1. Who provides the financial services described in this FSG?
The financial services referred to in this Financial Services Guide (FSG) are provided by Emergence Insurance Pty Ltd (ABN: 46 133 037 153) (‘Emergence’). Emergence hold an Australian Financial Services Licence (No.: 329634) issued by the Australian Securities and Investments Commission (‘ASIC’) under the Corporations Act 2001 (Cth).
All references in this FSG to ‘we’, ‘us’ or ‘our’ are references to Emergence unless specified otherwise.
2. How do you contact us?
You can contact us as follows:
Street Address: Level 8, 4-6 Bligh Street,
Sydney NSW 2000
Postal Address: GPO Box 327 Sydney NSW 2001
Phone: 1300 799 562
3. The purpose of this FSG
This FSG sets out the services that we can offer you. It is designed to assist you in deciding whether to use any of those services and contains important information about the services; how we and others are paid; any potential conflict of interest we may have; our internal and external dispute resolution procedures and how you can access them; and arrangements that are in place to compensate clients for losses.
This FSG is an important document. Please read it carefully and keep it in a safe place for your reference and for any future dealings with us.
4. Who is responsible for the financial services provided?
Emergence is responsible for the financial services provided to you. Emergence is also responsible for the content and distribution of this FSG.
We have given authority to your insurance broker to release this FSG on our behalf. Any financial services provided in accordance with this FSG will only relate to products arranged by us.
5. From when does this FSG apply?
This FSG applies from 1 October 2023 and remains valid unless replaced by a subsequently issued FSG.
6. What services can we provide?
We are authorised to deal in financial products, provide financial advice and provide claims handing service in relation to general insurance products for retail and wholesale clients. We only transact business through a licenced insurance broker. The products Emergence distributes are wholesale products.
To assist in your decision making, we will provide Important Information with the insurance policy.
In some cases, we may make a general recommendation or give an opinion about the insurance products (‘General Advice’). We do this without consideration of your specific individual objectives, financial situation or needs. This is a General Advice service. We do not provide any advice on whether other products may be more appropriate for your needs or which of the product options may be best for you.
You need to consider the appropriateness of any information or General Advice we give you, having regard to your specific individual objectives, financial situation or needs before acting on it.
7. Who do we act for?
When we provide financial services to you, including when we provide a claims handling service, we will not be acting on your behalf. This is because we are an underwriting agency. When we distribute insurance products and handle claims, we are acting under a binding authority given to us by the insurer who underwrites the insurance cover. This binding authority allows us to accept your application for insurance through your broker, as if we were the insurer. The authority also permits us to handle a claim as if we are the insurer. At all times we represent and act for the insurer and not for you.
Your insurance broker acts for you and will deal with us on your behalf.
8. General Insurance Code of Practice
We support the General Insurance Code of Practice (‘the Code’). The Code is designed to raise the standard of practice and service in the general insurance industry. For further information about the Code, please go to www.codeofpractice.com.au or contact us.
9. What information do we maintain in your file and how can you access it?
10. How we are paid for our services
How will you pay for the services provided?
When we issue you with an insurance product, we charge a premium, on behalf of the insurer, based on the risk profile you have provided. The total amount you pay is the premium plus any relevant taxes, charges and levies.
When you pay your premium to us (via your insurance broker), it will be banked into our trust account prior to being remitted to the insurer’s trust account, net of any commission (see below) payable to us. We will retain the commission from the premium you pay us and remit the balance to the insurer in accordance with our arrangements with the insurer.
All collected premium, plus any relevant taxes, charges and levies, are held in our trust account in accordance with statutory provisions.
You can choose to pay the premium by any of the payment methods set out in your insurance schedule and tax invoice. You are required to pay us, on behalf of the insurer, within the timeframe set out in the insurance schedule and tax invoice.
We receive income from the interest on premium held in our trust account and earn a return. We will retain any interest earned on the premium.
We receive a commission which is calculated as a percentage of the premium.
The commission is paid at a rate of 39%. From that, retail brokers receive a commission on each policy, capped at a maximum of 25% of base premium, and reinsurance brokers, who handle our transactions and placements with the insurer, receive 3%. We pay a professional services fee (PSF) in connection with our arrangement with Steadfast Group Limited (SGL – see below) and earn the remainder as net commission. Our net commission supports product research and development, underwriting, claims handling, marketing, design and maintenance of our IT transaction platform and websites, staff training and development, broker education and general administrative, overhead and other expenses. The commission is included in the total amount you pay for the insurance policy and is not in addition to the insurance policy. The commission applies to each policy issued or renewed through us. The commission may not be refundable in the event of cancellation unless the insurance policy is cancelled either within the cooling-off period or is a full-term cancellation.
See below for information on our association with Steadfast Group Ltd.
Emergence has potential to earn a profit share commission based upon performance of the book of business. Due to the contingent nature of insurance and the way the arrangement is set up, it is not possible to know the exact amount, if any, to which we may be entitled until the end of the qualifying period.
In some circumstances, we may charge you a Policy Fee. The standard Policy Fee for our Personal Cyber Policy ranges from $11 up to $303 inclusive of GST. The Policy Fee varies depending upon the Emergence insurance product purchased. The Policy Fee, as applicable, is noted on your insurance schedule and tax invoice. We can tell you the exact fee at the time you contact us (via your insurance broker). Such fees include meeting our costs of preparation and distribution of documentation.
The Policy Fee applies to each policy issued or renewed through us. The Policy Fee is not refundable in the event of cancellation unless the insurance policy is cancelled either within the cooling-off period or is a full-term cancellation.
We do not charge a fee for cancellation of the insurance policy. You may cancel your insurance policy at any time. If you choose to cancel your insurance policy, we will retain a portion of the
premium that relates to the period for which you have been insured. We will refund the residual for the unexpired period less any non- refundable taxes, charges and levies provided that no event has occurred where liability arises under the insurance policy.
Remuneration of employees
Our employees that will assist you with your insurance needs will be paid a market salary and may earn a cash bonus or other incentives based on achievement of a broad range of our goals, including financial targets.
You may request particulars of our remuneration (including commission) or other benefits, including, to the extent relevant, a statement of the range of amounts or rates within a reasonable time following receipt of this FSG and before we provide any financial service to you.
Steadfast Group Ltd (ABN 98 073 659 677) (‘SGL’) holds an equity position in Emergence.
SGL may receive a professional services fee (PSF) from insurers, premium funders and underwriting agencies such Emergence (Partner) for access to regulatory and compliance support; marketing and communications; data insights; and access to technology platforms. The PSF is an agreed amount between SGL and the relevant Partner, usually annually. The PSF is not determined by the volume of the business that the Steadfast Network brokers place, nor is the amount of the PSF known to the Steadfast Network Brokers, so it is not able to influence recommendations to their clients.
Emergence may have access to shared services from SGL, including: compliance tools; procedures; manuals and training; legal; HR banking; and group purchasing arrangements. These services are funded by SGL, subsidised by SGL or SGL receives a fee for them.
SGL’s FSG is available at www.steadfast.com.au or on request by telephoning SGL’s Company Secretary on +61 2 9495 6500.
12. Conflicts of interest
We take any potential and actual conflicts of interest seriously and have a conflict of interest policy. Conflicts of interest are circumstances where some or all of your interests are or may be inconsistent with or diverge from some or all of our interests.
We manage conflicts of interest through adequate controls, disclosure and avoidance. We also provide training to our employees to identify conflicts of interest and encourage the early reporting of potential conflicts of interest.
13. What is your duty of disclosure obligation?
In accordance with the Insurance Contracts Act 1984 (Cth) you have a duty of disclosure. For the full wording of your duty of disclosure, please refer to the Important Information section of the policy wording.
14. What arrangements do we have in place to compensate clients for losses?
We have a professional indemnity insurance policy (PI policy) in place which satisfies the requirements for compensation under section 912B of the Corporations Act 2001 (Cth).
The PI policy covers us for claims made against us as a result of our conduct or conduct by our employees (or former employees) in the provision of financial services.
15. What should you do if you have a complaint?
If you have any concerns or wish to make a complaint in relation to this Policy or our services, please let us know and we will attempt to resolve your concerns in accordance with our Internal Dispute Resolution procedure. Please contact Emergence in the first instance:
Postal Address: Emergence Complaints, GPO Box 327, Sydney, NSW, 2001
Phone: 1300 799 562
We will acknowledge receipt of your complaint in one (1) day and do our utmost to resolve the complaint to your satisfaction within ten (10) business days.
If we cannot resolve your complaint to your satisfaction, we will escalate your matter to Lloyd’s Australia who will determine whether it will be reviewed by their office or the Lloyd’s UK Complaints team. Lloyd’s contact details are:
Lloyd’s Australia Limited
Phone: +61 2 8298 0783
Postal Address: Suite 1603 Level 16, 1 Macquarie Place, Sydney NSW 2000
A final decision will be provided to you within thirty (30) calendar days of the date on which you first made the complaint unless an exception applies.
You may refer your complaint to the Australian Financial Complaints Authority (‘AFCA’), if your complaint is not resolved to your satisfaction within thirty (30) calendar days of the date on which you first made the complaint or at any time. AFCA can be contacted as follows:
Phone: 1800 931 678
Postal Address: GPO Box 3, Melbourne VIC 3001
Your complaint must be referred to AFCA within two (2) years of the final decision, unless AFCA considers special circumstances apply. If your complaint is not eligible for consideration by AFCA, you may be referred to the Financial Ombudsman Service (UK) or you can seek independent legal advice. You can also access any other external dispute resolution or other options that may be available to you.
16. More information
If you would like more information about us, please contact us by phone, in writing by email or in person.
This FSG was prepared on 29 September 2023
© Emergence Insurance Pty Ltd 2023