I've forgotten my password
Conduct Matters

Register for Updates

Enter your email address for the latest information from Conduct Matters.

About Me

40 years in insurance and 20 years specialising in conduct and customer service. Find out more about me. 

Contact Me

Thank you for visiting my website. If you want to find out more, please fill out the form on my contact page. 

The Portal

Learn more about the portal, how it can be accessed, used and how you can track the progress of your learners.

The Courses

See the courses I have designed and try a free taster. Courses cover a variety of insurance conduct topics.

Overseeing your service outsourcers

5th May 2020

Overseeing your service outsourcers

One of the most commonly asked questions I get is Ďhow should I oversee the conduct elements of my service outsourcers?í This is a great question and one I want to look at now for a moment. 

Whether they sell your policies or provide services, such as claims or complaints, you need to make sure there is a proportionate and effective way to oversee what your outsourcers are doing. You must be sure your customers are being treated fairly. 

You may have delegated authority to the outsourcer, but you still have regulatory responsibility should they fail to treat your customers fairly. Think of them less like a bolt-on and more of an extension of your own team. When it comes to customer care, we all have a role to play.

So, I thought it may be helpful to set out my thoughts on the essential elements of outsourcer conduct oversight. This is a topic I have designed a course on and itís an area that has many moving parts and careful considerations.

Before you even start, you must be clear about your expectations and make sure the outsourcer understands and agrees to meet them.

This is not just about how they operate in dealing with your customers but also the way in which they report to you. You cannot check they are doing what you agreed, if there is no evidence of what they are doing.

Management Information

The outsourcer should provide you with reports that allow you to see they are meeting the service standards you have agreed. You should be able to see historic data so you can track trends and see if there are any concerns.

These reports are a red flag telling you whether customers may not be being treated fairly. If this is the case, you can then drill down or speak to the outsourcer to see if you can find out what has happened and take action to resolve the matter.

Claims declinatures and complaints data tell you specifically where customers may not be happy. Drilling down into the cause of complaints is a great way to find out what your customers are telling you they want from you.


Itís tempting to leave a lot of the oversight work to the auditor Ė why bother to look at files or check your bordereaux when you can the auditor to do it? The FCA has expressed concern that many insurers do this so itís important to recognise that whilst audits are a crucial part of the oversight process. In essence, they should be designed to complement rather than replace your other oversight activity which takes place on an ongoing basis.

You must also be careful to make sure your audit scope is focused and actions are identified and tracked.

Frequency of conduct audits depends very much on the customers but if they are consumers, I would suggest you think about an annual audit Ė maybe each year can have a slightly different focus depending on what your oversight work tells you may need more attention.


I think visits are a great part of your conduct oversight. Nothing beats regular contact to chat through issues and really understand the operation. Itís a good time to look at some files, listen into a few calls and discuss management information.

If the outsourcer is handling a significant number of consumer or small business customers, then I would suggest a quarterly complaints liaison visit to discuss complaints information and the lessons to be learned.

File reviews

Donít wait for the auditor to look at files. You should have a regular review of files, whether complaints, claims, sales or service. Random checks are great, but you can also target certain files such as rejected claims or certain categories of complaints.

I hope this has helped you think about your outsourcer oversight. This topic is part of my outsourcer e-learning course. To learn more, take a look at the taster or go to my website for information about my courses and how to access this online training resource.

Author: Sally Pearce (Conduct Matters Ltd)

Sally Pearce started Conduct Matters in 2014 after 35 years working in the insurance industry. She was originally an underwriter, but since 2000 has worked in dispute resolution and helping Insurance firms understand how to treat their customers fairly. Her experience includes working for the Financial Ombudsman, in the Lloydís market and dealing with regulators. Sally is ACII, a qualified mediator and yoga teacher. She is also available for public speaking.

Powered by Conceptulise CMS