Communications/Advertising (ICOBS 2.2)

When a firm communicates with a customer it must take reasonable steps to communicate in a way that is clear, fair and not misleading.

When considering how to comply, a firm should take into account the customer’s knowledge of the contract of insurance to which the information relates.

All types of communication with a customer are covered e.g., oral, telephone calls and written.

Prominence of relevant information can play a key role in ensuring communication is clear, fair and not misleading. A firm should:

a. use materials and design to present the information legibly, accessibly and in a balanced way. This includes use of paper size, colour and font;
b. use emphasis sparingly; and
c. not use different font sizes or positioning so that the impact of certain information (e.g., significant conditions, exclusions, scope of cover or charges) is likely to be materially less than other information.

Firms must ensure that any marketing communications are clearly identifiable as such.

Financial promotions are a form of marketing communication and are covered in section 3.2.