROUM or Willis Reinsurance. bear this fee as part of their operating costs and not to
increase premiums directly payable by Willis Towers Watson
Group of Companies’ clients.

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FINMAR – FINEX PLACEMENTS Willis Towers Watson Group of Companies believes that the
best way to defray the cost of these functions is through this
A separate Business Unit within Willis Towers Watson Group brokerage. We will disclose the receipt of Subscription
of Companies, FINMAR Market Services, provides a wide Market Brokerage to you.
range of services direct to certain insurers that place
business for FINEX clients globally. A separate fee is paid to FACILITY ADMINISTRATION CHARGES AND PROFIT
FINMAR Market Services by insurers for the delivery of these
services to them. This fee is calculated within a range of COMMISSIONS
3.125% and 5.25% (plus applicable tax) of the overall Willis Towers Watson Group of Companies operates a
premiums placed depending on the scale of services number of “facilities” (Binders, Lineslips, Programs, MGAs
provided. Insurers have agreed that they will bear this fee as and Arrangements) under which we undertake a number of
part of their operating costs and not to increase premiums tasks. Some of those tasks are purely for the benefit of our
directly payable by Willis Towers Watson Group of clients, others are services that an insurer would be expected
Companies’ clients. to perform.
Our remuneration may reflect this multi-beneficiary approach
PANELS with what is known as a facility administration charge that
Willis Towers Watson Group of Companies develops panels covers the cost of these activities. A facility administration
of insurers in certain market segments. Participating insurers charge is additional to the fee or brokerage that Willis Towers
are reviewed on a variety of factors. Commission rates on Watson Group of Companies receives for placement and
panel placements may be higher than rates paid on business other services to clients. We will disclose any such charges
placed outside of the panel process. Willis Towers Watson to you.
Group of Companies discloses its commission rates to These facilities typically apply to straightforward, small
clients on quotes obtained through the panel process prior to business lines or specialist product areas, for example,
binding the coverage. In some instances, insurers pay an commercial combined, motor, personal lines, personal
administration fee to participate in the panel process. Your accident and terrorism.
Willis Towers Watson broker will provide you with additional The type of business written in these facilities tends to be
information on Willis Towers Watson Group of Companies high-volume, low-premium business that would not be viable
Panels upon request. for insurers to write individually on the open market. By
grouping this business together, clients enjoy the benefits
BROKERAGE ON FEE BUSINESS of a broad product, suited to their needs and the cost savings
In some territories outside of North America, Willis Towers of collective buying power.
Watson Group of Companies obtains brokerage on business In a very limited number of cases a portion of our
where our client pays us a fee. Our intention is to seek remuneration may be driven by the underwriting profitability
remuneration for work that Willis Towers Watson Group of of the facility. There is a potential for us to earn such “profit
Companies carries out for all parties in the insurance commissions”, but, because this business is grouped
transaction but for which Willis Towers Watson Group of together, it is not possible to determine the extent to which
Companies is not otherwise sufficiently compensated. Some the profitability of a book is affected by any single client.
examples of this are the vastly-increased cost of regulation,
distribution and infrastructure costs. This brokerage that
Willis Towers Watson Group of Companies receives is a set
percentage and is not contingent on achieving any level of
growth, retention or profit on the business concerned. You
can choose to exclude your placements from being included
in any of these carrier agreements.

SUBSCRIPTION MARKET BROKERAGE

Willis Towers Watson Group of Companies adds
Subscription Market Brokerage in some of its core specialty
businesses that place business into the subscription markets,
predominantly in London. The principles underlying this
Subscription Market Brokerage program include the
following:
■ Willis Towers Watson Group of Companies is required to
handle increased infrastructure costs such as those
arising from presentations to and negotiations with
multiple entities in the subscription market;
■ Willis Towers Watson Group of Companies performs
additional administrative, regulatory, accounting and
support functions in order to complete subscription
market placements. These functions benefit our clients
and insurers; and
■ Working groups of insurers in the subscription market
recognize these additional costs and agree that a
negotiated percentage of the premium to account for
these costs is appropriate and helps assure competitive
access to that market.

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1 Financial Services Guide WILLIS TOWERS WATSON