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If you need to use an interpreter in your interaction with us, please visit the following link, where information on and accessibility to such a service is provided: https://www.tisnational.gov.au/.

If you need to use teletypewriter services in your interaction with us, please visit the following link, where information on and accessibility to such services is provided: https://www.communications.gov.au/what-we-do/phone/services-people-disability/accesshub/national-relay-service. 

Other Policies

Our Modern Slavery Statement

To read our latest Marsh McLennan Modern Slavery Statement, please download a copy here.

Last Updated: August 2026

Our Modern Slavery Policy

To read our Marsh McLennan Modern Slavery Policy, please download a copy here.

Last Updated: October 2021

Product Development & Distribution Policy (Marsh)

1. Introduction

This Policy sets out the Marsh Pty Ltd (Marsh) approach to developing and distributing retail insurance products for its appropriate target markets where Marsh is acting on behalf of insurers. This Policy aims to support Marsh’s customer focussed approach by aiming to provide our customers with products that are consistent with their likely objectives, financial situations and needs.

To ensure our design and distribution obligations are met, our customers’ needs will remain at the centre of our product lifecycle including:

  1. The product design stage;
  2. The product delivery stage;
  3. The product review stage; and
  4. The product modification or decommission stage.

In further supporting this objective, Marsh will have in place Target Market Determinations (TMDs) which will guide the distribution of our products for appropriate target markets. These TMDs will be available on Marsh’s and/or the relevant insurer’s website for all relevant products from 5 October 2021.

2. Product Design

The first stage of a product’s lifecycle is the design stage. Marsh is committed to ensuring our products are designed so as to be consistent with the likely objectives, financial situations and needs of our customers for whom they are intended.

We recognise that we have a range of customers with different complex and multifaceted interests that should be considered in the development and design of our products.

When new products are developed or our current products are updated, we will start by assessing the likely objectives, financial situations and needs of the target market. This assessment may include:

  • market research and feedback to assist us in understanding the customers likely objectives;
  • needs analysis of internal and external data, industry data and other metrics; and
  • our own experience and expertise.
  • From 5 October 2021, TMDs will be available for retail products describing the type of customers comprising the target market for the insurance product.

3. Product Delivery

After a product has been appropriately designed, the product will be assessed to ensure that we identify the distribution channels and arrangements that are reasonably likely to result in our products reaching consumers in the target market.

We will take all reasonable steps to ensure our retail products are distributed in accordance with the TMDs including: assessing the most appropriate distribution channels for each individual product; setting distribution conditions that our distributors must follow including distribution in line with TMDs; obtaining information about the distribution from distributors; customer feedback and taking appropriate action in response; and adherence to our regulatory requirements.

4. Product Design and Delivery Review

Regular reviews will take place to ensure that our retail products are operating the way they were designed to operate and that they continue to meet our customers’ needs. Regular reviews are also important to ensure our products are distributed in a way that is likely to reach our designated target market.

Product reviews may include measuring complaints, customer feedback and other claims data and market conditions whilst also drawing on the experience of our own staff.

Commencing from 5 October 2021, product design and delivery reviews may also occur in response to TMD review triggers.

5. Product Modification or Decommission

Following a product review, it may be assessed that the product or its distribution channel require modification to ensure they remain consistent in achieving the likely objectives, financial situation and needs of our customers.

Our products may also require modification in response to regulatory changes. If following a review it is identified that a product is not delivering customer value and cannot be enhanced or distributed in a manner consistent with achieving the likely objectives, financial situation and needs of our customers, it may be decided that the product be decommissioned.

6. Review

This Policy has been developed by Marsh in conjunction with Marsh Legal, Compliance & Public Affairs team and will be reviewed on an annual basis or as required.

Date of next review: 1 July 2022

Marsh Product Development and Distribution Policy v.1.0.

Product Development & Distribution Policy (Victor)

1. Introduction

This Policy sets out the Victor Insurance Pty Ltd (Victor) approach to developing and distributing retail insurance products for its appropriate target markets. This Policy aims to support Victor’s customer focussed approach by aiming to provide our customers with products that are consistent with their likely objectives, financial situations and needs.

To ensure our design and distribution obligations are met, our customers’ needs will remain at the centre of our product lifecycle including:

  1. The product design stage;
  2. The product delivery stage;
  3. The product review stage; and
  4. The product modification or decommission stage.

In further supporting this objective, Victor will have in place Target Market Determinations (TMDs) which will guide the distribution of our products for appropriate target markets. These TMDs will be available on Victor’s and/or the insurer’s website for all relevant products from 5 October 2021.

2. Product Design

The first stage of a product’s lifecycle is the design stage. Victor is committed to designing our products to ensure they are consistent with the likely objectives, financial situations and needs of our customers for whom they are intended.

We recognise that we have a range of customers with different complex and multifaceted interests that should be considered in the development and design of our products.

When new products are developed or our current products are updated, we will start by assessing the likely objectives, financial situations and needs of the target market. This assessment may include:

  • market research and feedback to assist us in understanding the customers likely objectives;
  • needs analysis of internal and external data, industry data and other metrics; and
  • our own experience and expertise.

From 5 October 2021, TMDs will be available for retail products describing the type of customers comprising the target market for the insurance product.

3. Product Delivery

After a product has been appropriately designed, the product will be assessed to ensure that we identify the distribution channels and arrangements that are reasonably likely to result in our products reaching consumers in the target market.

We will take all reasonable steps to ensure our retail products are distributed in accordance with their TMDs including: assessing the most appropriate distribution channels for each individual product; setting distribution conditions that our distributors must follow including distribution in line with TMDs; obtaining information about the distribution from distributors; customer feedback and taking appropriate action in response; and adherence to our regulatory requirements.

4. Product Design and Delivery Review

Regular reviews will take place to ensure that our retail products are operating the way they were designed to operate and that they continue to meet our customers’ needs. Regular reviews are also important to ensure our products are distributed in a way that is likely to reach our designated target market.

Product reviews may include measuring complaints, customer feedback and other claims data and market conditions whilst also drawing on the experience of our own staff.

Commencing from 5 October 2021, product design and delivery reviews may also occur in response to TMD review triggers.

5. Product Modification or Decommission

Following a product review, it may be assessed that the product or its distribution channel require modification to ensure they remain consistent in achieving the likely objectives, financial situation and needs of our customers.

Our products may also require modification in response to regulatory changes. If following a review it is identified that a product is not delivering customer value and cannot be enhanced or distributed in a manner consistent with achieving the likely objectives, financial situation and needs of our customers, it may be decided that the product be decommissioned.

6. Review

This Policy has been developed by Victor in conjunction with Marsh Legal, Compliance & Public Affairs team and will be reviewed on an annual basis or as required.

Date of next review: 1 July 2022

Victor Insurance Pty Ltd (ABN 11 146 607 838) (“Victor”) arranges the insurance and is not the insurer. When arranging insurance products Victor acts under binding authority on behalf of various insurers, and not on behalf of policyholders directly. References to “We”, “Our” and “Us” refer to Victor.

Victor Insurance Product Development and Distribution Policy v.1.0.

Whistleblower Policy

Marsh’s Pacific Whistleblower Policy is designed to support colleagues, contractors and eligible persons to speak up and report concerns about misconduct, illegal activity, or breaches of Marsh policies, in line with applicable regulatory requirements across Pacific countries. It is an important part of good risk management and corporate governance because it helps protect people who raise concerns from retaliation, ensures disclosures are handled confidentially and appropriately, strengthens our culture of transparency and accountability, and helps deter wrongdoing by reinforcing our shared responsibility to comply with Marsh Code of Conduct ‘The Greater Good’.

Access the Marsh Pacific Whistleblower Policy.

Other notices

Code of Conduct: The Recovre Group Pty Ltd (ACN 003 330 167)

  1. Recovre is determined to meet high moral and ethical standards in all its business dealings and expects that all employees will be committed to meeting these standards. These standards are underpinned by our core values.
  2. The Code of Conduct applies to all employees and contractors employed by Recovre and all employees and contractors are provided with a copy on commencement of employment. Failure to comply with the Codes terms can result in disciplinary action, including dismissal.
  3. As part of the Marsh McLennan Group of companies, our employees are guided by the code of conduct known as ‘The Greater Good’. The Greater Good spells out our values as an organisation and obligations as individuals. A copy of our code of conduct can be obtained here: The Greater Good.

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Marsh Group entities operating in Australia, and providing financial services to clients, all hold an Australian Financial Services Licence (AFS Licence) and pride themselves on transparency and compensation disclosure. The Marsh Group is committed to maintaining the standards for ethical business practices and client service.

As our client, we will always look to treat you fairly and put your interests ahead of our own. We will disclose to you:

  • the role or roles we perform in an insurance transaction,
  • a list of the insurers we propose to approach  on your behalf and,
  • any equity interests we may have in those insurers.

In common with many financial organisations, we provide a range of services to a large number of clients. We also provide certain services to insurers. Situations may arise in which the interest of a client may conflict with those of another client or with our own interest. Accordingly, we have policies and procedures in place to ensure that should such circumstances arise, they are managed appropriately. You can contact us if you would like more information about how we manage conflicts of interest.

You can read further details about how we manage conflicts of interest in the Marsh and McLennan Companies Code of Conduct – The Greater Good.

We aim to be clear with you as to how we are paid. As part of that commitment, we have created a Compensation Guide for Australian Clients — a publication that summarises our commitments to our clients, describes the types of compensation we might receive, and supports our continued commitment to transparency and compliance.

In addition, we have established a toll-free "Ethics & Compliance" line at 1 800 98 8007, 24 hours a day, 7 days a week. Please use this number to submit any concerns or complaints you may have related to compensation paid or payable to Marsh by insurers or any other third parties.

Our Financial Services Guide contains important information about the services we can provide, our remuneration and is intended to assist clients in deciding to use our services.

Disclosure

Available here is information for clients and prospective clients regarding (1) equity interests of Marsh & McLennan Companies, Inc. and its subsidiaries in insurers and (2) contractual arrangements between Marsh & McLennan Companies, Inc. and its subsidiaries, on the one hand, and insurers and wholesalers, on the other.

Our Compensation

As an insurance broker, Marsh’s role is to place insurance coverage for our clients. We are compensated in a variety of ways, including commissions and fees paid by insurance companies and fees paid by clients. Marsh may receive compensation through one or a combination of the methods listed below.
Retail Commissions: A retail commission is paid to Marsh by the insurer as a percentage of the premium charged to the insured for the policy. The amount of commission may vary depending on a number of factors, including the type of insurance product sold and the insurer selected by the client. Retail commission rates can vary from transaction to transaction.

Client Fees: Some clients may agree to pay Marsh a fee for Marsh’s services in lieu of, or in addition to, retail commissions paid by insurance companies. The fee may be collected in whole or in part through the crediting of retail commissions collected by Marsh for the client's placements.

Insurer Consulting Compensation: Marsh receives compensation from insurers for providing consulting, data analytics or other services. The services are designed to improve the product offerings available to our clients, assist insurers in identifying new opportunities, and enhance insurers’ operational efficiency. The scope and nature of the services vary by insurer and by geography. In the US, Canada and Bermuda, this compensation can be paid in the form of a fixed fee, a percentage of premium, or a combination of both. Outside of those countries, Marsh is compensated for these services through fees.

Contingent Commissions: Some insurers agree to pay Marsh contingent commissions when we meet set goals for insurance policies placed with them during a given year or other time period. The set goals may include volume, profitability, retention and/or growth thresholds. The amount of contingent commission earned may vary depending on factors relating to an entire book of business over the course of the year or period. As a result, the amount of contingent commission attributable to any given insurance policy typically will not be known at the time of placement.

Compensation for Insurer Administration and Other Services: Marsh operates certain panels, facilities, quota shares, line slips and other placement arrangements with insurers. Marsh receives separate compensation relating to the creation, management, and operation of these arrangements that is in addition to any other fee or commission earned by Marsh.

Other Benefits or Compensation: Marsh may, from time to time, participate in insurance company promotional events or employee training and development provided by insurers. Sometimes, Marsh is reimbursed by insurers for its costs related to promotional marketing. Where legally permitted, Marsh earns interest and other income on premium accounts, as paid to us by the financial institutions where insurance premiums are held prior to remittance to insurers.

Our Contractual Arrangements with Insurers

Marsh has agreements with certain insurers pursuant to which Marsh provides services to them and for which Marsh is compensated to the extent permitted by law and regulation in each country in which Marsh operates. Examples include captive management services, claims administration services, claims management software and associated services, mergers and acquisitions due diligence services, insurer consulting services, managing general agent and managing general underwriter services and insurance brokerage services regarding insurers’ own insurance programs. Marsh is also party to agreements with insurers that facilitate insurance transactions, including agency agreements, agreements to administer facilities, and agreements to operate internet-based insurance placing facilities.

Marsh also routinely enters into various types of agreements with insurers that are ancillary to the insurance broking process, or other services performed on behalf of clients. Examples include confidentiality and nondisclosure agreements for the release of data relating to insurance placements, claims handling and loss control programs, nondisclosure and/or noncompetition agreements relating to the development and disclosure of new insurance products and services, and licensing agreements governing access to and use of data management systems and databases.

For more information on Marsh’s compensation or Marsh’s contractual arrangements with insurers, please contact your client executive or account representative.

Our commitments and how we are paid

Mercer Marsh Benefits (“MMB”) provides clients with a single source for managing the costs, people risks, and complexities of employee benefits. It is a collaboration between Mercer and Marsh companies, global leaders for innovative and reliable health and benefits advice strategic solutions, and brokerage services. In Australia Mercer Marsh Benefits is a business name of Marsh Pty Ltd (ABN 86 004 651 512), Australian Financial Services License 238983.

  • We take pride in our transparency and disclosure approach, and we make the following commitments when working for our clients:
  • We engage in ethical business practices
  • We define with our clients the terms of our engagement, including our role and responsibilities
  • We make available to our clients on request, and subject to local law and practices, our compensation from insurers and other third parties and our interests in the services we provide our clients
  • We manage conflicts of interest with integrity and are committed to treating clients honestly and fairly

Our commitments are applied throughout MMB globally, although how we are compensated, and the nature of our disclosure may differ according to the services we provide and in accordance with local law and practices.

This Global Transparency and Disclosure Statement summarises the types of compensation received across MMB globally. There may be countries that either do not receive certain of the compensation types noted below due to local practices or restrictions under local law and regulation. Accordingly, please consult your local MMB consultant for information related to a specific entity.

Broadly, MMB offers a wide range of services to its clients, with a variety of compensation arrangements with clients and insurers, including one or a combination of:

  1. Fee arrangements
  2. Commissions
  3. Insurer services revenue
  4. Other forms of compensation

1. Fee arrangements

Some clients may agree to pay a fee to MMB for the services it provides in lieu of, or in addition to, any commissions MMB agrees with insurance companies. Fee amounts will be agreed with clients and included in the contract for services entered into between MMB and client at the outset of the engagement.

2. Commissions

Broking commissions are agreed between MMB and insurers based on a percentage of the premium charged to the client for its insurance policy, less taxes and statutory charges. The commission is included in the premium charged and constitutes compensation to Marsh for arranging the insurance. Marsh retains the commission from the premium you pay Marsh and it then remits the balance to the insurer. The amount of commission may vary depending on a number of factors, including the type of insurance product sold and the insurer selected by the client, and commission rates may vary from transaction to transaction and change from time to time.

3. Alternative Commissions

MMB may receive different types of commission from insurers in addition to the broking commissions above as follows:

  • Additional Commissions: MMB may negotiate additional commissions with insurers for certain types of placements at the start of the year or a specific period, and they are fixed for the duration of that year/specific period.
  • Threshold Commissions:  in some countries MMB may also negotiate commissions (may be referred to as contingent or supplemental commission) at the start of the year or a specific period which are earned only when MMB meets an agreed threshold based on volume, retention, or growth of the relevant portfolio. MMB does not enter into any Profit-based threshold commission arrangements with insurers. In Australia threshold commissions are only agreed with an insurer if MMB binds the insurance policy on behalf of the insurer via a binding authority.
  • Scaled commission:  commission structured differently across time, i.e. the first year % of commission is typically higher (in lieu of business acquisition costs for the broker), and in subsequent years it drops to a lower level.

Additional information about MMB’s insurer commission arrangements are available to MMB clients on request to MMB.

4. Insurer services revenue

MMB receives compensation from insurers for specific portfolio-related services delivered by MMB (or MMB’s representatives), in some cases by dedicated teams.  These insurer relationships are documented in formal service agreements.  Depending on the services, MMB may receive fee-based compensation or compensation that is set as a percentage of premium.

MMB earns three types of compensation associated with the different forms of services provided to insurers as follows:

  • Insurer Consulting Compensation: MMB’s insurer consulting team may provide a range of consulting and data analytics services to insurers designed to improve the product offerings available to MMB policyholders, assist insurers in identifying opportunities, and enhance insurers’ operational efficiency.  Compensation for these services is by fixed fee only – MMB’s insurer consulting compensation arrangements do not include percentage-based compensation, discretionary components, bonuses or variable elements.
  • Insurance Solutions Compensation: MMB may create, manage and/or administer certain panels, portfolio facilities, quota shares, line slips and binding authorities and participating insurers may compensate MMB for the activities MMB carries out for or on their behalf by way of a fixed fee and/or on a percentage of premium basis.
  • Work Transfer Compensation: MMB may receive compensation from insurers for administrative work that MMB does for or on their behalf, including where MMB assists with policy servicing, claims, and placement execution (which is unrelated to the work MMB carries out as broker, and for the avoidance of doubt, MMB will not receive compensation twice for the same service).

Additional information about MMB’s insurer services compensation arrangements are available to MMB clients on request to MMB.

5. Other forms of compensation

MMB may also receive other forms of compensation including the following:

  • MMB may, from time to time, participate in insurer sponsored promotional events or employee training and development, and sometimes MMB is reimbursed by insurers for costs related to promotional marketing. Marsh’s representatives may also receive non-monetary benefits from insurers. This may include entertainment at sporting events, hospitality including lunches, training, and attendance at insurer sponsored functions. It is not possible to determine in advance what, if any, non-monetary benefit a representative may receive and these benefits are not generally attributed to any particular product or transaction. Marsh has compliance policies designed to mitigate the risk of these benefits creating a conflict with your interests.
  • Additionally, in the process of handling premium money we earn interest which MMB retains, and MMB may benefit from, investment income or foreign exchange rate differentials, although MMB can also incur losses from the same source.
  • MMB receive commissions and fees from the companies that provide premium finance facilities if MMB assists clients to obtain that premium finance.
  • In certain countries MMB may also enter into referral arrangements with third parties (including insurers) to refer clients to these third parties for their provision of products or services, and MMB may receive referral fees for this.
  • Distribution Brokerage – for placement of a general insurance policy in Australia where MMB is remunerated by fee from its client, it also collects from insurers a distribution brokerage of 2%, which is in addition to and will not be credited against any fee payable to MMB and will not be subject to any non-statutory cap on commissions payable to MMB.
  • Documentation Charges/Fee –  where commission or a fee is paid to MMB, we may also charge clients an administrative fee to cover administrative tasks that are performed in the insurance placement process, such as policy invoicing, premium collection and remittance.

6. Requesting details of how we are paid

Clients of MMB may obtain further details of how we are paid by making a request to their usual MMB contact.

How we are compensated and the level of information we can disclose may change according to the services we provide and in accordance with local law and practices.

7. Related Party Transactions

We and our subsidiaries or affiliates own shares in and have contracts with certain insurers and reinsurers. We also own or have interests in other insurance-related businesses that may provide services associated with a client's account.

Marsh has agreements with certain insurers pursuant to which Marsh provides services to them and for which Marsh is compensated (to the extent permitted by law and regulation) in each country in which Marsh operates. Examples include captive management services, claims administration services, claims management software and associated services, mergers and acquisitions due diligence services, insurer consulting services, managing general agent and managing general underwriter services and insurance brokerage services regarding insurers’ own insurance programs. Marsh is also party to agreements with insurers that facilitate insurance transactions, including agency agreements, agreements to administer facilities, and agreements to operate internet-based insurance placing facilities.

Risk Consulting Funding – in some instances Marsh arranges a pool of funding, which is made available by an insurer or scheme agent to a category of Marsh clients. With the client’s and the funder’s consent, Marsh may then apply the funding to pay for Marsh’s risk consulting services for the client. Marsh may allocate to itself a project management/administration fee of 10% of the pool as compensation for Marsh’s role in managing the pool and for associated administration services for clients.

Where Marsh or MMB is involved in arrangements whereby insurers pay it fees or brokerage, Marsh and MMB may be considered to have an incentive to place a broking client’s insurance with these insurers. In order to control any potential conflict of interest arising from the provision of services, Marsh employs and acts in accordance with its policies and procedures.

Marsh & McLennan Agency Pty Ltd (ABN 33 000 668 584) (‘MMA’) in Australia provides insurance products to third party brokers who utilise its services (including Marsh Pty Ltd and Marsh Advantage Insurance Pty Ltd) and it is remunerated by insurers who underwrite the insurance products provided via MMA.

Mercer is a global leader in talent, health, retirement, and investment consulting.

Guy Carpenter & Company Pty Ltd (ABN 95 000 351 299) and Marsh Resolutions Pty Ltd (ABN 19 055 301 721) are reinsurance brokers, and may place reinsurance for insurance companies that insure a client’s risk through Marsh.

If you have any questions about MMB’s transparency and disclosure commitments, or would like information on the compensation we receive, please do not hesitate to contact your MMB client contact.

Marsh McLennan is the leader in risk, strategy and people, helping clients navigate a dynamic environment through four global businesses. Marsh  GuyCarpenter  Mercer  OliverWyman

Target Market Determinations