1. Introduction

1.1. Within Cell Insurance, its subsidiary and associate companies, treating our customers responsibly, sustainably, and fairly is paramount. 1.2. It is essential to have a corporate-wide understanding of how to treat customers fairly and sustainably for the long-term success of the business.

2. Objective of the Policy

2.1. This policy provides guidance and outlines our philosophy of treating customers fairly in daily operations for the benefit of all stakeholders.

3. Scope

3.1. Applies to all activities undertaken by or on behalf of Cell Insurance, its subsidiaries, and associate companies.

3.2. Affected stakeholders include but are not limited to:

  • Insurance, medical, and healthcare services clients
  • Our Intermediaries and suppliers
  • Our Shareholders
  • Our regulators and related government institutions
  • Our employees

4. Definition of Key Terms

4.1. The Company – Cell Insurance and its subsidiary and associate companies.
4.2. Customers – Any individual, corporate, or institution purchasing goods/services from the company.
4.3. Treating Customers Fairly (TCF) – Putting customer well-being at the heart of business operations to minimize conduct risk.
4.4. Regulators – Licensing and supervising authorities for insurance, medical, and healthcare services.
4.5. Service Provider – Any entity with a business relationship impacting service delivery to customers.
4.6. Intermediaries – Licensed entities appointed by the Company to sell/provide its products/services.

5. Policy Statements

5.1. The company commits to treating all customers fairly by embedding a culture of fairness, understanding customer needs, and providing suitable products/services.
5.2. This commitment is core to our values and demonstrated through actions and corporate policies.
5.3. TCF is instilled throughout the business—from Board/Executive strategy down to recruitment, reward, controls, and staff performance.
5.4. The policy sets out responsibilities and demonstrates how the Company continually assesses fair customer treatment.

6. Treating Customers Fairly Commitments

6.1 Keeping things simple

  • Communicate clearly in simple language; translate where applicable.
  • Help customers understand our products/services.

6.2 Keeping things easy

  • Provide contact details via our contact centre.
  • Keep customers updated via SMS, emails, and Quarterly Newsletter.

6.3 Keeping things personal

  • Treat customers as individuals; offer choices based on individual needs.

6.4 Keeping things open

  • Listen to customer views.
  • Answer questions honestly and resolve problems quickly/fairly per our Service Charter.

6.5 Keeping things professional

  • Treat customers with courtesy, respect, and fairness.
  • Uphold integrity, empathy, and professional standards.
  • Hold third parties to the same standards via signed service level agreements.

7.0 Customer Outcomes

Regulator-defined TCF Outcomes (IPEC):

  • Outcome 1 – Customers can be confident fair treatment is central to corporate culture.
  • Outcome 2 – Products/services are designed to meet identified consumer group needs.
  • Outcome 3 – Clear information is provided before, during, and after sale.
  • Outcome 4 – Advice given is suitable and considers customer circumstances.
  • Outcome 5 – Products perform as expected; service meets acceptable standards.
  • Outcome 6 – No unreasonable post-sale barriers to change product, switch provider, claim, or complain.

7.1 Achieving the Desired Customer Outcomes

  1. Implement and embed TCF across the entire business.
  2. Core focus areas aligned with regulatory framework:

7.1.1 Product Designing and Testing

  • Consider target customers’ specific needs.
  • Adopt risk-based pricing reflecting individual circumstances.
  • Aim to offer the best rate based on customer characteristics.

7.1.2 Identifying Target Markets & Selection of Distribution Channel

  • Identify target markets before product design.
  • Select main distribution channels as part of business strategy; any additional channel must be examined for suitability.

7.1.3 Marketing and Promoting Products

  • Communicate clearly, fairly, and without misleading customers/distributors.
  • Regularly engage with distributors/customers to ensure clear understanding of products/processes.

7.1.4 Monitoring the End Result

  • Collect customer feedback to evaluate/review products.
  • Use review results to redesign products and improve service standards.

7.1.5 Delivery of Post-Sale Services

  • Monitor post-sale services to ensure promised/expected service levels.
  • Review customer complaints and feedback.
  • Document policies/procedures for complaints, claims, arrears, and collections.
  • Include feedback channels (e.g., feedback@cellinsurance.co.zw) on all customer touchpoints.

7.1.6 Monitoring TCF Compliance & Delivery of TCF Outcomes

  • Compile management reports (compliance reviews, complaints analysis, audits) for Board assessment.

8. Responsibilities

8.1 Board

  • Approve/ratify the TCF policy and periodic reviews.

8.2 CEO

  • Review TCF reports and approve management-proposed initiatives.
  • Recommend initiatives to the Board when necessary.

8.3 Management

  • Identify and propose initiatives to improve customer experience.
  • Implement approved initiatives per policy.

8.4 Internal Audit

  • Authorized by Management to assess policy compliance.

9. Reviews of the Policy

9.1. The policy shall be revised annually due to changing business landscapes and fraud risks. 9.2. The CEO and Board may review/change the policy at any time if deemed necessary.

Signed and Approved by the Chief Executive Officer