Purpose and scope

Commonwealth Insurance Limited (‘CIL’) is a wholly owned subsidiary of Commonwealth Bank of Australia (‘CBA’). CIL sells its general insurance products across retail and digital distribution channels within the CBA Group, including Bankwest.

The purpose of this document is to help you understand how CIL develops and distributes products. 

Our approach aims to reduce the risk of developing and distributing products that do not meet the needs, goals and financial situations of our customers.

If we don’t properly develop and distribute our products and services it can result in complaints and, at worse, result in financial loss to our customers and to us.

This approach applies to our employees and contractors who develop and distribute products for us and on our behalf.

Approach to product design and distribution

Development principles

Our products are designed for customers who own a domestic building, contents, portable contents or cars in Australia and want to protect themselves against the risk of financial loss or damage if an insured event occurs. 

When we develop and distribute our products, we will:

  • Meet customer and business objectives;
  • Comply with the CBA Code of Conduct including our living up to our values and applying the ‘Should We?’ test; 
  • Comply with applicable laws, industry codes and regulations;
  • Consider our customers’ circumstances, including financial literacy, potential vulnerabilities and accessibility, and
  • Manage change in a way that makes sure we consider our customer outcomes.

Distribution principles

The distribution of our products is subject to the following conditions and restrictions:

  • CBA Group staff who distribute our products must meet minimum qualification requirements and have the appropriate training to discuss the features and benefits of our products with customers;
  • Our products can only be distributed through the CBA Group’s proprietary channels (e.g. in branch; online; over the phone) which we believe are appropriate to reach customers; 
  • Our policy acceptance criteria is built into each of our distribution channels, and in case any customer experiences vulnerability, they will be referred to the underwriter for manual review; and
  • We must have oversight of how the product is promoted and issued.

Product monitoring and governance principles

Our products are subject to ongoing management, monitoring, assurance and governance to ensure they remain appropriate for our customers. We capture all potential risks, implement controls to prevent risks from occurring, and regularly test controls so that any identified issues or incidents can be appropriately rectified. We must ensure that:

  • Our products are regularly reviewed to confirm they are appropriately targeted to meet customer and business objectives;
  • Distributors and their associated arrangements are regularly reviewed to ensure they meeting their distribution responsibilities, together with customer and business objectives; and
  • Where products fall short of customer and business objectives, or concerns about the products’ distribution are identified, then change is implemented in an efficient manner. Where the outcome of a product review is to close the product, the reason must be communicated and clearly documented. The impact on customer financial wellbeing must be considered, ensuring we meet their needs and interests. we must meet all obligations to customers in relation to the product to be closed;

For further information on our product please see our Home or Car Insurance information booklet (PDF) for a list of the insured events, the additional benefits, and optional covers which vary based on what cover you choose. Alternatively, for the full terms and conditions please see our Home or Car Insurance Product Disclosure Statement