Code of Conduct

Overview
The Doctors’ Health Fund is proud of the reputation of its business and strives to maintain that reputation through conducting business, in a responsible and ethical manner.

Our employees and management are encouraged to maintain high ethical standards in their work and by acting within the letter and spirit of the laws that govern our business and the policies set down by the Fund. Their integrity, skill, care and diligence is vitally important to our reputation and, therefore; to our business and ultimately to you our clients.

All The Doctors’ Health Fund employees have a positive duty to know, understand and comply with company policy in relation to duty of care to clients and product knowledge. However, the most important rule is
they must never put The Doctors’ Health Fund ’s integrity at risk, nor act in any way that might give the appearance to they have acted in an improper manner.

The policies set out in this Code are intended to provide you with guidance on how the Fund conducts its day-to-day business.

Many of these policies reflect a judgment that there are certain business practices in which The Doctors’ Health Fund will not engage or otherwise condone. This is the case no matter how prevalent or common such practices may seem in the marketplace because such practices do not always reflect the best practices that we expect of ourselves or that our clients and members expect of us.

These policies are intended to ensure that The Doctors’ Health Fund’s reputation, and the trust our clients place in us, continue to be well-earned.

If you have any question about this document or compliance policies generally, you should contact the company.

Introduction
Coverage of this Code
This Code of Conduct applies to all employees of The Doctors’ Health Fund, including temporary and contract staff

Overview of the Australian Regulatory System
The Private Health Insurance Administration Council (PHIAC) is the primary regulator for the health funds industry in Australia under the auspices of the Department of Health and ultimately the Federal Minister responsible. The company must also comply with the Australian Securities & Investments Commission (ASIC) the corporate regulator. PHIAC regulates and overseas operation of the Fund under the legislation.

Amongst others the legislation encompasses: 

• Private Health Insurance Act (2007)
• ASIC administers certain important legislation, amongst others the legislation encompasses: 
  • Australian Securities & Investment Commission Act 2001 (ASIC Act) 
  • Insurance (Agents and Brokers) Act 1984 
  • Insurance Contracts Act 1984 
  • Superannuation (Resolution of Complaints) Act 1993
  • ASIC also exercises consumer protection related functions under additional legislation. ASIC has wide-ranging regulatory powers to take whatever action is necessary in the enactment of its statutory responsibilities

Responsibility

Employees
The Doctors’ Health Fund expects every employee (including persons engaged on a temporary or contract basis) to be individually responsible for exercising good judgement and applying high ethical standards to his or her work, and acting within both the letter and spirit of the laws and regulations that govern our business and the internal policies and procedures set down by The Doctors’ Health Fund.

Management
Consistent with The Doctors’ Health Fund governance arrangements management is responsible for ensuring that adequate systems of management control are in place. Each individual staff member is responsible for the effective day-to-day operation of the function under their control or for which they are responsible.

Risk Control
Independent risk control measures such as Key Risk Indicators, Compliance Checks, and Product Control are designed to assist management in establishing an efficient and effective control environment and a disciplined business operation.

These risk control measures are not, and are not intended to be, a substitute for effective managerial supervision of the business.

Whistle blowing
Every employee is responsible for alerting Management to actual or potential violations of laws, regulations and internal policies or procedures that come to his or her attention. There may be circumstances whereby fraud is being perpetrated in The Doctors’ Health Fund due to third party transactions or even within the organisation itself.

If any employee has reason to suspect that there are fraudulent activities/transactions taking place in The Doctors’ Health Fund, they are encouraged to report their suspicion to the Head of business for immediate attention.

The Head of business is accountable to the Board of Directors and responsible for ensuring the confidentiality of information received and the protection of the informants identity.

Authority

Corporate Authority
The operating entity is: The Doctors’ Health Fund Limited
The Doctors’ Health Fund is registered under the National Health Act.
The Dept. of Health empowers the Fund to conduct a full range of Health fund activities.

Delegated Authority
All staff, Directors and external contractors who perform duties in respect of dealing with or providing advice to clients or are responsible for making decisions about the ongoing operations of the business must be empowered to do so.

Privacy

Handling Private & Confidential Information
All employees have a duty to safeguard confidential information whether obtained from those with whom The Doctors’ Health Fund does business or from within The Doctors’ Health Fund. All such information can only be used for its intended purpose and not be used for any personal employee benefit or The Doctors’ Health Fund 's general benefit.

Confidential information should not be discussed with anyone outside the company (including immediate family) unless required by law.

Any breach of confidentiality will result in disciplinary action.

Information about The Doctors’ Health Fund and its Clients
Information about The Doctors’ Health Fund the company (or its employees) including, for example, its business activities, internal operations, financial condition and business plans, is confidential; unless publicly and officially disclosed.

Confidential information relating to our clients’ affairs remains confidential at all times.

Confidential information may include not only information received from a client but also information about a client’s identity and transactions, our internal credit assessment, or any other client information held by us.

Safeguarding Confidential Information
The company maintains strict adherence to the safeguarding of confidential information.

Conflicts of Interest
A conflict of interest arises in a situation where personal or professional interests of Directors and employees of The Doctors’ Health Fund Limited and /or the Fund either conflict, potentially conflict or could reasonably be perceived to conflict with the interests of and obligations to Fund members.

General Principles
As a matter of policy and where possible The Doctors’ Health Fund avoids all potential conflicts of interest and manages those conflicts to ensure fair treatment to all its members by disclosure.

Employees have a duty to ensure that the interests of The Doctors’ Health Fund are not unfairly placed above those of its members where a properly informed member would reasonably expect that The Doctors’ Health Fund would place the members’ interests above its own.

Responsibilities of Employees
Employees are expected to recognise and avoid or manage conflicts of interest. This means that they need to identify and deal with any conflicts of interest which may arise either between a member and the interests of The Doctors’ Health Fund or between two or more members.

They also must not put themselves in a position in which their personal interests, financial or otherwise, might influence or give the appearance of influencing any action taken, judgment made or advice given on behalf of The Doctors’ Health Fund.

When assessing the appropriateness of any advice given to, or transaction undertaken on behalf of a member, only the members interests are to be considered, and any interest or potential interest of The Doctors’ Health Fund, or of any other member, disregarded.

Product Information
All Policy documents and disclosure statements are where practicable full and complete. Documents where possible are written in plain language (English only) to promote better informed decisions about our private health insurance products and services.

Advice to Members
Where members seek advice on matters outside our authority to give such advice, no information that could be construed as giving advice will be discussed.

All requests for advice will be referred to the appropriate person or party authorised to handle such an enquiry.

Complaints/Dispute Resolution
All complaints, verbal or written, received by the company are registered. Details including nature of complaint, response of the Company to the complainant and action taken to remedy such a complaint is recorded.

Where a member is deemed in dispute with the Fund, details are escalated to senior management who will determine appropriate action(s) to achieve a resolution.

Acknowledgement a dispute exists will be communicated to the member within three working days where earlier resolution is not obtained.

Member will be kept informed of action(s) taken either verbally or in writing (at Fund’s discretion).

Where internal resolution is deemed unsuccessful or resolution has not been achieved within one month from date of complaint; reasons for outcome or delay in resolution will be conveyed to the member either verbally or in writing (at Fund’s discretion).

Should the member be dissatisfied with outcome or delay in resolution, the right to pursue resolution through the Private Health Insurance Ombudsman will be conveyed to them.