1. About This Document
SureInsure Pty Ltd (AFSL 525177) is committed to conducting its insurance broking business to the highest standards of professionalism, integrity and fairness. This document sets out how we adopt and apply the Insurance Brokers Code of Practice (the Code), developed and administered by the National Insurance Brokers Association of Australia (NIBA), across SureInsure and our network of Authorised Representatives.
The Code sets standards that often go beyond the minimum required by law, and is independently monitored by the Insurance Brokers Code Compliance Committee (IBCCC), with day-to-day code monitoring services provided by the Australian Financial Complaints Authority (AFCA).
Currency note: NIBA reviews the Code at least every three years. The 2022 Code remains in force at the time of writing, and NIBA has opened public consultation (8 July – 7 August 2026) on a revised Code addressing matters such as strata remuneration disclosure, a 28-day pre-renewal contact requirement, and expanded protections for clients experiencing vulnerability. SureInsure will update this document and internal procedures once the revised Code is finalised.
2. Why We Follow the Code
Clients engage SureInsure to help assess and manage risk, arrange and maintain appropriate insurance, and act as their advocate when a claim arises. Adopting the Code publicly commits us to:
- high standards of customer service;
- a free and transparent complaints and compliance review process; and
- compliance with any binding orders or sanctions imposed on us for a breach.
3. Scope of the Code
3.1 Who is covered
The Code applies to the general insurance and associated services SureInsure and our Authorised Representatives provide to clients — including advice, arranging and maintaining policies, claims assistance, and related services such as premium funding referrals and risk management support. It does not apply to reinsurance services.3.2 Who is protected
A client for the purposes of the Code is any person or business to whom we provide these covered services. It does not generally extend to insurers, other brokers, or intermediaries, except to the extent we provide covered services to them in connection with their own purchase of insurance.3.3 How the Code interacts with the law
The Code operates alongside — and does not limit — client rights under the Corporations Act 2001, the Insurance Contracts Act 1984, the ASIC Act 2001, the Competition and Consumer Act 2010, and the Privacy Act 1988. Where the Code sets a higher standard than the law requires, we meet it, provided doing so would not put us in breach of the law.4. Our Service Standards
The following twelve standards, drawn from the Code, describe what clients can expect from SureInsure and our Authorised Representatives.
1.Acting with honesty,careand skill
We carry out every engagement diligently, competently and with integrity, communicating with clients clearly and promptly. Where we provide personal advice, we identify each client’s objectives, financial situation and needs, make reasonable enquiries where information appears incomplete, and provide advice appropriate to those circumstances.
2. Managing conflicts of interest
We identify, assess and respond appropriately to any conflict between our interests and a client’s interests. Depending on the circumstances, this may involve disclosure to the client, reallocating the matter to another representative, or declining to act. Our conflicts arrangements are monitored, and any non-compliance is recorded and addressed.
3. Being clear about who we act for
Before or when we provide insurance services, we tell clients plainly whether we are acting as their agent or as agent for an insurer, and whether a wholesale broker is being used to place their cover.
4. Being clear about the scope of our service
We tell clients whether personal advice is being provided, whether that advice has been limited in scope, and what that limitation means for them.
5. Supporting clients through claims
Where we act for a client, we assist with lodging and progressing claims in their best interests, pass on insurer responses promptly, and help negotiate where a claim is disputed or declined. Where we act for an insurer rather than the client, we say so upfront.
6. Handling client money appropriately
Premiums and other client money are held in accordance with the Corporations Act 2001 and any relevant trust account obligations, and we will answer any question a client raises about how their money is handled.
7. Being upfront aboutremuneration
Before a client enters into a policy, we disclose any fee payable in addition to or instead of commission, and whether any commission or fee is retained if a policy is cancelled part-way through its term.
8. Maintainingcompetence and training
Representatives providing covered services receive adequate training, including on this Code and any other applicable code, with training records kept for at least five years and performance monitored so that gaps are identified and addressed.
9. Supporting clients experiencing vulnerability
We recognise that some clients — including those affected by catastrophic events such as fires, floods, cyclones or severe storms — may need additional support, and we respond to catastrophes and disasters in a timely, practical and compassionate way, in step with any industry-wide response.
10. Operatinga fair complaints process
We maintain an internal dispute resolution process that is free of charge, timely and transparent, acknowledges complaints promptly, considers only relevant information, and corrects errors as soon as they are identified.
11. Promoting the Code
We make information about this Code, including how to make a complaint, and about our services generally, readily available to clients.
12. Protecting the profession’s standing
We do not engage in conduct, or fail to act, in a way that is reasonably likely to bring the insurance broking profession into disrepute.
5. Complaints and Dispute Resolution
5.1 Making a complaint to us
If a client is dissatisfied with our service, they can raise it with SureInsure directly. We acknowledge complaints promptly, consider only relevant information, and aim to advise our proposed resolution within 21 days (or such longer period as is agreed, during which we keep the client updated), or within any shorter period required by law.
5.2 If a complaint remains unresolved
Where a complaint is not resolved to the client’s satisfaction, it is treated as a dispute and referred to our internal dispute resolution manager, who will investigate and respond in writing with clear reasons for the decision, generally within the same 21-day framework.
5.3 External review
If a client remains dissatisfied after our internal process, they may take the matter to the Australian Financial Complaints Authority (AFCA), which is free of charge to consumers and administers Code compliance monitoring on NIBA’s behalf. Details are available at afca.org.au or by phone on 1800 931 678.
5.4 Code Compliance Committee
Alleged breaches of the Code that are not resolved through conciliation may be referred to the independent Insurance Brokers Code Compliance Committee, which can make binding determinations and impose sanctions on Code Members — including requiring rectification, audits, corrective advertising, additional training, or publication of non-compliance. The Committee cannot impose monetary penalties.
6. Training and Competence
SureInsure maintains training and development plans for all Authorised Representatives and staff providing covered services, covering this Code and other applicable obligations. Training records are retained for at least five years and are available to the Code Administrator or Code Compliance Committee on request. Representative performance is monitored, with additional or remedial training provided where gaps are identified.
7. Supporting Clients Experiencing Vulnerability
We recognise that clients may face vulnerability for many reasons, including age, health, financial hardship, language barriers, or the impact of a catastrophe or disaster. Where this is reasonably apparent, our representatives are expected to respond with patience, flexibility and appropriate support — including allowing a client to nominate a support person or authorised representative to assist in their dealings with us.
8. Governance and Review
This document is owned by SureInsure’s compliance function and is reviewed at least annually, and whenever NIBA updates the Code, to ensure it continues to reflect current obligations. Questions about this document, or about how SureInsure applies the Code, can be directed to our compliance team.
9. Contact
SureInsure Pty Ltd — AFSL 525177 — ABN 11 642 332 698
For complaints, questions about this Code, or to request a copy of our internal dispute resolution procedure, please contact SureInsure’s compliance team through your usual SureInsure representative.