SCHEDULE 1 Code of Conduct and Customer Engagement 2015

SCHEDULE 1 Code of Conduct and Customer Engagement 2015 Nominal Insurer And Schedule 1 (Code of Conduct and Customer Engagement) Page: 1 of 14

Contents Overview... 3 1. Code of Conduct... 4 1.1 General... 4 1.2 Positive Work Environment... 4 1.3 Honesty and Integrity... 4 1.4 Professional Behaviour... 5 1.5 Confidentiality and Privacy... 5 1.6 Process and Adherence to the Schedule... 6 2. Customer Service... 7 2.1 Customer Engagement... 7 2.2 Customer Service Model... 8 3. Complaints Management... 10 3.2 WorkCover Independent Review Office (WIRO)... 10 3.3 Communication... 10 3.4 Reporting Framework... 11 4. Attachments... 12 5. Definitions... 13 Schedule 1 (Code of Conduct and Customer Engagement) Page: 2 of 14

Overview The purpose of this Schedule 1 (Code of Conduct and Customer Engagement) is to describe the engagement framework for the Scheme Agent. It consists of 3 components: 1. Code of Conduct 2. Customer Service 3. Complaint Management The Code of Conduct describes the core values to be adopted by the Scheme Agent when providing the Services. Both the Nominal Insurer and the Scheme Agent are required to ensure that all its Personnel comply with these values. The Scheme Agent must ensure this code is implemented within its Workers Compensation operations and that the Scheme Agent s Personnel comply with the code when providing the Services. A Customer Service Model will enable the Scheme Agent to comply with the requirements of this Deed and other applicable codes, guidelines and standards. The Nominal Insurer, in conjunction with the Scheme Agent, is committed to delivering high quality Services to customers, stakeholders and the NSW community. As an agent of the Nominal Insurer, the Scheme Agent is considered to be operating as an extension of the Nominal Insurer and is providing Services that reflect on the image and brand of both the Nominal Insurer and the NSW Government. This Schedule 1 (Code of Conduct and Customer Engagement) describes the conduct that is expected of the Scheme Agent under this Deed. The Scheme Agent must adopt a complaints management model, that has in place a 3 level, 4 step complaints handling model, that includes an initial contact point and escalated internal review options. Detailed standards and expectations including timeframes and escalation procedures are contained within Attachment 1.03 (Workers Compensation Complaints Standard) and Attachment 1.04 (Handling customer complaints A guide for scheme agents and insurers). Glossary Except as provided in Attachment 1.01 (SRWS customer service charter) to this Schedule 1 (Code of Conduct and Customer Engagement), capitalised terms used in this Schedule 1 (Code of Conduct and Customer Engagement) have the meaning set out in section 5 of this Schedule 1 (Code of Conduct and Customer Engagement) and in the Glossary. Schedule 1 (Code of Conduct and Customer Engagement) Page: 3 of 14

1. Code of Conduct 1.1 General The Scheme Agent s Personnel engaged in providing Services in relation to this Deed are expected to operate under the following core values of: (ii) (iii) (iv) (v) Integrity Trust Service Accountability Respect The Scheme Agent is required to reflect the requirements of this section 1 of Schedule 1 (Code of Conduct and Customer Engagement), and set out the principles and standards that underpin the delivery of Workers Compensation insurance services and achieve sustainable Return to Work, health and recovery outcomes. 1.2 Positive Work Environment The Scheme Agent must work with injured Workers, Personnel, Subcontractors, and all other providers to: (c) (d) (e) (f) (g) (h) Ensure Personnel have the skills and experience they need to provide quality and culturally sensitive services to injured Workers, Employers and Third Party Service Providers; Work in collaborative partnerships with stakeholders to identify needs and how they can be met; Handle all matters consistently, promptly and fairly in a non-discriminatory way, conform with natural justice and in accordance with Approved processes; Behave ethically and do not bully, discriminate against, harass, intimidate, victimise or vilify any person during the course of providing the Services; Treat every injured Worker fairly and with respect; Be open and accountable; Avoid any practice or activity which the Scheme Agent could reasonably foresee could bring the Nominal Insurer or WorkCover into disrepute; Sensitively manage any information collected; and Provide a timely response to injured Worker enquiries. 1.3 Honesty and Integrity The Scheme Agent must operate with honesty, due care and diligence by: Acting in good faith and for the benefit of the Nominal Insurer. Where this duty of fidelity and good faith conflicts with another duty of the Scheme Schedule 1 (Code of Conduct and Customer Engagement) Page: 4 of 14

(c) Agent or its commercial interests, then the interests of the Nominal Insurer should prevail; Advising the Nominal Insurer of any potential Conflicts as soon as possible after the potential Conflict is known; and Employing similar business ethics policies that reflect intent of those to which the Nominal Insurer adheres which include: (ii) 1.4 Professional Behaviour No solicitation of bribes, gifts and/or benefits or behaving in a manner that could be seen to represent this behaviour. This includes attending lunches, dinners, parties and sporting events as a guest of providers; and Not accepting receipt of a gift, favour or benefit in excess of a value of $100. The Scheme Agent must ensure its Personnel: (c) Present to work in a condition that renders them capable of safely carrying out their duties and responsibilities; Do not undertake any work, including driving work vehicles, if they are under the influence of any alcohol or drug (including prescription drugs) which could impact on their ability to properly complete their duties or pose a risk to themselves or others; and Ensure the reputation of the Nominal Insurer is not damaged or brought into disrepute by: (ii) Participating in, accessing or disseminating offensive or inappropriate material; Misrepresentation such as: (A) (B) (C) (D) 1.5 Confidentiality and Privacy Misrepresentation for any purpose which will reflect unfavourably upon the Nominal Insurer s reputation; Misrepresentation of identity including origination of messages. For example, spamming, spoofing or use of other identities akin to identity theft; Distributing unauthorised material in the workplace in support of any business other than that of the Nominal Insurer; and Illegal or unethical material breaching the objectives of this section 1 of Schedule 1 (Code of Conduct and Customer Engagement). The Scheme Agent must ensure its Personnel are aware of and adhere to the privacy and confidentiality requirements specified within the Deed. In particular, ensuring its Personnel: Schedule 1 (Code of Conduct and Customer Engagement) Page: 5 of 14

(c) (d) (e) Do not make any public comment on behalf of the Nominal Insurer without Approval. Public comment includes public speaking engagements, comments on radio, television and newspapers, books and social media; Do not make unauthorised disclosures. Unauthorised disclosures may cause harm to individuals, give an individual or department an improper advantage and may damage the credibility and integrity of the Nominal Insurer; Protect all Records and information in accordance with agreed policies and processes and will comply with obligations under this Deed; Ensure that Confidential Information in any form cannot be accessed by any other person and is only discussed with those who are authorised to have access to it; and Ensure access to information should only occur if it is relevant for the completion of duties. The Scheme Agent will ensure that Records are created and maintained to support what they do and ultimately justify their actions. The Scheme Agent will register any Records created in the Nominal Insurer management system and any changes/amendments will be completed transparently whilst maintaining the original document. All Records are to be managed in accordance with the Manuals. 1.6 Process and Adherence to the Schedule At all times the parties will work together to reach an outcome that addresses the injured Workers needs in a timely and efficient manner through regular and open communication. Issues in relation to non-compliance or under-performance with this Schedule 1 (Code of Conduct and Customer Engagement) will be managed in accordance with Schedule 5 (Performance Management and Remuneration). Schedule 1 (Code of Conduct and Customer Engagement) Page: 6 of 14

2. Customer Service This section supports communication processes between the Nominal Insurer, the Scheme Agent and the WorkCover Independent Review Office (WIRO). It provides a link between the Scheme Agent s policies and processes and the implementation of the new WorkCover customer feedback framework and Attachment 1.03 (Workers Compensation Complaints Standard). Its objective is to ensure the Scheme Agent is accountable for achieving high standards of customer service and ensuring that customer service and complaint handling processes are reliable and consistently performed across all areas of the NSW Workers Compensation Scheme. 2.1 Customer Engagement Customer engagement is intended to increase confidence and trust in customers interactions and support the health and wellbeing of all participants in the Workers Compensation system. It also provides an improved mechanism for the receipt and management of customer complaints. (c) In addition it outlines the requirements for the measurement of customer experience and satisfaction and the provision of data and reports to ensure service recovery opportunities are identified in support of a continuous improvement approach. An important aspect of customer engagement is to ensure the provision of equal access to Services for all members of the NSW community including those that require additional support due to disability or any other factor. It is vital that Scheme Agent Personnel in customer contact roles understand and are provided with appropriate training to uphold the principles of: (ii) (iii) (iv) Cultural Diversity; Equal Employment Opportunity (EEO); Ethical Practice; and Workplace Health and Safety (WH&S). Schedule 1 (Code of Conduct and Customer Engagement) Page: 7 of 14

(d) The Scheme Agent must ensure that adverse decisions or complaint outcomes are communicated to the customer with empathy and an approach that respects differences in cultural, socio-economic and religious backgrounds. This may include arranging a face-to-face meeting or speaking to the customer on the telephone prior to sending the information in a letter or email. Correspondence must be written in plain English with an interpretation or explanation of the legislation to ensure the information is clearly understood by the recipient. In addition, all customer service interactions are to be provided free from all forms of discrimination, bullying and harassment, and ensure respect and fairness to employees, stakeholders and the NSW community. 2.2 Customer Service Model The Scheme Agent is required to develop and implement a Customer Service Model and associated policies, procedures and processes that meet the requirements of the Nominal Insurer and the Australian Standard (10002; 2006 MOD) and the NSW Ombudsman s Guidelines. To meet the requirements noted above, the Scheme Agent must have in place a Customer Service Model that: (ii) (iii) (iv) Adheres to Attachment 1.01 (SRWS customer service charter), which depicts the standard of service that customers can expect, outlines details of key stakeholders and customers, provides information on how to lodge a complaint and includes service standards such as expected timeframes for response/resolution. Attachment 1.01 (SRWS customer service charter) will be reviewed and updated/amended accordingly at least every 2 Years from the date it was last issued; Offers customers a variety of options to contact the Scheme Agent including telephone, website, face-to-face and will clearly outline roles and responsibilities at each stage of a customer s interaction with the Scheme Agent; Is published on the Scheme Agent s website and provided to customers along with Attachment 1.02 (Fact Sheet How to make a complaint about your claim, insurer, premium or dispute decision), Attachment 1.03 (Workers Compensation Complaints Standard) and other relevant information at the commencement of a Policy or Claim; Adheres to the Code of Conduct and NSW Government guidelines that outline the standards of professionalism, behaviour and ethics expected of Personnel managing customer interactions and engaging/remunerating a service provider; Schedule 1 (Code of Conduct and Customer Engagement) Page: 8 of 14

(v) (vi) Ensures that frontline Personnel are suitably skilled and trained in the provision and principles of excellent customer service and managing customer interaction, including customers who present with challenging and/or complex behaviours, Attachment 1.05 (Managing complex customer behaviour policy). Frontline Personnel will clearly understand and be able to articulate customer service processes including requirements for escalating customer concerns. Personnel who are required to manage escalated complaints will attend suitable training programs that protect their own health and safety at work and provide a framework for effective complaints managements and the management of complex customer behaviour. All Personnel in customer facing roles will be required to attend ongoing professional development/accreditation as necessary to ensure currency of skills and approaches to effective customer service; Acknowledges that Personnel whose primary role involves customer service or complaint handling may, on occasion, be the recipient of abusive language, threats, intimidation or other complex, challenging or unreasonable conduct from customers. The Scheme Agent will have in place a process to support the health, safety and wellbeing of Personnel while at work that ensures the risk of customer behaviours impacting Personnel is identified and managed. Mechanisms to support this requirement could include the provision of counselling and debriefing services to Personnel who have been impacted; (vii) Allows for the periodic measurement of customer experience either through customer satisfaction surveys, any recorded feedback that is received via telephone calls to the contact centre or other agreed methods of measuring customer experience and satisfaction. A range of questions and measures may be used in the Scheme Agent's Customer Service Model but should specifically include questions relating to: (A) (B) (C) (D) (E) Knowledge and competency of Personnel; Fairness of process and treatment; Outcome: client received what they needed; Timeliness and access; and Extra mile: Personnel went the extra mile for client to receive what they needed; and (viii) Allows for continuous improvement - data is captured, trends are identified and quality control framework and improvement initiatives are in place. Schedule 1 (Code of Conduct and Customer Engagement) Page: 9 of 14

3. Complaints Management The Scheme Agent must have in place a 3 level, 4 step complaints handling model that includes an initial contact point and escalated internal review options. The model will: (ii) (iii) (iv) (v) (vi) Identify Level 1 complaint processes, roles and responsibilities; Identify Level 2 escalated complaints and internal review processes, roles and responsibilities; Include a process that details the complaint referral processes from the Nominal Insurer, and the 2 Business Day Service Standard for contacting the customer and establishing a resolution timeframe; Include a process for the referral of escalations to the Nominal Insurer or for independent review by the WorkCover Independent Review Office (WIRO), the WCC or other external review body (such as the NSW Ombudsman); Identifies data capture points and mechanisms; and Includes a process for notifying the Nominal Insurer when managing customers and protecting Personnel wellbeing when dealing with customers who are demonstrating complex, challenging, unreasonable or vexatious behaviour and any restrictions that have been applied to these customers to manage their behaviour and ongoing contact. Detailed standards of service and expectation including timeframes and escalation procedures are contained within Attachment 1.03 (Workers Compensation Complaints Standard) and Attachment 1.04 (Handling customer complaints A guide for scheme agents and insurers). 3.2 WorkCover Independent Review Office (WIRO) The Scheme Agent must ensure that Workers are made aware of the WorkCover Independent Review Office (WIRO), which provides an independent complaints solution service for Workers who are unhappy with a decision made by their Scheme Agent. WIRO also provides funding for legal advice. The Scheme Agent must advise Workers of the availability of this service. Contact information for WIRO is to be provided on the Scheme Agent s website including the contact number (ph 139476) and website address (www.wiro.nsw.gov.au). 3.3 Communication The Scheme Agent will endeavour to keep the connection and communication channels open and functioning between the Employer and the injured Worker (where reasonably practical). Where there is an issue, the Case Manager will advise the Employer that there will be no further communication and the reasons for ceasing communication. Schedule 1 (Code of Conduct and Customer Engagement) Page: 10 of 14

(c) (d) (e) As described in Schedule 3 (Claims) the Scheme Agent is accountable for communicating the outcome of a decision, dispute or review to customers. When communicating with customers, the basis for the decision should be referenced to legislation or the Scheme Agent policy, procedure or process. Information should also be provided on further assistance that may be sought in relation to medical costs and/or other financial support mechanisms (for example: Centrelink and Medicare). In addition, options for external review and dispute resolution should be provided (for example: WIRO, Merit Review, WCC). References to WorkCover in verbal or written correspondence must only occur when a decision has been made by WorkCover acting on behalf of the Nominal Insurer (for example: Merit Review). The Scheme Agent must immediately notify WorkCover of any changes to their Level 1 and Level 2 contact and escalation points to ensure that there is no delay or interruption to complaint investigations or reviews. Communication protocols are described in Schedule 5 (Performance Management and Remuneration). 3.4 Reporting Framework Reporting on complaints/business performance will be provided as part of the Quarterly review report as referred to in Schedule 6 (Governance) and must include the following elements: Advice to the Nominal Insurer of any customer complaints alleging: (A) (B) (C) (D) (E) Fraudulent activities. Maladministration or corruption. Bullying or serious harrassment. Serious threats to the Agency. Threats of media exposure. (ii) (iii) (iv) The implementation of restrictions or changes to restrictions to a customers access to the Scheme Agent. Reports on Level 1 (frontline) and Level 2 (escalated) complaints as described in Attachment 1.04 (Handling customer complaints A guide for the scheme agents and insurers). In addition to the Quarterly complaints/business report the Scheme Agent must develop and submit an annual report against key customer and business performance metrics by the end of the second week of February each Year. Reports must be submitted electronically in PDF, Excel or Word format, via email, to the Nominal Insurer within the timeframes stated in Attachment 6.05 (Reports Matrix) to Schedule 6 (Governance). Schedule 1 (Code of Conduct and Customer Engagement) Page: 11 of 14

4. Attachments Attachment 1.01 Attachment 1.02 Attachment 1.03 Attachment 1.04 Attachment 1.05 Safety, Return to Work & Support (SRWS) customer service charter Fact Sheet How to make a complaint about your claim, insurer, premium or dispute a decision Workers Compensation Complaints Standard Handling customer complaints A guide for scheme agents and insurers Managing complex customer behaviour policy Schedule 1 (Code of Conduct and Customer Engagement) Page: 12 of 14

5. Definitions Complaints and Complaint Levels Customer Care Hub (CCH) A complaint is defined as per the Australian Standard: Any expression of dissatisfaction made to an organisation related to its products, service, or the complaints handling process, where a response or resolution is explicitly or implicitly implied A Level 1 Complaint (also called frontline complaint) is a complaint that: Is acknowledged, and where possible, resolved at first or second (e.g.: follow up) contact with the complainant. Does not involve complex investigation. Is generally received and resolved by telephone. A Level 2 Complaint (also called escalated complaint) is a complaint that: Is commonly referred to as an escalated complaint. Is unable to be resolved at Level 1. Can be the result of a customer requesting the complaint be escalated or reviewed. Requires investigation, senior officer review/ approval (independent of the original decision maker); or subject matter expertise. Can be of a serious nature such as misconduct or illegal behaviour. Involves a review of a complaint resolution process and/or procedure; or outcome. Involves investigation which is more complex and exceeds 2 Business Days of total effort. Are complaints about service delivery or process. Contest a decision made by a Scheme Agent. The CCH is a team that forms part of the Customer Experience Team within the Customer Service Centre. The team is responsible for triage, investigation and working with the Scheme Agent or other business areas to resolve escalated complaints. Roles within the CCH: Customer Care Case Manager: A member of the CCH who is the initial contact for escalated complaint referrals. They gather information relating to the complaint investigate and review the circumstances. They may recommend the complaint be referred to a specialist area for further investigation or to an external independent Level 3 complaint organisation. Customer Care Business Partner: A senior member of the Customer Care hub whose role is to manage escalated complaints investigations and review the recommendations made by the Customer Care Case Managers. Schedule 1 (Code of Conduct and Customer Engagement) Page: 13 of 14

Customer Service Centre (CSC) Established in 2011 The Customer Service Centre (CSC) is responsible for customer management on behalf of WorkCover NSW and acts as the voice of the customer, leading policy and practice in Customer Service and complaints handling across WorkCover NSW. The CSC incorporates: Customer Contact Centre (formerly Information Centre). Customer Experience Group/Customer Care Hub (formerly CAS). Operations Group (Licence Solutions). Resource Planning and Service Level Management (new team). Note: For a detailed list of definitions refer to Attachment 1.04 (Handling customer complaints A guide for scheme agents and insurers). Schedule 1 (Code of Conduct and Customer Engagement) Page: 14 of 14