General Insurance Companies APRA Prudential Standard GPS 231 - Outsourcing by Jenny Willcocks | October 2006
APRA has released a package of new prudential standards to apply to life insurance companies (including friendly societies), general insurance companies and authorised deposit taking institutions, covering requirements for: • • • •
responsible persons to meet ﬁt and proper requirements; a risk management framework; business continuity management; and outsourcing arrangements involving “material business activities”.
These changes are intended to standardise prudential management for all APRA regulated entities to the extent that is possible given the diversity of those entities. This paper provides an overview of Prudential Standard GPS 231 (GPS 231) dealing with outsourcing arrangements for material business activities entered into by general insurance companies (insurers). It also considers the Prudential Practice Guide 231 (PPG 231) on outsourcing, which is intended to provide guidance on how GPS 231 should be applied. GPS 231 is legally binding1 but PPG 231 is not. GPS 231 will apply from 1 January 2007 subject to some transitional arrangements.
Objective The objective of GPS 231 is to ensure that outsourcing arrangements are subject to appropriate levels of due diligence, Board approval and ongoing monitoring. By ensuring the outsourcing does not expose the insurer to new and uncontrolled risks, the risk of ﬁnancial loss to policy holders is reduced. GPS 231 will also ensure that insurers can demonstrate that they have identiﬁed and addressed the key risks involved in outsourcing, managing and monitoring those risks in an appropriate way.2
Key Requirements The key requirements for GPS 231 are that insurers must: • • • • •
have a policy in place for outsourcing material business activities (the Policy); have sufﬁcient monitoring processes for the ongoing management of those activities; where those activities are with third parties, have a legally binding agreement except where agreed by APRA; consult with APRA before entering into agreements to outsource these activities where service providers are located outside Australia; and notify APRA after entering into an agreement to outsource material business activities and when those agreements cease to apply.
The insurer remains responsible for complying with all prudential requirements concerning the outsourced material business activity, even though it may have handed responsibility for that activity and its day-to-day management to a service provider.3
T U R KSLEGAL
What is a Material Business Activity? A “material business activity” is an activity of an insurer that has the potential, if disrupted, to have a signiﬁcant impact on the insurer’s business operations, or its ability to manage risks effectively.4 To determine whether the activity outsourced is a “material business activity”, the following factors should be considered: • • • • • •
the ﬁnancial, operational and reputational impact on the insurer’s business if the service provider fails to perform over a given period of time; the cost of the outsourcing arrangement as a share of total costs; the degree of difﬁculty to ﬁnd an alternative service provider or bring the material business activity in-house, and the time this would take; whether the insurer will be able to meet regulatory requirements if problems occur with the service provider; potential losses to the insurer’s customers and other affected parties which may result from the failure of the service provider; and afﬁliation or other relationships between the insurer and the service provider.5
EXAMPLES OF “MATERIAL BUSINESS ACTIVITIES” GPS 231 states that the internal audit function must be treated as a material business activity6. Other examples of a material business activity of an insurer include:
• • • • • • •
investment management functions; professional services such as accounting and actuarial; a signiﬁcant part of a regulated institution's information technology functions that support its core business; business continuity management arrangements and business recovery facilities; loan processing; claims processing; marketing and research; custodial or administration arrangements; and arrangements with agents, brokers and reinsurance brokers.7
WHAT IS NOT A “MATERIAL BUSINESS ACTIVITY”? PPG 231 gives some guidance as to what APRA does not consider would be caught by the deﬁnition of “material business activity”. This would include: • • •
contractor relationships where there are numerous service providers in the market place; where the agreement is short term (ie. less than 12 months); and where the cost of switching between providers is low and relatively easy.8
EXAMPLES OF WHAT IS NOT A “MATERIAL BUSINESS ACTIVITY” Examples of what is not a “material business activity” include:
T U R KSLEGAL
• • • • • • • • •
utility services (eg. mail and telephone services); legal services; advertising; recruitment and other personnel functions; printing services; travel and transportation services; repair and maintenance of ﬁxed assets; purchase of goods; background investigation and information services; and specialised training and software licensing arrangements.9
PPG 231 indicates that use of a third party Approved Actuary by an insurer will not generally constitute a “material business activity” of the insurer. Therefore, these activities would not fall within the deﬁnition of outsourcing for the purposes of GPS 231. However, it is still APRA's expectation that these arrangements would be subject to adequate assessment and proper documentation.10
What is “Outsourcing”? Outsourcing involves an insurer entering into an agreement with another party (including a related body corporate) to perform, on a continuing basis, a business activity that currently is, or could be, undertaken by the insurer itself.11
IS A SECONDMENT OUTSOURCING? PPG 231 conﬁrms that a secondment would not usually be deﬁned as “outsourcing”. This is because most secondments involve the insurer maintaining effective management control of a third party resource, which is normally physically located within the insurer. In normal circumstances, a secondment would involve one company within a corporate group employing all personnel of the group and seconding those personnel to other entities within that group. If there is doubt as to whether a particular secondment could be deﬁned as outsourcing, the insurer should treat the activity as if it were outsourcing in order to comply with GPS 231.12
TEST TO APPLY Therefore for GPS 231 to apply:
• • •
there must be an agreement between the insurer and another party; the agreement must relate to performance of a business activity that the insurer is or could perform itself; and the business activity must be a “material business activity” as deﬁned in GPS 231.
T U R KSLEGAL
Outsourcing Policy A insurer must develop an outsourcing policy (the Policy) approved by its Board, that: •
describes how it approaches outsourcing its material business activities; and includes a detailed framework for how it will manage its outsourced arrangements.13
RISK MANAGEMENT Risks relating to the outsourcing of a particular material business activity must be addressed in the insurer’s risk management framework.
PROMOTING THE POLICY Procedures must be in place to ensure relevant business units within the insurer are aware of the Policy and its terms and comply with the Policy.14 This could include publishing the Policy on the insurer’s intranet for its staff, providing training for staff and including training on the Policy in its induction process.
RELATED BODY CORPORATES The Policy must deal with speciﬁc requirements when outsourcing to related bodies corporate, and to service providers conducting the material business activity outside of Australia.15
Assessing Options for Outsourcing GPS 231 sets out a process for selecting the service provider to which a material business activity should be outsourced, that must include: • • • • • • • •
preparation of a business case for outsourcing the relevant activity; undertaking a tender or other selection process for service providers; undertaking a due diligence review of the chosen service provider; involving the Board in approving the outsourcing agreement (the Agreement); ensuring the Agreement covers the minimum requirements (see below); preparation of procedures for monitoring performance of the service provider under the Agreement on an ongoing basis; a renewal process for the Agreement; and developing contingency plans so an alternative service provider can provide the outsourced business activity or it can be brought in-house where necessary.16
OUTSOURCING TEAM A possible approach to this assessment process is by use of a multi skilled team. The team would include representatives from the relevant business areas of the insurer and others with skills to assess risks involved in the outsourcing of the speciﬁc material business activity, including external experts.
T U R KSLEGAL
One of the obligations of the team would be to ensure that the Policy is complied with including assessment of the tender and due diligence processes, evaluation of the outsourcing options available and making recommendations to senior management and the Board on the outsourcing proposal.17
RELATED BODY CORPORATES Where the decision to outsource is to a related body corporate, the insurer’s assessment of the service provider must also include a consideration of: •
• • • •
changes to the risk proﬁle of the material business activity being outsourced that will occur as a consequence of it being outsourced to a related body corporate, and how that change will be addressed within a insurer's risk management framework; the ability of the related body corporate to conduct the material business activity on an ongoing basis; what monitoring procedures will be necessary to ensure a related body corporate performs effectively and how potential inadequate performance would be addressed; what contingency issues, in accordance with policy or procedures of the insurer, are in place concerning the business continuity management if the outsourced activity needs to be brought in-house; the need to apply any of the above requirements to the extent they are relevant to Agreements with related bodies corporate.18
Offshoring Arrangements DEFINITION OF “OFFSHORING” For the purposes of GPS 231, the term “offshoring” means outsourcing of a material business activity associated with the Australian business of an insurer to a service provider (including a related body corporate) where the outsourcing activity will be conducted outside Australia. This would include arrangements where the service provider is incorporated in Australia, but the physical location of the outsourced activity is outside Australia. It does not include arrangements where the physical location of an outsourced activity is within Australia, but the service provider is not incorporated in Australia.19 It also does not include the situation where an Australian entity has an overseas branch that outsources within the host country or another country.20
CONSULTATION WITH APRA Before entering into any offshoring agreement involving a material business activity, the insurer must consult with APRA so that APRA can satisfy itself that the impact of the offshoring arrangement has been adequately addressed as part of an insurer’s risk management framework.21 The intention is that APRA will have an opportunity to review the insurer’s assessment of offshoring risks, and the processes and controls introduced to mitigate those risks. Although APRA will provide feedback, it does not intend to approve individual offshoring arrangements.22 Where APRA considers the offshoring agreement involves risks the insurer is not managing appropriately, it may require the insurer to make other arrangements for the outsourced activity as soon as practicable.23 This seems to contradict the statement that APRA is not approving such an arrangement. If it investigates the assessment and does not object to it then quasi approval could be implied.
T U R KSLEGAL
“OFFSHORING” RISKS GPS 231 identiﬁes the following risks that are speciﬁc to an offshoring arrangement:24 • • • •
Country Risk – Risk of overseas economic, political and/or social events impacting on the ability of an overseas service provider meeting its obligations to the insurer. Compliance (legal) Risk – Risk that the arrangement will impact on the insurer’s ability to comply with relevant Australian and foreign laws and regulations (including accounting practices). Contractual Risk – Risk that the insurer may not be able to enforce the offshoring agreement. Access Risk – Risk that the insurer will be partly or completely hindered in obtaining information and records. This also potentially results in APRA being unable to gain access to the service provider and information for the purposes of prudential review. Counterparty Risk – Risk of the service provider being unable to comply with Agreement or perform as agreed.
These and any other risks would be identiﬁed during preparation of the business case for outsourcing the material business activity, the due diligence process and contractual negotiations. They would also be considered during the ongoing monitoring and control of the relevant material business activity.25 Additional requirements apply to an Agreement involving an offshoring arrangement (see below).
The Outsourcing Agreement All Agreements must: • • •
be evidenced by a legally binding written agreement, except where otherwise stated in GPS 231 (see related party exception below); be executed before the outsourcing arrangement commences; and be sufﬁciently ﬂexible to accommodate changes to existing processes and to accommodate new processes in the future to meet changing circumstances.26
RELATED BODIES CORPORATE EXCEPTION TO WRITTEN AGREEMENT The requirement that a written, legally binding agreement be in place does not apply to an outsourcing arrangement with a related body corporate unless: • •
APRA notiﬁed the insurer, after consulting with it, that the arrangement must be evidenced by a written, legally binding agreement; or another prudential standard requires the arrangement in question to be undertaken using a written, legally binding agreement.27
MINIMUM REQUIREMENTS Paragraph 19 of GPS 231 sets out the following minimum requirements an Agreement must meet: • • •
the scope of the arrangement and services to be supplied; commencement and termination dates; provisions for reviewing the Agreement;
T U R KSLEGAL
• • •
pricing and fee structure - pricing arrangements must be speciﬁc and cover frequency of payment, invoicing and payment procedures.28 service levels and performance requirements - this may include: • content, frequency and format of the service being provided; • timelines for receipt and delivery of work and priorities; • performance benchmarks including default benchmarks which, if not met, could result in penalties, or in extreme cases termination of the Agreement. Agreed service levels would be speciﬁed in the Agreement29; audit and monitoring procedures - this may include: • details of how internal or external auditors can obtain sufﬁcient information (including by on-site inspections or appointment of an external party) to satisfy themselves that the service provider’s risk management systems are adequate; • provision for an annual review of the service provider’s internal control systems by an independent expert.30 business continuity management (BCM) - details of how the BCM arrangements would ensure acceptable service levels are maintained if problems arise with the service provider or any sub-contracting or outsourcing by the service provider.31 conﬁdentiality, privacy and security of information; default arrangements and termination provisions - clearly specify what constitutes a default event, how it would be rectiﬁed and what indemnity provisions would apply to it.32 As a guide, the Agreement could include: • reasons for termination; • procedures to apply when termination occurs, such as notice period, rights and responsibilities of parties and transition arrangements for services to an alternative service provider or in house; • transition arrangements could include who owns and access to: - documents; - records; - software and hardware; • period for which the service provider would continue to provide the material business activity during transition; • role of service provider in transitional arrangements if the activity is brought back in-house or outsourced to an alternative service provider.33 dispute resolution arrangements - this should include conciliation and arbitration arrangements to resolve disputes and provide where appropriate for the continuation of the provision of the material business activity while any dispute is being dealt with.34 liability and indemnity - this could include: • the extent of the liability of each party to the Agreement; • whether there is any limitation on liability for negligence; • what indemnities apply; • any obligation to maintain insurance and the type of insurance required during the term of the Agreement; - extent of liability of parties for any subcontracting arrangements.35 (see below) subcontracting (see below); insurance; and where applicable, offshoring arrangements (including through sub-contracting) (see below).36
T U R KSLEGAL
FURTHER REQUIREMENTS Sub-contractors The Agreement must also include: •
An indemnity to the effect that any subcontracting by the third party service provider of the outsourced material business activity will be the responsibility of the service provider, including liability for any failure on the part of its subcontractor.37 Rules or limitations on the service provider outsourcing or sub-contracting the material business activity (e.g. a requirement to notify the insurer before entering into a sub-contracting arrangement).38 The same standards applicable to the service provider concerning security and conﬁdentiality of information, offshoring, compliance with relevant legislation and regulations, and APRA's right of access to information apply equally to sub-contractors or outsourcing arrangements entered into by the primary service provider.39
APRA Access to Service Providers The Agreement must include a clause allowing APRA access to documentation concerning the outsourcing arrangement. While APRA will seek information from the insurer, the Agreement must also give it the right to conduct on-site visits to the service provider where APRA considers this is necessary to perform its role as prudential supervisor. APRA expects service providers to cooperate with its request for information and assistance and this can only be assured if the service provider has a contractual obligation to do so which is enforceable by the insurer, as service providers may not be APRA regulated entities. If an on-site visit to a service provider is to be undertaken, APRA will usually inform the insurer of its intention.40 If the Agreement is with a related body corporate, the Board and insurer must ensure that access by APRA to the related body corporate will not be impeded.41 The insurer must take all reasonable steps to ensure through the Agreement that a service provider will not disclose or advertise that APRA has conducted an on-site visit except as necessary to coordinate with other institutions regulated by APRA, which are existing clients of the service provider.42
LEGAL ADVICE While legal advice concerning the Agreement is not mandatory, PPG 231 states that it could be considered including undertaking a legal due diligence before executing the Agreement to ensure there are no legal impediments to APRA gaining access to information, and/or to relevant employees of the insurer and service provider for the purpose of prudential supervision of the insurer’s business activities.43
OFFSHORING AGREEMENT The following additional provisions should be included in an Agreement involving an offshoring arrangement: •
Choice of Law – Specify what legal jurisdiction will apply to disputes. The due diligence process may include an investigation of the relevant foreign law applicable by a suitably qualiﬁed expert to ensure the contract will be enforceable in the foreign jurisdiction.
T U R KSLEGAL
Security and conﬁdentiality of information – PPG 231 suggests that contractual provisions concerning data should be of the same standard as those applicable under Australian legislation, and ensure information sent to the service provider (and including information sent by the service provider to third parties) remains the property of the insurer.44
NOTIFICATION REQUIREMENTS The insurer must notify APRA as soon as possible after entering into an Agreement of a material business activity, but in any event not later than 20 business days after executing the Agreement.45 Notiﬁcation of a new Agreement must be accompanied by a summary of the key risks involved in the outsourcing arrangement and the risk mitigation strategies the life insurance company has put in place to address those risks. APRA has the right to request additional material if it considers it necessary to assess the impact of this new outsourcing arrangement on the insurer’s risk proﬁle.46
UNEXPECTED EXTREME EVENTS Where an insurer must enter into an Agreement due to an unexpected extreme event resulting in it invoking its business continuity plan or the sudden ﬁnancial or operational failure of an existing service provider, the assessment process and requirements concerning the terms of the Agreement and notiﬁcation requirements referred to above, need only be complied with to the extent reasonably possible having regard to the nature of the extreme event concerned. The insurer must notify APRA as soon as practicable of any such arrangement.47
Monitoring the Relationship RESOURCES The insurer must have sufﬁcient and appropriate resources to manage and monitor its outsourcing relationships. The type and extent of resources required depends on the materiality of the outsourced business activity however, as a minimum, monitoring must include: • •
maintaining appropriate levels of regular contact with the service provider (e.g. daily operational contact to senior management involvement); and a process of regular monitoring of performance under the Agreement, including meeting criteria of service levels to be delivered.48
MONITORING FRAMEWORK The monitoring framework of an insurer should reﬂect its size and the nature of the arrangements it has in place. This could include speciﬁcally assigning accountability for the management of outsourcing arrangements to an individual or committee to ensure a continued focus on the outsourcing arrangement.49
T U R KSLEGAL
NOTICE TO APRA Where a signiﬁcant problem occurs that has the potential to materially affect the outsourcing arrangement and consequently the business operations, proﬁtability or reputation of the insurer, APRA must be advised.50 The insurer must also notify APRA as soon as practicable when it terminates an Agreement and provide a statement as to the transition arrangements and future strategies it has for carrying out that outsourced material business activity.51
AUDIT ARRANGEMENTS An insurer’s internal audit function must review any proposed outsourcing of a material business activity and regularly review and report to the Board or audit committee on compliance with the Policy.52 APRA may request the external auditor, or an appropriate external expert, to provide an assessment of the risk management processes in place concerning an arrangement to outsource a material business activity. This could include areas such as IT, systems, data security, internal control frameworks and business continuity plans. These reports will be paid for by the insurer and must be made available to APRA.53 To support the audit function an insurer would usually arrange for access to records held by the service provider necessary for the audit trail.54
SPECIAL REQUIREMENTS FOR MONITORING OFFSHORING ARRANGEMENTS To address the speciﬁc risks applicable to offshoring arrangements, APRA expects an insurer to maintain copies of important documents concerning the arrangement written in English and held at the insurer’s Australian ofﬁce. These documents could include copies of the: • • • •
contractual agreement; due diligence assessment; service provider’s business continuity management documentation and details of latest testing undertaken; and ﬁnancial statements, reports and any other information the insurer considers critical to the ongoing monitoring and control of the outsourcing arrangement with the service provider.55
It is also recommended that an insurer maintain an ongoing monitoring of the economic, social and political conditions within the host country to assess the ability of the service provider to continue to adequately perform the contracted service.56
Transitional Arrangements TRANSITIONAL RELIEF APRA has the discretion to grant transitional relief from the requirements of GPS 231 by exempting an insurer from any provisions of GPS 231, or varying its operation concerning a particular insurer.
T U R KSLEGAL
An application must be made to APRA for this relief, which will only be granted if APRA is satisﬁed that the insurer will not be able to comply with GPS 231 by the due date and that the Board and senior management have made all reasonable attempts to comply.57
TRANSITIONAL ARRANGEMENTS FOR EXISTING OUTSOURCING AGREEMENTS An insurer must notify APRA within 20 business days of 1 January 2007 of all existing Agreements that involve material business activities within and outside Australia.58 This requirement does not apply to Agreements entered into before 1 January 2007 until the next scheduled “review date” of the Agreement if the Board is satisﬁed that the existing Agreement is “generally compliant” with the requirements of GPS 231.59 If the Board is not satisﬁed, the insurer has until 31 December 2007 to comply unless it is granted transitional relief by APRA as referred to above.60
What is a “Review Date”? What will constitute a “review date” is not speciﬁed and clariﬁcation will be required. A “review date” could be: • • •
the annual date on which fees are reviewed; the date on which the Agreement is automatically renewed for a further term under an option to renew which does not require negotiation or review of any of the existing terms of the Agreement; or the date the Agreement is terminated and a new Agreement negotiated.
What is “Generally Compliant”? It is also not clear what is meant by “generally compliant” and further clariﬁcation will be required. Determining whether the Agreement is “generally compliant” will determine whether the Agreement has to comply from 1 January 2007 or at a later “review date”. Obviously “generally compliant” is something less than completely compliant but PPG 231 currently gives no guidance on this aspect.
Conclusion The timeframe permitted for compliance with GPS 231 is extremely tight given that it was released in October 2006. This means there is less than 3 months (including the Christmas/New Year holidays) for insurers to establish the Policy, implement it and have in place the necessary procedures to support the Policy. It will also be necessary to review all existing Agreements to determine if GPS 231 applies and, if so, whether the Agreement complies or will require amendment. If amendment is needed, changes will have to be negotiated with the service provider who may or may not be co-operative. The size of this undertaking is obviously greater for large insurers or those that outsource most of their business activities. A prompt response to GPS 231 is essential to meet the time frame.
T U R KSLEGAL
Policy Develop an outsourcing policy which complies with the requirements of GPS 231 including:
• • •
3. • • • • •
4. • • •
the assessment process for selecting service providers; the obligations which must be documented in each Agreement, including conﬁrmation of APRA's right of access to service providers’ premises and documents they hold; obtain Board approval of the Policy and implement it by circulating to all relevant stakeholders to ensure they are aware of its requirements and undertake appropriate training.
Monitoring Framework Develop monitoring framework to support the Policy and ensure that it is adhered to. Ensure there are sufﬁcient resources to support the management and monitoring of the Policy and the outsourced relationships. See “Monitoring the Relationship” in the attached Turk Alert. Note special requirements for offshoring arrangements. Modiﬁed internal audit requirements to include review of any proposed outsourcing arrangements and regular review and reporting to Board or Audit Committee on compliance with the Policy.
Identify “Material Business Activities” Identify all “material business activities” that are, or will be outsourced. Use the factors outlined in the section dealing with “What is a Material Business Activity” as a guide. Determine which of those “material business activities” are or could be performed by the insurer itself. Identify the Agreement(s) (whether in writing or not) relating to those activities that meet both the above requirements and are subject to GPS 231. Identify any activities, which involve “offshoring” and are subject to the special requirements applicable to those arrangements. Identify any Agreements that are with a related body corporate and ensure they meet the special requirements referred to in GPS 231.
Existing Agreements Identify and review Agreements entered into before 1 January 2007 to determine whether they meet the requirements and what changes are needed to comply. Determine the relevant “review date” for each Agreement and whether they are “generally compliant”. If the Agreement is not “generally compliant” identify changes needed for it to meet the GPS 231 requirements. Negotiate with the service provider all necessary changes to the Agreement to comply no later than 31 December 2007 and notify APRA. If the Agreement is “generally compliant” notify APRA within 20 business days of the next “review date”. If you are unable to renegotiate an Agreement within the time permitted, consider an application for transitional relief to APRA.
T U R KSLEGAL
5. • •
New Agreements Ensure all Agreements entered into after 1 January 2007 meet the new requirements. This will require informing employees, Board members or external service providers responsible for negotiating these Agreements, of the terms of the Policy, the monitoring framework and the need for the Agreement to meet the APRA requirements. This should ideally occur as soon as possible so that any Agreements currently being negotiated, or which will be before that date, can take account of the changes and avoid the need to renegotiate them at a later date. Notify APRA within 20 business days of execution of an Agreement and provide a summary of key risks involved in the outsourcing arrangement and risk mitigation strategies in place to address those risks. Ensure procedures provide for notiﬁcation to APRA of any signiﬁcant problems with potential to materially affect the outsourcing arrangement, and of termination of such an arrangement as soon as practicable with a statement as to the transitional arrangements for that activity.
Paragraph 32(1)(a) Insurance Act 1973
PPG 231 paragraph 16
Background, APRA Explanatory Statement
PPG 231 paragraph 8
GPS 231 paragraph 12, prudential requirements
PPG 231 paragraph 12
include those under the Insurance Act and its
PPG 231 paragraph 13
regulations, prudential standards, the Financial Sector
PPG 231 paragraph 14
(Collection of Data) Act 2001, reporting standards,
PPG 231 paragraph 1534 PPG 231 paragraph 17
conditions on a general insurance authority and other
PPG 231 paragraph 18
GPS 231 paragraph 19 GPS 231 paragraph 20
GPS 231 paragraph 9
GPS 231 paragraph 9(a) to (f )
PPG 231 paragraph 9
GPS 231 paragraph 10
This is not conﬁrmed in GPS 231, but is referred to in
PPG 231 Outsourcing, paragraph 3
PPG 231 at paragraph 10
PPG 231 paragraph 4
GPS 231 paragraph 23
PPG 231 – Outsourcing, paragraph 4
GPS 231 paragraph 24
PPG 231 – Outsourcing, paragraph 6
GPS 231 paragraph 25
GPS 231 paragraph 6
PPG 231 paragraph 20
PPG 231 – Outsourcing, paragraph 5
PPG 231 paragraph 26
GPS 231 paragraph 11
GPS 231 paragraph 26
GPS 231 paragraph 13
GPS 231 paragraph 27
GPS 231 paragraph 15
GPS 231 paragraph 22
GPS 231 paragraph 16
GPS 231 paragraph 30
PPG 231 paragraph 21
PPG 231 paragraph 28
GPS 231 paragraph 17
GPS 231 paragraph 31
GPS 231 paragraph 8
GPS 231 paragraph 32
PPG 231 paragraph23
GPS 231 paragraph 33
GPS 231 paragraph 28
GPS 231 paragraph 34
PPG 231 paragraph 22
PPG 231 paragraph 29
GPS 231 paragraph 29
PPG 231 paragraph 30
PPG 231 paragraph 24
PPG 231 paragraph 31
PPG 231 paragraph 25
GPS 231 paragraph 35
PPG 231 paragraph 11
GPS 231 paragraph 37
GPS 231 paragraph 21
T U R KSLEGAL
For more information please contact: Jenny Willcocks Partner T: 03 8600 5001 email@example.com
Melbourne | Level 10 (North Tower) 459 Collins Street , Melbourne, VIC 3000 | T: 03 8600 5000 | F: 03 8600 5099 Sydney | Level 29, Angel Place, 123 Pitt Street, Sydney, NSW 2000 | T: 02 8257 5700 | F: 02 9239 0922
Business & Property | Commercial Disputes | Insurance & Financial Services Workers Compensation | Workplace Relations www.turkslegal.com.au This Tur k Aler t is cur rent at its date of public ation. While eve r y c a re h a s b e e n t a k e n i n t h e p re p a rat i o n o f t h i s Tu r k Al e r t i t d o e s n o t co n s t i t u te l e g a l advice and should not b e relied up on for this pur p ose. Sp e c i f i c l e g a l a dv i ce s h o u l d b e s o u g ht o n p a r t i c u l a r m at te r s. Tu r k s Le g a l d o e s n o t a c ce p t resp onsibilit y for any er rors in or omissions from this Tur kAl e r t . Th i s Tu r k Al e r t i s co py r i g ht a n d n o p a r t m ay b e re p ro d u ce d i n a ny fo r m w i t h o u t t h e p er mission of Tur ksLegal. For any enquir ies, please contac t t h e a u t h o r o f t h i s Tu r k Al e r t .
APRA has released a package of new prudential standards to apply to life insurance companies (including friendly societies), general insuran...