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COMPLAINTs & Code of Conduct

Complaint Handling Protocol

Whistleblower Policy

Code of Business Conduct

Complaint Handling Protocol

Nova Mutual is committed to providing excellent service to our members. However, we recognize that from time to time, members may have a concern regarding an action, service, or product of Nova Mutual or one of our authorized agents. When that happens, we welcome the opportunity to address any dissatisfaction by conducting a fair and timely review.

A concern can often be resolved quickest by speaking with the right insurance specialist.

If your concern is regarding your Insurance Policy (premiums, coverages, and payment), we encourage you to reach out directly to your Broker or Agent.
For concerns regarding an Insurance Claim, reach out to your Claims Adjuster.

If your concern is regarding something else, you do not know the right person to contact, or would like to escalate to a department manager, call our office at 1-833-829-6682 where we will be happy to direct you to someone who can help.

Complaint Handling Protocol

When an issue remains unresolved after reasonable consultation with the appropriate department, members will be referred to Nova Mutual’s Complaint Handling Protocol. This does not apply to any situation where a member has engaged legal representation.

To file a complaint, please provide key details in writing to our Complaints Officer:

Ken Worsley, Complaints Officer
Nova Mutual Insurance Company
35 Talbot St E, Jarvis, ON N0A 1J0
ombudsman@novamutual.com

To facilitate the process, we recommend including the following information:

Name and address
Claim and/or policy number
Phone number where you can be contacted during regular business hours
A summary of the complaint, including a list of unresolved concerns, key dates, and any supporting documents
Names of Nova Mutual employees you have dealt with
A description of your expectations and desired outcome

Within two (2) business days, you will receive a call from Nova Mutual’s Complaint Officer where they will explain their role and review the details of your complaint. This call will be followed by a written acknowledgement of the complaint by the Complaints Officer.

The Complaints Officer will then conduct an investigation by reviewing your file and consulting with the appropriate staff. After their review, the Complaints Officer will work with you to resolve your complaint or provide a Final Position Letter from the company within sixty (60) days.

Financial Services Regulatory Authority of Ontario (FSRA)

When the Complaints Officer has issued a Final Position Letter, your file will be closed. If you remain dissatisfied with the company’s handling of your complaint, you may contact the Complaints and Risk Assessment Branch of the Financial Services Regulatory Authority of Ontario. Complete their Complaint Form and provide a copy of the Final Position Letter via fax, mail, or e-mail.

Financial Services Regulatory Authority of Ontario
Complaints and Risk Assessment Branch
25 Sheppard Avenue West, Suite 100
Toronto, ON M2N 6S6
Telephone: (416) 250-7250
Toll Free: 1-800-668-0128
Fax: (416) 590-8480
TTY: 1-800-387-0584
Email: contactcentre@fsrao.ca

For more details on submitting a complaint to FSRA, visit their website at: https://www.fsrao.ca/submit-complaint-fsra

Whistleblower Policy

At Nova Mutual We Support Speaking Up!

Nova Mutual will always make every effort to do the right thing using good judgement and in the best interest of those we serve. Our Team Members are committed to providing a service to the community which embodies Nova Mutual’s values of Integrity, Respect and Courage.

At Nova Mutual we support a transparent and courageous culture where improper, unethical, or illegal conduct may be shared without fear of reprisal.

What You Might Report

Any action or suspected action of fraud, corruption or other illicit activity that may adversely affect Nova Mutual, our Team Members, Policy Holders, the Brokers, or the public at large is to be shared without fear of retaliation or negative impact.

Types of conduct which may be shared include (but are not limited to):

Financial Reporting.
Suspected Fraudulent or improver activity.
Retaliation or retribution against an individual who reports a concern.

What You Need To Know

Accounts of alleged violations or concerns are to be as factual as possible and contain as much detail as reasonably possible to allow for a proper examination.
We expect any concern or suspected concern will be made in good faith and have reasonable grounds.

What You Need To Know

Concerns raised in good faith will in no way result in retaliation or negative impact towards the person who reported the concern.
Accounts of concern will be evaluated to determine if it contains a reasonable basis for an examination.
In certain circumstances, concerns brought forward may not be fully reviewed should the information provided be insufficient or inadequate to warrant a proper assessment.
Cooperation from the Nova Mutual Leadership Team, auditor, external legal or accounting expertise may be used as required.
Unless necessary, every effort will be made to keep your identity confidential

Where You Can Voice Your Concerns

Should you suspect conduct at Nova Mutual which is improper, unethical, or illegal we encourage you to email whistleblower@novamutual.com and the Governance Committee Chair of the Board of Directors will contact you to by email or phone to investigate.

Code of Business Conduct

1. A conflict of interest refers to situations in which personal, occupational or financial considerations may affect, or appear to affect, a Director’s objectivity, judgment or ability to act in the best interest of the Corporation and includes conflicts as described throughout this document.
2. A conflict of interest may be real, potential or perceived in nature.
3. A real conflict of interest arises where a Director has a private or personal interest; for example, a close family connection or financial interest.
4. A potential conflict of interest may arise when a Director has a private or personal interest such as an identified future commitment.
5. A perceived or apparent conflict of interest may exist when a reasonable, well-informed person has a reasonable belief that a Director has a conflict of interest, even if there is no real conflict.
6. Full disclose, in itself, does not remove a conflict of interest.

Nova Mutual expects all employees and directors to act appropriately. This means distinguishing between your personal interests and Nova Mutual’s interests and avoiding any conflict between the two. Any action you take on behalf of Nova Mutual must not be influenced by the possibility of gain for yourself or for anyone personally associated with you. It is also important to avoid any appearance of a conflict.

Any person who is aware of, or has reasonable grounds to believe that, a potential conflict of interest exists, is required to report it to the President & Chief Executive Officer, or to the Chair of the Conduct Review/Governance Committee of the Board of Directors. All real conflicts of interest must be disclosed by the President & Chief Executive Officer to the Chair of the Conduct Review/Governance Committee on an annual basis or more frequently.

The existence of a potential conflict will not necessarily prevent the employee’s/director’s involvement in that situation. There may be situations where, once declared, the conflict can be managed so as to enhance rather than undermine the employee’s/director’s contribution to the Company. That said, in some cases, an individual may be asked to remove himself/herself from the situation.

An employee who fails to disclose a conflict of interest to his/her supervisor shall be subject to appropriate disciplinary action that may include suspension, termination, reimbursement to the Company of the monetary value of the benefit received directly or indirectly, and/or legal action, depending on the nature and severity of the conflict.

Many situations could give rise to a potential conflict of interest, or to the appearance of a conflict. This section of the Code sets out some of the more common conflicts, but it is not exhaustive. If you feel that your personal interests and those of Nova Mutual may be, or may be perceived to be, in conflict, speak to the President & Chief Executive Officer.

	Conflict Guideline	Examples of Conflict Management Resolution
A	If such a conflict arises … Employees/directors will not participate in the underwriting, adjusting, inspection or other Company business of an immediate family member or close personal friend or their own policy.	Then … Employee ask supervisor to assign that work to another employee or to an independent contractor. Employee may declare the conflict, and the employee’s supervisor will independently audit the work.
B	Employees/directors will not participate in the hiring/acceptance, direct supervision, evaluation, promotion, or salary administration of relatives or persons with whom they have a close personal relationship.	Person must be hired/accepted according to their merits as compared to all other applicants. An independent capable supervisor must direct and evaluate the person’s work. An independent capable supervisor must determine the person’s promotion and salary.
C	Employees/directors, or entities in which they or immediate family members hold an interest, may not contract with the Company as a business supplier of materials, equipment or services, or as a purchaser of surplus assets.	Conduct Review/Governance Committee may provide written permission
D	It is possible that you may be offered gifts or favours in the course of your work. In limited circumstances, you may accept them. In each case, you should consider the value of the gift or favour and the circumstances in which it is offered. Generally, you should not accept gifts or other favours that could in any way influence, or appear to influence, your business decisions. You should not accept frequent gifts from one source, even if they are only of nominal value. Of course, you may not engage in conduct that could be interpreted as directly or indirectly seeking, receiving or providing a bribe or kickback.	The gift/prize is disclosed to the employee’s supervisor. The gift is a token courtesy with small intrinsic value and does not place or appear to place the recipient under any obligation to the giver or have the possibility of influencing the recipient in their duties. The gift is accepted on behalf of the Company and used in fund raising events or for Company business purposes and has the effect of reducing expenses that would normally have been incurred. Cash, in any amount, must not be accepted or given as a gift or favour under any circumstances.
E	An employee/director must not use his/her position within the Company to influence any business in its dealings with other parties for the personal profit or advantage of any person. You should ensure that you are independent, and are seen to be independent, from any business organization that has a contractual relationship to provide goods or services to Nova Mutual. For this reason, you should not invest, or acquire a financial interest, directly or indirectly, in any organization if that might influence, or create the impression of influencing, your decisions on behalf of Nova Mutual.	When settling a claim, ask the policyholder to select which contractor is used from a list of approved contractors. Unless specifically provided under the tERM and ORSAs of your employment or engagement, you may not receive a commission or other compensation related to the sale of any product or service of or to Nova Mutual.
F	An employee/director may not use the services of other employees, or make use of Company facilities, supplies or resources to serve a personal interest.	Supervisor approval and agreement that level of use is immaterial. Other employee’s time does not conflict with his/her ability to meet the responsibilities/duties to the Company. Employee reimburses Company for facilities, supplies, resources or services of other employee’s time at fair market value rates.
G	An employee may not involve him/herself in outside activities, either paid or unpaid, if these activities interfere with his/her obligations, duties and responsibilities as an employee of the Company.	Realigning activities so that they bring credit to Company, as well as to the employee. Reducing the level of outside activity to avoid interference. Reducing the work load and corresponding remuneration, where applicable, to allow employees the freedom to pursue outside activities.

Dealing with Information, Technology and All Other Assets

Keeping information confidential

All information about Nova Mutual and its businesses is, and must be treated as, confidential until that information has been publicly disclosed by press release or is otherwise generally available to the public. This is the case even if the information is not material.

You may not disclose confidential information, except as required by law or as approved in advance by the appropriate manager, to anyone outside of Nova Mutual, including family and friends. This applies even after you have left Nova Mutual’s employment. You may also not disclose confidential information to Nova Mutual colleagues unless they need to know the information to carry out their employment.

You are responsible for protecting confidential information in your custody against, theft, loss, unauthorized access, destruction or misuse.

Using Technology Appropriately

The internet, any intranets, and email are increasingly important business resources and provide unprecedented access to information. However, it is possible that this technology may be abused.

Nova Mutual’s electronic communications systems are Nova Mutual’s property and should be used primarily for Nova Mutual’s business purposes. Limited appropriate personal use is permitted provided it does not interfere with your business activity or Nova Mutual’s business operations. Social networking activities while at work should be limited to business purposes and are not to interfere with the employee’s primary job responsibilities. To monitor personal use, the Company will check individual activity periodically. You should not expect that any of your email or Internet communications are private. Cyber bullying is defined as harmful actions that are communicated via electronic media that are intended to embarrass, harm, or slander another individual. We will not tolerate cyber bullying whether at work or outside of work.

Using Other Assets Appropriately

You may only use Nova Mutual’s assets for legitimate business purposes and are required to use good judgement in spending Nova Mutual’s funds. You must also take responsible steps to protect assets owned by or entrusted to Nova Mutual against loss, theft, damage or misuse.

You are required to follow internal policies and procedures for handling and protecting Nova Mutual’s assets. This includes being careful not to breach any copyright laws, intellectual property laws or regulations when making copies of documents or software, not to reveal company secrets and not to permit others to use Nova Mutual’s assets

Maintaining Books and Records

Nova Mutual Insurance Company is required to maintain accurate and reliable records to meet its legal and financial obligations and to manage its affairs. Nova Mutual’s books and records should reflect accurately all business transactions. Undisclosed or unrecorded revenues, expenses, assets or liabilities are prohibited.

Maintaining Privacy

Respect for privacy is necessary to build strong business relationships. We accumulate a considerable amount of information about customers and employees. You are required to keep confidential any of this information that you might access in the course of your work.

You should collect, use or disclose personal information only with the knowledge and permission of the person to whom the information relates unless otherwise permitted by local laws. In that context, you should always validate the person with whom you are speaking at any time personal information is being disclosed.

In certain jurisdictions where we conduct our business, our customers have the right to ask if we hold any personal information about them and, if so, to review it. They may also have the right to know how we collected the information, how we use it, and to whom we have disclosed it.

Personal information may only be used for the purposes for which it was originally collected, unless otherwise permitted by local laws or we are authorized to use it for another purpose. In addition, access to personal information within Nova Mutual generally is restricted to those employees who have a legitimate business reason to access it.

Engaging In Charitable Activity

Nova Mutual has an organizational structure in place to deal with charitable and philanthropic spending. Please direct this type of request to the President & Chief Executive Officer.

Communicating With Others

When communicating on matters that involve Nova Mutual business, you should not speak for Nova Mutual unless you have been expressly authorized to do so.

Broker Portal Complaints & Code of Conduct Land Acknowledgement Privacy Policy Careers

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