The purpose of a Target Market and Fair Value Statement is to explain the identified target market and the expected distribution strategy for each AXA Commerical Insurance product manufactured by AXA Insurance.
It also outlines our approach to Product Oversight and Governance to demonstrate how we design, monitor and review our products to ensure they continue to provide fair value and meet the needs, characteristics and objectives of the target market including vulnerable customers.
Product Oversight and Governance
AXA UK’s Product Governance Policy sets out the standards that AXA Commercial is required to implement to ensure the achievement of fair value and good customer outcomes by having robust product oversight and governance arrangements, systems, policies and procedures in place, which encourage a business culture with customers’ interests at its core.
We identify, define and assess our target markets at an appropriate level, based on the nature and complexity of our products.
We undertake appropriate testing of our new products before launch, to make sure they meet our customers’ needs and provide fair value.
The design and performance of all our new, existing and legacy products are subject to regular assessment and review to ensure products provide fair value and that there is a continuing customer-centric focus, achieving good customer outcomes.
The features, nature and complexity of our products are carefully matched to our intended distribution channels to ensure they reach our identified target market.
These requirements are in place in order to ensure that all AXA UK customers receive fair value and that good customer outcomes are delivered in line with AXA UK’s defined customer outcome statements.
Why is AXA Commercial asking for this information?
AXA Commercial wrote to its broker community in October 2021 to let them know about the steps we are taking to oversee our products, so that we can ensure they deliver fair value for customers. We also outlined the part our broker partners must play, by providing information to enable us to complete our annual Fair Value Assessments, as required by the FCA's enhanced rules which came into force on 1 October last year.
Will brokers receive the same questionnaire to complete from AXA Health and AXA Retail?
Brokers who have a relationship with AXA Health and AXA Retail will receive a separate questionnaire from them.
Is there one standard questionnaire that insurers could use, so that there is consistency across the industry?
Some trade bodies have collaborated to create a template. We are not using this template because it did not meet all of our information needs. AXA Commercial has reconciled this against our own approach and where appropriate we have tried to align our own assessment with this template.
How can brokers be expected to know the full distribution chain's remuneration/fees and activities?
As the product manufacturer, we need to ensure we have a full view of the services provided across the chain, and the cost of these to the end customer. It is important that as part of this we understand how fees contribute to the end price, so that we can assess if our product delivers fair value, as required by the FCA's rules. Brokers have their own responsibilities as distributors to understand the value of the chains they use to sell the product.
Can brokers request an extension to the submission request?
If you require an extension please contact your AXA Commercial Relationship Manager. Your Relationship Manager will document the late submission reason and revised submission date, this is so we can pause on sending out any reminders. In order for AXA Commercial to complete its internal assessments we would appreciate where possible brokers keeping to the original submission date but understand there could be extenuating circumstances preventing you from doing this.
AXA Commercial manufactures the product, so why do brokers have to complete this?
AXA Commercial needs a clear understanding of the distribution process. The broker partners who we have a direct relationship with are required to provide information about services, remuneration, controls, and information about any other parties in the distribution chain. It's important that product manufacturers and distributors work together to ensure that customers receive fair value from the goods and services they purchase and achieve the right outcomes at every point of their journey, regardless of who they're interacting with.
What response will brokers receive from AXA Commercial following completion of the questionnaire and when?
Once we have received a response, AXA Commercial will review this and let the broker know if there are any further questions, or any next steps.
The information AXA Commercial has requested from brokers is commercially sensitive and so cannot be provided, why is this needed?
AXA Commercial must ensure that our products are delivering fair value to end customers. This means working closely with all of our broker partners and obtaining more information from them than we have previously, about the remuneration they receive and what they do for customers in return for this. The information we have requested is in line with the requirements set out by the FCA in their PROD rules. This does not require insurers to obtain details of any separate commercial agreements between distributors and other firms, which are paid by the distributor (rather than being included separately in the premium) or a breakdown of the distributor’s costs or profit margins.
Why do brokers have to complete a questionnaire for every AXA Commercial product they distribute?
AXA Commercial's assessment approach is being conducted at product level in line with the FCA's PROD rules and guidance contained for manufacturers and distributors. We appreciate that there might be some duplication in the information across the products sold by a broker however, in order for us to complete the fair value assessment it's important that responses are product specific.
What happens if brokers fail to respond?
Where a broker does not respond, their Relationship Manager will reach out to try and understand the reasons why and offer guidance and support to enable completion of the questionnaire. It's important AXA Commercial understands the role each broker plays in distributing the product as that information forms an integral part in helping us to complete our fair value assessment.
Should brokers include information relating to the distribution of Ageas products within the questionnaire response?
For this 2022 assessment, the information we are asking for relates only to the AXA Commercial products each broker distributes or services.
When will AXA Commercial share information relating to its product fair value assessments with us?
We know that our broker partners need to understand the value of our products, the target market, and how this impacts their distribution strategies. A lot of this information is already included in the Target Market Statements for our products, which can be accessed at the top of this webpage. If AXA Commercial make any changes to a product based on the outcome of our fair value assessment, we will notify brokers and our Target Market Statements will be updated to reflect these.
What do I do if the questionnaire link doesn’t work?
We apologise that you’re having problems accessing the questionnaire. Please contact your AXA Commercial Relationship Manager in this first instance where we will try and resolve any issues you appear to be having.
