Our approach to Product Governance

RSA has an established Product Governance Framework in place to design, approve, distribute, oversee, change, and withdraw products throughout the lifecycle to ensure they deliver good customer outcomes and meet regulatory requirements.

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What you'll find on this page

We made necessary enhancements to processes, systems, and controls to address the additional requirements that came into effect on 1 October 2021. 

An overview of our Framework and product review and approval process can be found below. If you have any questions, please contact your RSA Relationship Manager, or send an email to: prodgovdistribution@uk.rsagroup.com.

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Product Lifecycle

We have a Product Governance Framework in place to manage our products from identification through to closure. The Framework helps us meet requirements set out in the FCA Product Intervention and Product Governance Sourcebook Chapter 4 (PROD 4) and the Insurance Distribution Directive (IDD), where RSA is a product manufacturer of UK General Insurance products.

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Product Oversight

The FCA’s enhanced product governance rules have prompted us to clarify and confirm the apportionment of product governance roles and responsibilities between RSA and our partners. In accordance with FCA guidance, we have ‘grouped’ selected policy wordings that are intended to deliver similar cover and outcomes for customers where the intended target market is consistent. This means that we perform our reviews at an appropriate level to identify potential customer harm.

How our framework works

We use a set of questions to establish the inherent risk of our products, including consideration of a number of product risk factors, including target market, product type, and distribution method. The product risk rating informs our review schedule.

The product review and approval process is driven by questions that balance quantitative (e.g. metrics such as claims acceptance rate, claims complaints (as a % of claims), claims frequency, loss ratio, operations service) and qualitative information (e.g. processes and controls) to form our view on product value. These questions encompass product cover, utility, RSA service, and distribution, with further investigation and/or mitigating actions triggered by question responses, as appropriate.

Our ongoing Customer Outcome Monitoring also informs the timing of our reviews. When key metrics (e.g. claims or complaints) indicate potential – or actual – customer harm or poor value, we may accelerate the review for the impacted product(s).

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Partner Information Request

Where RSA is the sole or lead co-manufacturer of the product, we gather information from our distribution partners (including brokers) to complete our product reviews. To understand the impact of distribution on product value, we confirm services and distributor remuneration (including commissions, fees and charges, and any other remuneration) and seek confirmation that our partner’s remuneration is consistent with FCA regulatory obligations, including SYSC 19F.2. We may also need information on claims and complaints (where relevant) and evidence that the product has been/is being sold by appropriate methods to the identified target market. Distributors are required to provide this information to product manufacturers (if requested) in accordance with PROD 4.3.10B.

Product Review and Approval and Product Fair Value Assessment Reporting

Where RSA is the lead co-manufacturer, we share our approved Target Market Statement (see below) and product review and approval (including fair value assessment conclusion) output with relevant distribution partners. Where RSA is the follow co-manufacturer, we expect our distribution partners to share relevant outputs from their own product review and approval activities with us in a timely manner. We may also ask to review our partners’ product governance frameworks in some cases – where we delegate insurance underwriting authority, for example.

Target Market Statement

Where RSA is the sole manufacturer, we share our approved Target Market Statement with relevant distribution partners. This includes details of the intended target market, suitable distribution methods, and a summary of the RSA product fair value assessment outcome and conclusion.

The Target Market Statement for each of our products includes consideration of:

  • What customer need is met by the product
  • Who the product is designed for
  • Who the product is not designed to support
  • Whether the product be sold with or without advice
  • How the product should be sold.

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