Havensrock Excepted Group Life Assurance

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1 Havensrock Excepted Group Life Assurance Technical Guide 30 th July 2015 vs2.2 Havensrock Excepted Group Life Assurance - Technical Guide 1

2 Havensrock Technical Guide Welcome to our Technical Guide. This document will help explain the key features of our Life Assurance Policies for Excepted Benefits by clarifying our words and definitions. This technical guide needs to be read in conjunction with your individual policy schedule and quotation. Havensrock Excepted Group Life Assurance - Technical Guide 2

3 Contents 1 Glossary of Terms Havensrock Policies Your questions answered Setting up the policy What premiums are charged for cover? How does the policy accounting work? Cancellation Claims Are there any exclusions? Can cover be provided for a Principal Member who is not in the UK? Taxation on Excepted Group Life Insurance Schemes Further Information We have developed this technical guide based on the best practice format recommended by Group Risk Development (GRiD) and the Association of British Insurers (ABI) Havensrock Excepted Group Life Assurance - Technical Guide 3

4 1 Glossary of Terms Actively at work A Principal Member is working in their usual job, at their usual place of work. They cannot be working against medical advice. The Principal Member must be: Following their normal occupation, Working their usual number of contracted hours, and Working at their normal workplace, or at a location specified by their business. Anniversary date The annual anniversary of the start date of the policy - unless another date has been agreed with us. This date is stated in the policy schedule. Census data In order to provide a quotation we will require census data which will include: Profile of Principal Members to be insured (salary, date of birth, gender). Work locations and postcodes. Occupations. Dependant A person married to, or in civil partnership with, the Principal Member at the date of the Principal Member s death or The partner of the Principal Member who is in a relationship with the Principal Member, for more than 6 months, which resembles marriage or civil partnership and Is below State Pension Age. Cover for any Dependant is subject to limits highlighted on your quotation and policy schedule. Discretionary entrant A Principal Member that the employer wishes to insure, but who has joined outside the normal eligibility parameters agreed in the policy eligibility. In many cases these are early or late entrants to the policy. Eligible/Eligibility The factor(s) we consider when assessing whether or not a person can be covered by the policy. Havensrock Excepted Group Life Assurance - Technical Guide 4

5 Employer A company, partnership, limited liability partnership or other organisation that holds the contract of employment of the Principal Members. Event limit The total sum value of all claims you can make which are directly or indirectly attributable to one originating cause. If an event limit is imposed this will be shown and explained in your policy schedule. Excepted Group Life A group life policy as defined in section 480(3) of the income tax (trading and other income) act The seven conditions of an Excepted policy are: 1. The policy provides a capital sum on the event of a death for insured Principal Member up to the age of The policy must have benefits based on the same method of calculation. 3. The policy must not have a surrender value. 4. The policy is not permitted to provide benefits outside conditions 1 and 3 above. 5. Benefits from the policy can only be paid to an individual or charity. Benefits can be paid via a trust. 6. The policy cannot be used as a business protection arrangement. 7. Securing a tax advantage cannot be the main purpose of the policy. Free cover limit A threshold of benefit, as stated in your quotation and policy schedule, under which we do not require individual medical underwriting to provide insurance cover. Havensrock The trading name of a range of Life Assurance policies that are underwritten and provided by Scottish Friendly Assurance Society Limited and distributed by Punter Southall Health and Protection Limited. HMRC Her Majesty s Revenue and Customs who will grant registration of your scheme. Lifetime allowance The HMRC may impose a limit on life assurance benefits that can be payable tax-free. This is known as the lifetime allowance. This allowance may change from time to time as advised by the HMRC. Havensrock Excepted Group Life Assurance - Technical Guide 5

6 Long-term absentee A Principal Member who is not actively at work and has been continually absent from their normal occupation for three continuous months or more before your policy start date or anniversary date. Lump sum benefit The total lump sum of money that would be payable in the event of an accepted claim. Membership schedule This is the data provided to us which includes all the membership data we need to operate your policy. This data includes the full details of all Principal Members to be insured and the level of benefit required. This membership schedule needs to be updated monthly as long as the Havensrock policy is in force. Originating Cause A series of events or occurrences attributable to one originating cause. Partnership partner An equity partner of a partnership or an individual listed in the incorporation document of a Limited Liability Partnership (LLP) Policy Havensrock Life Assurance document that confirms the contract between the scheme Trustees and Havensrock. Details of the scheme benefits, the application, the policy schedule, policy costing, policy wording and all future declarations made are part of your contract. Policy schedule The current statement that details the specifics of your policy including your employer details, cover provided and any applicable endorsements. A new policy schedule is issued with each change or update to your policy. Policy termination age The age when a Principal Members cover ceases according to the policy schedule. Policy year The period between: Two anniversary dates or The start date and the first anniversary. Havensrock Excepted Group Life Assurance - Technical Guide 6

7 Pre-existing condition A medical condition that in the five years before cover was provided under your policy, the Principal Member or Dependant was: Aware of, Or suffered symptoms of, Or had been treated for. This includes conditions that are directly or indirectly linked to any other medical and/or related condition, or complication. Premium The cost of the insurance cover assessing the sum assured multiplied by the unit rate in force. The premiums may include additional costs for individual Principal Members who have had premiums loaded following medical underwriting. Principal members Individuals holding a current contract of employment with the employer that are within the policy eligibility. Rate guarantee date The specific date that you re quoted rates and terms are guaranteed to apply until unless there are material changes to the policy. The rate guarantee period is shown on your quotation. Scheme The arrangement between an employer or Trustees in respect of life assurance benefits promised. The scheme name is referred to in the policy schedule. Scheme rules The rules of your scheme which you need to abide by. Start date The date your policy starts, known as the commencement date in your policy schedule. Trustees The Trustees appointed to manage your scheme, as stated in your policy schedule. Underwriting information The details that help us assess the risk and therefore cost of providing you with cover. This will include, but is not limited to, the age, gender, benefit, state of health, medical history, occupations, places of employment (work postcodes) lifestyles and recreational activities of your Principal Members. Havensrock Excepted Group Life Assurance - Technical Guide 7

8 We/Us All references to we or us in the documentation refer to Scottish Friendly Assurance Society Limited. Havensrock Excepted Group Life Assurance - Technical Guide 8

9 2 Havensrock Policies 2.1 Our policies Are designed to provide you with appropriate life assurance cover to support promises made to your insured membership through an Excepted Group Life \Assurance policy. Are designed to be part of an effective Principal Member benefit solution. Are provided and underwritten by Scottish Friendly Assurance Society Limited. 2.2 Your commitment You will provide us with the following information throughout the lifetime of your Havensrock policy: The scheme s pension scheme tax reference (PSTR). Full monthly updates in respect of policy membership and benefits insured. Details of any discretionary entrants. Material changes to the employer or Trustees. Full information in respect of any claim. All TUPE or group employment transfers in plan or underway. You will honour your premium payments when requested. You agree to abide by the scheme rules and the terms and conditions of the policy. 2.3 Discretionary Trust Benefits payable upon the death of a Principal Member will be paid through a Discretionary Trust. The policyholder needs to check the correct Trust is in place. You should take regular professional advice to check that your Trust is set up correctly taking into account HMRC rules and limits that may change from time to time. 2.4 Dependant s Benefit It is important to note that the Dependant's Benefit payable to a working Principal Member is not written under a Discretionary Trust. In these circumstances the benefit is payable from Havensrock to the employer. It should be noted that the Dependant s Benefit would be paid to the Principal Member through payroll and this would typically be taxed as a salary payment. Havensrock Excepted Group Life Assurance - Technical Guide 9

10 2.5 Your risks You may not be covered if you do not comply with the terms and conditions of the policy or if you default on paying the premiums. You may not be adequately covered if you do not provide us with up-to-date membership data in respect of the Principal Members on a monthly basis. Accurate policy accounts will be provided at renewal and premiums will be based on actual cover in place during the insured period. Actual premiums due could vary if the total sum assured increases or decreases. Principal Members may not be covered or might have their benefit restricted, if you fail to submit the relevant underwriting information when your policy is set up or renewed. The rates used to calculate premiums are normally guaranteed for two or three years. However, if there is a change of 25% or more in the number of Principal Members or your total benefit insured or there is a change to legislation, regulation or taxation affecting the policy, then these rates may be affected which could change your future premium payments. Changes to the benefit basis, Principal Member eligibility criteria, the nature of your business or companies included within your scheme, may affect your premium rates. We may have to delay, or withhold, claims payments if you do not provide the information we ask for, at the right time. If this Excepted policy is linked in any way to another Group Life policy provided by us this policy would automatically cease if the linked group life policy ceased for any reason. Havensrock Excepted Group Life Assurance - Technical Guide 10

11 3 Your questions answered 3.1 How does our policy work? You, the employer, decide on the level of benefits you need. If the benefit (or multiple) insured varies between categories you must insure each category under a separate policy. You can choose whether to insure all of your Principal Members or just a group of them. You select the policy termination age. We will provide a quotation once we have all the underwriting information we need to assess your policy risk. You pay all of the premiums and the cost is usually treated for tax purposes as an allowable business expense. Premiums are not normally taxed as a benefit in kind for Principal Members. You provide us with monthly membership data. You provide us with the information we require to assess any claims. We will pay lump sum benefits as advised by the Trustees. The lump sum is normally taxfree. The Dependant s Benefit is not paid through an Excepted Trust. Payments are made directly from Havensrock to the employer who will pay this benefit to the Principal Member. 3.2 What factors should be considered when deciding what benefits to provide? Who can be covered? All Principal Members need to be specified by the employer within a clearly defined eligibility criteria and satisfy our actively at work conditions. Eligibility Eligibility conditions need to be made clear by the employer and should clearly confirm the following: Minimum and maximum entry ages. Any service qualifications or probation that may apply before cover commences. Categories of Principal Members to be covered, for instance any clarification around seniority or links to pension scheme membership or legacy promises. Date that new entrants can enter your scheme (for example, daily, monthly etc.). Havensrock Excepted Group Life Assurance - Technical Guide 11

12 Membership must be open to all your eligible Principal Members within a defined category or categories. Eligibility conditions covering entry ages, entry dates and waiting periods must be the same for each Principal Member within their defined category. Important Note Havensrock recommend that employers consult their advisers to ensure that their proposed policy arrangement and scheme set up does not breach the Equality Act Requirement to be actively at work To be covered under the policy, your Principal Members must be actively at work: Either from its start date. Or from their scheme eligibility date (if they joined the scheme after the start date). If the Principal Member isn t actively at work, we won t offer cover until that person has made a full and active return to their normal occupation for 20 consecutive working days. This period can be reduced if you provide our underwriters with medical evidence that is acceptable to us. Exceptions to actively at work We may at our discretion waive our actively at work conditions for any Principal Members of your schemes, as long as those Principal Members benefits were covered by another insurer immediately before the start of your policy and provided that there has been no break in cover, or increases in benefit level. We may also at our discretion waive our actively at work conditions for new Principal Members. Before we can consider waiving the actively at work conditions we need confirmation of any longterm absentees and also Principal Members who have historically been medically loaded, declined, restricted or postponed by your previous insurer. Where groups of Principal Members join the scheme as a result of a Transfer of Undertaking Protection and Employment Regulations (TUPE), we cannot waive our actively at work conditions for any Principal Members. Any changes to this rule would be subject to separate written confirmation. 3.3 What underwriting information should be provided before Principal Members are covered? Havensrock policies can include a free cover limit. This is a benefits threshold. If this threshold is exceeded we will require medical underwriting to be completed before any further cover can be considered. An individual s free cover limit depends on them fulfilling actively at work conditions and not being a discretionary entrant. A Discretionary entrant will not benefit from a free cover level. We will need full medical information before agreeing to provide any cover. Havensrock Excepted Group Life Assurance - Technical Guide 12

13 Once medical underwriting is completed to our satisfaction we let the Trustees know if additional premiums are required to obtain full cover, if a premium loading or exclusion applies or If no cover above the free cover is available. 3.4 What happens if a claim needs to be made before an underwriting decision has been finalised for that Principal Member? Havensrock provide temporary full benefit cover, excluding any pre-existing conditions, for up to 90 days or until our underwriting decision is made if earlier. Cover starts from the date of joining your scheme or from the effective date of an increase in benefits. Temporary full cover will be subject to a maximum of 1million of benefit insured above the free cover limit, or previously underwritten benefit - whichever is lower. It will not apply to Principal Members who have previously been: Postponed, Restricted, Declined, Rated, or Who have previously not provided full underwriting information. 3.5 When will cover stop? Havensrock cover will stop when the policy is cancelled, or if premiums are not paid within 30 days of the due date or when a Principal Member: Reaches your policy termination age. Dies. Leaves your company (including redundancy where there is no redundancy cover). Leaves your scheme. Or If an insured Partner ceases to be a partnership partner. If the HMRC regulations change to not allow Life Assurance provision through an Excepted Group Life Assurance policy. 3.6 What types of cover are available? Lump sum benefit Havensrock cover can either be for a fixed amount, or a multiple of salary. It is payable when a Principal Member dies. Havensrock Excepted Group Life Assurance - Technical Guide 13

14 Cover can vary from one category to another and providing reinsurance can be arranged, there is no limit to the level of cover Havensrock can insure. You should note that If the benefit (or multiple) insured varies between categories you must insure each category under a separate policy. Dependant s Benefit Your policy can also include a Dependant s Benefit that provides a payment to the Principal Member if their eligible dependant dies. Check your policy schedule for confirmation as to whether this cover applies and the maximum limits on this benefit. When is a Dependant s Benefit paid? Following assessment of a claim, we pay the benefit to your company and you pass it onto your Principal Member. The criteria for assessing claims include: Proof of death of your Principal Member s eligible dependant. Confirmation of Principal Member s eligibility for benefits. Confirmation that any claim made within the first 12 months of cover being in place for the insured Dependant is not in result of a pre-existing medical condition. Confirmation that the Principal Member had insurance in place at date of the Dependant s death. 3.7 Can cover be extended? Temporary absence Where a Principal Member is off work due to illness or injury, the cover can extend up to the policy termination age, providing your premiums continue and the Principal Member is still contractually employed. Where absence is due to any other reason, then Havensrock cover may continue for 36 months maximum. Any increases in benefit during this period will need to be in line with standard company pay awards and will be limited to a maximum of 5% per year. For existing schemes, temporary absence cover may be restricted in line with the scheme s rules. We need to be made aware of these rules when pricing your policy. Havensrock Excepted Group Life Assurance - Technical Guide 14

15 4 Setting up the policy We require the following underwriting information for all Principal Members before the policy starts: Gender. Date of birth. Salary. Benefit basis/level. Occupation. Location of normal place of work. Countries of residence (if outside the UK). We will also need full details of any: Long-term absentees (Principal Members who have been absent from work for 90 days or more at policy inception date). Previous underwriting decisions. Previous scheme history. Previous claims history. Material Facts (should you be aware of any Principal Member that has a life threatening condition irrespective of whether active at work or not this needs to be disclosed). If any of this information differs substantially from the details provided for the quotation, the quotation could be revised or withdrawn. To complete the policy set-up we need: Up to date underwriting information for all Principal Members or confirmation that membership details shown in the quote issued are correct. Fully completed Trustee Proposal Form and Scheme Details Form. Deposit premium, or direct debit mandate. Signed and dated scheme rules. Existing schemes that transfer cover to Havensrock may continue to use their existing trust and rules. Your Trustees are responsible for ensuring that the rules are updated to reflect future changes. Written confirmation from your previous Insurer confirming cover for any Principal Members over the free cover limit. Havensrock Excepted Group Life Assurance - Technical Guide 15

16 We agree to start cover whilst waiting for this information to be provided. We need all of it within 30 days from the start of cover. If we don t receive necessary information within this timeframe, we reserve the right to cancel cover and may not pay claims that are made whilst cover was being agreed. Monthly data All policies require a monthly Membership Schedule to be provided by you the employer. This includes notification of joiners, leavers and any changes to the underwriting information used to set up the policy. Havensrock Excepted Group Life Assurance - Technical Guide 16

17 5 What premiums are charged for cover? The way we calculate premiums depends on several factors, including: Level of Benefits Insured. Eligibility and entry conditions. Census Data provided Claims history if the scheme has been insured before. Information in respect of long-term absentees or other material facts disclosed. 5.1 How will premiums be calculated? Unit Rate Basis Your premiums will be calculated on a unit rate, shown per thousand of benefit insured. This is based upon the total benefits for Principal Members at the start date or anniversary date. Annual accounts At policy renewal accounts will be provided and any difference between premiums received and accurate cost of actual cover provided will be identified as a balancing premium. The balancing premium could lead to a premium refund or a further payment being due. 5.2 Will there be any unexpected extra premiums? Unit rates can be guaranteed for two or three years. A new unit rate may apply at the rate guarantee date. Premium loadings may be applied for any of your Principal Members who have been medically underwritten. Any loading will reflect their medical condition or hazardous pursuits they may undertake. An additional balance premium would be due if the cover required increased during the year. 5.3 Terms and conditions We reserve the right to change the terms and conditions at the rate guarantee date. 5.4 What commission is included within the premium? Any commission payable will be shown on the quotation issued. Havensrock Excepted Group Life Assurance - Technical Guide 17

18 6 How does the policy accounting work? Our policies and total premiums are based on daily calculations of cost of providing life cover to each Principal Member covered. Your premiums can be paid annually or monthly. At policy renewal accounts will be provided and any difference between premiums received and accurate cost of actual cover provided will be identified as a balancing premium. The balancing premium could lead to a premium refund or a further payment being due. Where premiums are not paid to us annually, we may charge an additional charge of each year to cover our extra administration costs. Any additional fee will be shown in your quotation. 6.1 What information do you need to provide? The employer must keep the Principal Member underwriting information accurate by providing monthly updates to us. If monthly membership data is not provided the policy may be cancelled. At renewal date, we will need confirmation that all long-term absentees have been disclosed in the monthly data. If not we need full long-term absentee data. 6.2 If the policy is cancelled mid-year, will premiums paid in advance be lost? No. We produce a final account based on the actual cover provided up to the date when you cancelled the policy. The appropriate premium adjustment is made. Havensrock Excepted Group Life Assurance - Technical Guide 18

19 7 Cancellation Your policy will be cancelled if you don t pay the premium within 30 days of its due date. We may reinstate cover if your premium is subsequently paid within a reasonable timeframe, subject to our requirements. There is no cooling off period, but you may cancel your policy at any time in accordance with the scheme rules. Cover for all benefits under the policy will stop on the agreed date and a premium will be due for the time you were covered. If any claims are made after cancellation of the policy this will be assessed by checking the following: At date of death the policy was in force. All premiums have been paid for cover in force. We cannot backdate cancellations. Havensrock Excepted Group Life Assurance - Technical Guide 19

20 8 Claims If you need to make a claim on your policy, you must give us written notice as soon as possible after your Principal Member s, or their Dependant s death. You must also provide us with all the documents and information that we need to process your claim. This may include: Completed claim form. Deceased Principal Member s original death certificate or Coroner s interim certificate. Copy of relevant authorisation showing who is empowered to sign for, and act on behalf of, the Trustees. Evidence of Membership and earnings. Principal Member s birth certificate. If your claim is for a Dependant s Benefit, we will also need original copies of: Dependant's original death certificate or Coroner s interim certificate. Marriage / civil partnership certificate where appropriate. Birth certificate for the Principal Member s Dependant. Confirmation the Principal Member had insurance in place at date of the Dependant s death. We may need evidence of the stability of their relationship too. This could include one or more of: Proof of joint mortgage. If there is a child - then the child birth certificate to show both parents names. Joint bank account. Joint insurances - e.g. building/contents or annual travel or life insurance. Pension schemes where the Dependant is the nominated beneficiary. If a Dependant s Benefit claim is made within the first 12 months of the Dependant being insured we will need to check that the cause of death was not linked to a pre-existing medical condition. To obtain this data we may need to approach the deceased dependant's GP / medical practitioner for medical evidence. We do not pay any claims notified to us more than 2 years after the Principal Member s death. Havensrock Excepted Group Life Assurance - Technical Guide 20

21 8.1 Who can payment be made to? We pay Lump sum benefits only as advised by the Trustees. Dependant s Benefits are paid to the employer. If you have any questions about making a claim, write to us at: Havensrock Insurance Scottish Friendly House 16 Blythswood Square Glasgow G2 4HJ You can also call us on or us at Calls may be monitored and/or recorded. Havensrock Excepted Group Life Assurance - Technical Guide 21

22 9 Are there any exclusions? All causes of death are covered under Havensrock policies. Policy limits Like most UK Life Assurance policies there are maximum limits that apply to claims: Event limit In extreme circumstances an Event Limit will be applied on the total amount of benefits payable for claims which are directly or indirectly attributable to one originating cause, irrespective of the period of time or geographical area over which the deaths occur. A series or sequence of causes which on the balance of probability result from persons acting in concert or in accordance with a plan or design shall be deemed to be one originating cause. Benefits will not be payable for claims arising directly or indirectly from one originating cause unless full postcode information has been provided and terms have been agreed. Any event limit applied to your policy will be detailed in our quotation. Travellers limit Where two or more members travel together by any means of transport the total sum assured will be restricted to a maximum of 35,000,000 Postcode limits There may be some postal locations where we would be unable to provide any cover for claims arising directly or indirectly from one originating clause and in such cases the Event Limit for those postal locations will be zero. Where there are changes to the postcode information for more than 5% of the members, or for members whose benefits equate to more than 5% of the total sum insured (or 10,000,000 if lower), the Event Limit will be set to zero for those members until we have confirmed such cover can be provided. Any postcode limits that apply will be shown on your quotation. Havensrock Excepted Group Life Assurance - Technical Guide 22

23 10 Can cover be provided for a Principal Member who is not in the UK? Potentially yes. But before cover can be accepted we would need the following data: Nationality. Confirmation of where employment contract is held. Location. Salary. Occupation. Travel Pattern. We will confirm any cover possible in writing. Principal Members and Dependants are expected to follow the British Foreign & Commonwealth Office s travel advice. Find out more at The tax treatment of any benefit paid out for an overseas Principal Member will depend on whether or not they have been treated as non-resident for tax purposes at any time when covered under the policy. Havensrock Excepted Group Life Assurance - Technical Guide 23

24 11 Taxation on Excepted Group Life Insurance Schemes An employer normally pays the whole premium for the policy. The benefit will be paid to the Trustees to enable the benefit to be paid in accordance with the terms of the discretionary trust. UK Trusts According to our understanding of legislation and HMRC practice (July 2011): Premiums paid by the employer are normally treated as a business expense. However, tax relief on premiums paid by the employer in respect of any employees who have a proprietary interest in the company will not normally be available. HMRC may, nevertheless, agree to such relief if similar benefits are provided for a substantial number of other employees. Premiums for partnership partners or Principal Members who are taxed on a self-employed basis will not normally be allowed as a business expense. Premiums will not be treated as a P11d benefit for Principal Employees. Lump sum benefits for Principal Members will not be subject to income tax and will not count towards the Principal Member's lifetime allowance. The Dependant s Benefit is not paid through a discretionary trust and therefore any payments made through the employer will be subject to tax in the normal way. All references to taxation are based on our understanding of current tax law and practices; if in doubt please contact a taxation specialist. Havensrock Excepted Group Life Assurance - Technical Guide 24

25 12 Further Information Third party rights Only Scottish Friendly and the Trustees have any rights under these policies. Any person or persons who are not party to these policies shall have no rights under the Contracts (Rights of Third Parties) Act 1999 to enforce any terms under this policy. Reference to, or the consent of, any person who is not a party to the policy is not required for any changes to it or its rescission. Compensation The Financial Services Compensation Scheme (FSCS) may cover your policy if Scottish Friendly becomes insolvent and we are unable to meet our obligations under the policy. For this type of policy, the FSCS will cover you for 90% of the total amount of an existing claim. The FSCS will also provide a refund of 90% of the premiums that have not been used to pay for cover whether you are making a claim under the policy or not. For further information, see or telephone Currency and jurisdiction The policies are issued in Scotland and will be subject to English Law. All payments made to or by us under this policy will be made in the currency of the United Kingdom. Havensrock and Scottish Friendly Havensrock is a marketing and distribution brand of Punter Southall Health and Protection Limited. All Havensrock Life Assurance policies are provided and underwritten by Scottish Friendly Assurance Society Limited If you have cause for complaint Havensrock and Scottish Friendly aim to provide a first class standard of service for our customers and to do everything we can to ensure you are satisfied. However, if you ever feel we have fallen short of this and you have cause to make a complaint, please let us know. Our contact details are: Havensrock Insurance Scottish Friendly House 16 Blythswood Square Glasgow G2 4HJ Telephone: Havensrock Excepted Group Life Assurance - Technical Guide 25

26 We have every reason to believe that you will be totally satisfied with your policy and with our service. It is very rare that matters cannot be resolved amicably. However, if you are still unhappy with the outcome after we have investigated it for you and feel that there is additional information that should be considered, you should let us have that information as soon as possible so that we can review it. If you disagree with our response or if we have not replied within eight weeks, you may be able to take your case to the Financial Ombudsman Service to investigate. Their contact details are: The Financial Ombudsman Service South Quay Plaza 183 Marsh Wall London E14 9SR Telephone: Website: Please note that the Financial Ombudsman Service will only consider your complaint if you have given us the opportunity to resolve the matter first. Making a complaint to the Ombudsman will not affect your legal rights. Havensrock Insurance Health UK Limited. Registered in England Number Havensrock Excepted Group Life Assurance - Technical Guide 26

27 Scottish Friendly Assurance Society Limited Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Member of AFM, Member of ABI: Life, Savings and Investments. Registered in Scotland No Head office: Scottish Friendly House, 16 Blythswood Square, Glasgow G2 4HJ.

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