Okay. And was that – was that an appropriate way to incentivise your sales agents, Mr Howden?Ms Orr, when you’re running a call centre you need to have incentives to keep the staff motivated. The intent was to keep the staff motivated. And you accept that this incentive campaign was a contributing factor ?I do accept that. to the ?I do accept that. misconduct that led to the in funeral insurance sales to Aboriginal and Torres Strait Islander people in 2015?Correct. This sales incentive program coincided with the introduction of the refer a friend campaign, didn’t it?We always had a refer a friend campaign. But during this time, that campaign was abused. I did send a correction – correction to the original statement. I just want to understand that, because – I will tender this document before I turn to another, Commissioner. THE COMMISSIONER: Vespa sales battle rounds 1 and 2, SAF.0004.0001.0236, exhibit 4.181. EXHIBIT #4.181 VESPA SALES BATTLE ROUNDS 1 AND 2 (SAF.0004.0001.0236) MS ORR: Could I ask that you go back to the internal file note about the investigation again, SAF.0004.0001.0220. And I will ask that you be shown 0221 and paragraph 8: Select advised that two incentive arrangements, being a boat cruise incentive for the second quarter of 2016 and a Vespa prize that coincided with the introduction of the refer a friend campaign (offering gift vouchers to customers) were contributing factors to the spike. Now, is that correct? Were these incentive programs introduced at a time that coincided with the introduction of the refer a friend campaign?No. The refer a friend campaign we’ve always had. Yesterday you showed an exhibit The flyer?The flyer. The refer a friend flyer?Correct. But what happened at this time coincided with these incentives, but certain agents chose to abuse that refer a friend program.
And the wild cards were selected on a number of bases, including ongoing promotion of the incentive. What was that referable to?It’s to make sure that the incentive is still promoted in the call centre and everyone is aware of the existence of that incentive. Of this particular incentive program ?Correct. I see. And then at 0250 we see a heading What Can Hinder Your Chances? Points would only be docked for sales in which commission was clawed back due to one of five specified breaches. Is that right?That’s correct. And these breaches were all quite serious breaches, but they by no means covered the field in relation to serious breaches about which Select would be concerned?They would account for the majority of incidents that you would have on a call. The majority of incidents. So they are ?Analyse the incidents on the these would account for the majority. The main problems, are they?When are detected. And the first is not recording the call?Yes, but Is that what that is?That’s correct. The second is not giving the general advice warning?But often – incidents occur in pairs. So the general advice warning and this call is recorded are both contained in the same statement. Yes?So invariably you could get two in the same. And omission of any exclusion. So that’s a failure to tell the potential customer about an exclusion from the policy?Or incorrectly describe a feature. A failure to obtain a clear yes to start the policy?That’s correct. And And a failure to obtain a direct debit authority?Correct. And in that instance, if any of those things happened, they would be deducted two points ?That’s correct. for incident. So this is an example of promotional sales incentive material that did refer to some consequences for what you would describe as a non-compliant sale. Is that right?Correct. But if you see the timing of this, it coincided also with an overlap with the Vespa. So you can see the deduction for two points was articulated in this presentation. Yes?It did coincide also with the Vespa.
You would get a file note?Correct. And if you got 10 points in six weeks, you got a formal warning?Correct. And if you got 20 points in six you would get a second formal warning?Correct. And if you got 30 points in six weeks, you would be dismissed?You have lost your licence, yes. And does that result in dismissal ?Once you lost your licence you’re dismissed. So if we look also at the compliance disciplinary under that, we see how points were attributed to certain offences. Do you see that?Yes, I do. And perhaps if we could – that’s a table that continues onto the second page. So perhaps if we could have blown up both parts of that table. We see that prompting a customer to say “yes” – do you see that in the lighter grey portion, third from the bottom. Prompting a customer to say “yes” ?Yes. Attracted three points?I see that, yes. And customers not give a clear yes to a start a policy attracted five points?Correct. And failing to explain key exclusions also attracted five points?Correct. And applying pressure selling tactics attracted seven points?I see that. And if you made misrepresentations or provided misleading information, that was 10 points?Correct. If you completed an unethical sale, that was also 10 points?Correct. And if you provided personal advice, which would be a contravention of the Corporations Act, wouldn’t it?Yes, it would be. Yes. So if you did that, you also got 10 points?Correct. So you had another 20 points to live with until you made it through for the rest of the six weeks when all of your points would be returned?But you’re taking it out of context. You’re taking one example. But it doesn’t mean we don’t listen to further calls for that agent. So it doesn’t take six weeks for us to realise that there’s a problem. We would automatically give feedback to that agent and we would listen to all calls for that agent. So if we listen to additional calls and we found more repeats
Index of Witness Events RUSSELL HUGH HOWDEN, ON FORMER OATH P-3923 CROSS-EXAMINATION BY MS ORR P-3923 THE WITNESS WITHDREW P-3986 THY DO, AFFIRMED P-3986 EXAMINATION-IN-CHIEF BY MS ORR P-3986 CROSS-EXAMINATION BY MS WILLIAMS P-4007 THE WITNESS WITHDREW P-4011 PHILIP STEWART BOWDEN, SWORN P-4012 BY MR COSTELLO P-4012 THE WITNESS WITHDREW P-4021 TONY COLIN TAPSALL, AFFIRMED P-4021 EXAMINATION-IN-CHIEF BY MS WILLIAMS P-4021 THE WITNESS WITHDREW P-4050 Index of Exhibits and MFIs EXHIBIT #4.180 BLUEINC QUARTERLY AWARDS 2015 TO DATE (SAF.0005.0001.0125) P-3926 EXHIBIT #4.181 VESPA SALES BATTLE ROUNDS 1 AND 2 (SAF.0004.0001.0236) P-3929 EXHIBIT #4.182 LET’S INSURE SAILORS SALE INCENTIVE FEBRUARY TO JUNE 2015 (SAF.0004.0001.0238) P-3932 EXHIBIT #4.183 SELECT AFSL COMPLIANCE TRAINING MANUAL 2015 (SAF.0009.0001.0057) P-3934 EXHIBIT #4.184 LET’S INSURE FIRST QUARTER 2016 INCENTIVES (SAF.0005.0001.0109) P-3936 EXHIBIT #4.185 LET’S INSURE PRODUCT SCRIPT 25/08/2015 TO 25/09/2015 (ASIC.0025.0003.1212) P-3946 EXHIBIT #4.186 EMAIL ASIC TO SELECT DATED 09/01/2018 (ASIC.0025.0003.3248) P-3955 EXHIBIT #4.187 ST ANDREWS RISK MANAGEMENT COMMITTEE MEETING PAPERS DATED 28/03/2018 (BOQ.0001.0112.0092) P-3966
EXHIBIT #4.205 SUPPLEMENTARY STATEMENT OF MR TAPSALL DATED 04/07/2018 P-4024 EXHIBIT #4.2016 BRANCH OPTIONS RECOMMENDATION (ANZ.700.008.0060) P-4031 EXHIBIT #4.207 ACCELERATED BRANCH CLOSURES PRESENTATION DATED 26/04/2017 (ANZ.700.008.0002) P-4034