New General Insurance Code of Practice: The main points of compliance

New General Insurance Code of Practice: The main points of compliance

Access Polonious' free guide to GICoP compliance in investigations.

Australia’s insurance industry is undergoing the biggest regulatory and compliance changes in its history, and these changes will significantly impact investigation teams.

The Insurance Council of Australia (ICA) has released a new General Insurance Code of Practice, and all insurers were required to implement the changes by July 1, 2021. The changes are legally binding and, as of July 1, 2021, organisations can be fined for non-compliance. These fines can amount to hundreds of thousands of dollars.

To avoid penalties and compliance headaches, insurers will need to change their business to comply with the new regulations, which must be met in their entirety, as opposed to a piecemeal approach. The new Code is a result of a two-year review by the ICA, which invited input and recommendations from various organisations.

Australia’s insurance industry leaders must act now to bring their investigation teams, and the wider organisation, in line with the changes. Investigation teams will be pressured by the more detailed compliance requirements, but this does not mean there are no business imperatives.

Polonious’ report, New General Insurance Code of Practice: A reference guide to how changes will impact fraud investigations, gives insurance industry leaders an overview of the required changes, and details of how the impending requirements can go a long way to benefiting the business.

I this blog, we will look at the main points of compliance.

Regulatory and compliance requirements are often seen as a process and reporting burden by organisations already stretched by administrative overhead. However, contrary to this common belief, the new ICA Code will help insurance companies improve customer engagement. And there is already software available to help manage the new requirements in an automated way.

The benefits of meeting compliance

When it comes to dealing with customers, meeting compliance is good for business.

Insurance investigators need to remember that an investigation is also customer service. When dealing with a customer, including them in the process leads to a much more positive experience for them.

If customers are well informed, and have clear guidelines as to what is required, not only are they more likely to remain a customer, they will also be more likely to refer the insurer to their friends, family, and colleagues.

Moreover, a well-informed investigator can recommend a settlement sooner when evidence of a genuine claim is confirmed, rather than through the regular claims process. Building the ability to “green light” a genuine claim into the investigative process is critical.

The requirements of the new Code are an opportunity for insurers to improve their investigative processes. These improvements should be baked into their investigation methodology from the outset, with compliance monitored via the tracking of progress, timeframes and the investigation plan, ensuring that the claimant is included in regular communication.

With the new rules mostly relating to the claimant, they should be viewed from claimants’ perspective in terms of benefits. This is not to say the changes don’t also ultimately benefit the insurer — by making the claims process more transparent and less time consuming for the claimant, customer satisfaction and retention will increase.

The importance of compliance monitoring

Constant compliance monitoring is necessary to ensure that fairness and due process is followed, which impacts the relationship with the customer and how it is viewed.

For example, any evidence that is gathered under non-compliant circumstances loses its weight in court.

Another benefit of compliance monitoring is a reduction in turnaround times. Shorter investigation times lead to reduced cost of the investigation and increased customer satisfaction.

With a mature investigation methodology and system in place, turnaround time for genuine claims that undergo an investigation can be reduced by 50 per cent.

This, in combination with reduced administration, has the flow-on effect of reducing the total number of open cases also by 50 per cent. One Polonious customer had 1000 cases open at the time of go-live, and within 18 months had reduced that to 500 cases despite still investigating the same total number of cases per month.

By following well-defined processes, administration costs can also be reduced by some 30 per cent, which further reduces turnaround time. In one Polonious customer review, more than two hours of admin time was saved per case. This manifested itself in a reduction in the investigation work from 14 days to 12 days. In short, two hours less administration led to a two-day saving in turnaround time.

Calculating compliance ROI

Polonious has identified more than 40 key points of compliance required to be monitored during the course of an investigation to ensure ICA standards are being met by investigative teams.

In an effort to build consensus and an agreed best-practice approach, in late 2019 Polonious started a working group with a number of leading Australian insurers to discuss how a system could be used to track all of these points of compliance and make them part of the business process.

During the course of an investigation, all of the compliance points can be met as part of the process from beginning to end, with appropriate reminders.

Table 1: The main stages of investigation workflow

Polonious has analysed numerous client investigation processes to determine the efficiencies gained after implementing the SAME methodology.

On average, the ROI at 90 days after implementation was an approximate time saving of 33 per cent, with improvements at 15 out of the 18 stages of the investigation process.

Figure 1: How Polonious saves time during an investigation

Investigation insights: Get the best performance measurement factors

Investigation insights: Get the best performance measurement factors

Polonious_Investigation Insights Study Cover

During the International Association of Special Investigation Units (IASIU) conference held virtually on September 14 and 15, 2020, Polonious ran a panel discussion with some of the world’s leading investigation professionals. Investigation Insights contains new research into the performance, effectiveness and challenges of special investigation units, and communicates how better insights can drive improvements in productivity. You can download the full report here.

In this blog, we will look at the factors by which investigators measure the performance of their SIU and them impact they have.

To gather performance insights, we asked survey respondents to describe the factors by which they measure the performance of their SIU and found that they were largely as we would expect, though there were some concerns.

Referrals can mask real SIU performance

The overwhelming majority of respondents (80%) use number of referrals as a performance measure. When considered alongside the percentage of false positives, this is only a measure of how much work the SIU is doing clearing those cases — not a measure of how much value the SIU is providing.

For example, if you are an SIU with more than 40 per cent false referrals, as some of our respondents appear to be, then your true performance figure — the referrals that result in savings — is less than 60 per cent of your total referrals.

The next most commonly used metric is whether or not fraud is determined, which was used by 55 per cent of respondents. This is getting closer to reporting on actual value — cases where fraud was found and, we can assume, savings were made — but it is not quantifying those savings. This means you might be finding a lot of small fraud, which is good, but the ROI of your budget on those cases might not be there.

However, Figure 10 shows the range of individual measures employed, which we have itemised for illustrative purposes. Respondents could give multiple answers, and most, if not all, sensibly use a combination of measures.

There were also around 40 to 50 per cent of units using the percentage of claims investigated, and percentage referred to a department of investigations (DOI), and another 25 per cent reporting on recovered premiums and 40 per cent reported specifically measuring for ROI.

So, for example, measuring the total number of referrals combined with a percentage of investigations, and a percentage of referrals to DOI, would give a reasonable picture of SIU performance.

However, in terms of value provided to your organisation, the ROI — costs on investigations versus savings on claims — is an easily recognisable measure to claims executives.

Figure 10: Measures used by organisations to calculate the performance of the SIU

Figure 10: Measures used by organisations to calculate the performance of the SIU


Many respondents also report on indirect performance measures (see Figure 11) such as training and deterrent effects.

Figure 11: Performance activities not directly related to investigations


A bit more than half (53.33%) report on fraud deterrent effects, and 60 per cent report on training they provide for other staff on detecting and preventing fraud. Two thirds of respondents (66.67%) report on various other non-fraud related activities, but for this survey we did not go into further detail of what they were.

The contribution of these indirect activities to financial performance is harder to measure. However, it speaks to the proactive work that SIUs are doing to prevent fraud, which is very encouraging.

5 ways to stop workplace harassment and discrimination before it hurts

5 ways to stop workplace harassment and discrimination before it hurts

Stop harassment and discriminatioon before they startIn this blog we’ll look at five ways to help prevent harassment and discrimination among staff before they take their toll.


1. It’s okay to say something

If people are too scared to say something, then it probably won’t get said. Start by reassuring staff that it is okay to report any incident of harassment or discrimination. Make sure everyone in the organisation has access to a newsletter (or other notification) that poor behaviour won’t be tolerated and should be communicated.

If most people know they are likely to be “dobbed in” then the potential for sinister conduct is reduced. It’s also good practice for employers to encourage staff to identify issues before a complaint is made to prevent unnecessary escalation.


2. Do have a policy

Don’t think matters will always resolve themselves, or should be handled in an ad-hoc way by the individual presented with a complaint. Have a consistent policy for dealing with harassment or discrimination and make sure the policy template is recognised, and can be applied by, all the key stakeholders.

The policy doesn’t need to be overly bureaucratic but it should clearly define the severity of different incidents and an appropriate course of action to resolve them.

A policy which facilitates managers who listen and engage with employees to resolve potential disputes makes it easier for everyone if there is a problem. And it makes it easier for staff to raise a question in proper way that will result in an answer.


3. Keep an eye out

Are certain staff clearly not themselves? Keep a look out for anecdotal changes in behaviour, participation and performance. Such changes could mean harassment or some other incident which has led to dissatisfaction. A change in emotion state is one of the best ways to discern if something is wrong that no app can replicate.

Employers should keep an eye out for any sign of employee distress or dissatisfaction, and you can conduct management training to notice the signs of unhappy employees.

Casually observing staff while they are working should give you enough clues to any dissatisfaction or changes in morale.

In addition, keep an eye on who is leaving the organisation and why. A high turnover in one department or under one manager might indicate a toxic culture.


4. Monitor the metrics

In addition to point three above, use automated metrics where it is practical to do so. Things like anomalies in sick leave, measurable output and email volumes can be flagged for follow up by HR to see if there are any concerns.

Identifying trends will indicate both good and poor performance and a feel for what is likely to change in the event of harassment or discrimination.

This tactic can be applied across the company and should reduce the need to “look over the shoulder” of staff to determine if there is a problem.


5. Fine tune your processes

When new trends that appear in the workplace – for example, a new social network – the processes and policies for dealing with inappropriate behaviour should be updated accordingly. Using a new social network to harass co-workers is not acceptable, even if it wasn’t part of an exciting policy.

Ensure your policies and processes are flexible and can be consulted on, and updated, by all stakeholders.

Updating your processes is important as different workplaces have different forms of harassment and discrimination. A workplace where there is potential for dishonest activity (handling money, privileged access, etc) might be very different to one that does not.

At Polonious, our application helps organisations develop better policies and processes, and improves the challenging task of dispute resolution.

By stamping out the first sign of a toxic culture staff will be happier and stick around for the long run and the company’s ethical standards will be highly regarded.

Happy New Year and welcome to 2022, an exciting year for investigation tech

Happy New Year and welcome to 2022, an exciting year for investigation tech

From all of us at Polonious Happy New Year and welcome to 2022.

As we start a new calendar year the team is full of excitement for what we have in store for 2022 and we hope you have big plans as well.

Happy New Year: Let’s collaborate in 2022

We hope this year will bring more opportunities for the Polonious team to collaborate with our customers and partners.

Thanks to the pandemic, most organisations now can easily collaborate remotely, but we hope we will be able to collaborate more in-person this year.

With more collaboration comes better outcomes for our customers and improved product development.

As our portfolio of customers continues to diversify across insurance, banking and education we are always looking at helping customers use Polonious to meet regulatory requirements and improve their end customer service.

Time to focus on investigation tech

In another exciting development this year the team will be focusing on how to take advantage of dedicated investigation management technology for their investigation requirements.

It’s all too common to see organisations struggle with a collection of disparate (and manual) tools for their investigation information.

Managing an investigation is difficult at the best of times but having the right technology by your side makes it much more efficient and leads to be better outcomes for the business.

Stay tuned for a new report we will be releasing in the first quarter of 2022 that covers why Polonious is far superior to alternative technologies such as spread sheets and project management apps.

In 2022 we will be enabling our customers to get more use out of Polonious, which is a feature-rich application and can be configured for any number of business cases or processes – without the need for custom code.

And, as always, if customers need something added to help their business they can always let us know what’s on the wish list and we will take a look at making it happen in future product releases.

Innovate with better workflows

In yet another benefit of dedicated investigations technology is the innovation opportunity it brings.

As a start, look at your business and ask yourself if you are innovating at a pace customers have come to expect.

With better workflows and customer service you can confidently develop new products and services and drive real innovation in your industry.

Our product development roadmap for 2022 is exciting and we are constantly looking at ways to bring innovation to investigations management.

We expect this year will be a busy one for product development and the Polonious application will see enhanced features, improved usability and updated with the raft of regulatory compliance changes.

From all of us at the Polonious team we hope you have a safe and prosperous 2022 and discover the wider benefits of dedicated investigations management technology.

Yours sincerely,

Alastair Steel and Stuart Guthrie
Polonious Founders and CEOs

5 ways to dig deeper than a Web search for better investigation

5 ways to dig deeper than a Web search for better investigation

Whenever an investigation begins it is only natural to jump on the Internet and do a Web search for any relevant material that is publicly available.

The Web is an ideal starting point, but there are many more data sources available to intrepid investigators. In this blog we will look at five ways to garner more information for an investigation, and how the results will help you deliver a more comprehensive result.

1. Specialist Web search engines

When people search the Internet they think of Google, but there are many more specialist search engines which focus on certain niches, or verticals.

These include alternative general search engines and forums and portals which focus on specific topics. Your investigation might relate to the aviation sector, so log onto aviation forums and look (and ask) for information which might be helpful.

There are also many localised search engines which focus on particular geographies, which could help your investigation if there are elements relating to non-English speaking regions.

2. Social networks

Your investigative work is made easier if the people you are investigating are happy to share their private live with the world.

A person’s profile can be reviewed and information can be gathered from it, and from there it will depend on how it fits into the wider case and whether it can be used to bolster the investigative process.

Like search engines, the Web is awash with social networks of all shapes and sizes. Facebook won the war for the most popular social network, but again there are plenty of niche options to include in your investigative work.

Take the time to look at any niche social networks which might give new light to the investigation.

Some OSINT providers will perform detailed social media searches for you, and Polonious integrates with a number of leading providers.

3. Government databases

In addition to open data sources like search engines and social networks, there are more shielded information repositories, such as government-controlled databases which can be used during an investigation.

These databases house public records, but often require some form of application or payment to be searched.

Examples include company records; births, deaths and marriages; estates and wills; and other regulated industry data. If the case involves a criminal or civil court matter, then there will be records available for searching.

Such data can give your investigation the boost it needs by revealing interests and relationships not contained in public repositories.

4. Associates

The person you are investigating might be very private, but their associates might not be.

Today’s connected Web can reveal a lot about a person, even if they didn’t consent to having the information about them shared.

By using a combination of search, social and other data sources your investigation can easily reveal a lot about a person, or organisation, by proxy.

Including relations and associates is now an important factor in getting the most amount of information available.

5. Work history

Another source of information for your investigation is work history. Like government data, this might not be immediately available for free, but can be sourced specialist sources such as financial records.

LinkedIn is the go-to social network for professionals and from there someone’s work history can be investigated.

While looking into work history, don’t forget co-workers. People who have worked together know a lot about each other and this information can be readily shared online.

The amount of open source information available to investigation teams extends well beyond a regular Google search. Look at the numerous free and paid-for data sources which might give your investigation the edge.

There are also support services available which focus on the many different databases containing personal information.

Web search is useful but basic search engines like Google do not cover all bases for investigations
SIU Insights report 2021How do you compare to other SIUs?

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GICOP changes 2021Download the GICOP whitepaper and stay compliant.

Our whitepaper covers all aspects you need to know to stay compliant with the latest GICOP changes coming into effect in 2021. Submit below form to receive the download link and related updates going forward.