ࡱ> %` YbjbjNN C,,If |||.$ttt}}}8}}'#~~L~~~:::$hMȦt26Ȧ((~~4ݦCCC(~t~CCCΝ0^t2~~ d}F\0#Ɇ^422tF:DCDHI:::ȦȦ':::#''D*=D n]D ''*=n]\((( AUSTRALIAN HUMAN RIGHTS COMMISSION  ApplicantsAuto & General Insurance Company Limited (ACN111586353)ANDa & g insurance services ltd (acn 003 617 909)ANDAUSTRALIAN INSURANCE HOLDINGS PTY LTD (ACN086321459) SUBMISSIONS INTRODUCTION The submissions are made on behalf of Auto & General Insurance Company Limited (A&G), A & G Insurance Services Ltd (AGIS), Australian Insurance Holdings Pty Ltd (AIH) and their employees, officers, agents, insurance distributors and contractors (collectively the Applicants) in respect of an application for exemption pursuant to section 44 of the Sex Discrimination Act 1984 (the Act). The Applicants seek an exemption in respect of sections 22(1)(b), 22(1)(c) and 27 in relation to the ground described in section 6 of the Act, marital status. CONFIDENTIALITY Much of the information contained in these Submissions is sensitive and confidential to the business of the Applicants. The statistical data upon which this Application is based has been collected by Budget Insurance Company Ltd and A&G from their customers over a five year period ending 30 September 2008. As far as the Applicants are aware, no other insurers or insurers operating in Australia have compiled similar data. The data discloses A&G's client numbers and loss ratios. If made publicly available, this information could enable A&G's competitors to identify the most profitable segments of A&G's business and/or gain knowledge of its pricing structures. For these reasons, the Applicants request an order protecting the confidentiality of these Submissions. THE APPLICATION The application is made on behalf of a class of Australian companies and all of their employees, officers, agents, insurance distributors and contractors. Section 44(1)(c) allows for an exemption to be made in favour of a class of persons. There is no requirement that the members all be identified or ascertained at the time the application is made. Exemption is requested in respect of: discrimination in relation to the terms on which goods or services are provided on the ground of marital status which would otherwise be unlawful under the Act (section 22(1)(b)); discrimination in relation to the manner in which goods or services are provided on the ground of marital status which would otherwise be unlawful under the Act (section 22(1)(c)); and requests for information regarding marital status which may otherwise unlawful under the Act (section27); The exemption is sought for the maximum term, five years. BACKGROUND AND OBJECTIVE The Applicant companies form part of the Budget group of companies (the Budget Group). The Budget Group operates in South Africa, the United Kingdom and Australia. The Budget Group has operated in South Africa for more than 25 years and in the United Kingdom for more than 15 years. The Budget Group specialises in personal lines insurance. In South Africa, the relevant group companies underwrite insurance. In the United Kingdom, the relevant group companies act as an intermediary on behalf of a number of different insurers. The Applicants' international associates have identified a material statistical difference in the claims experience of their insured drivers, depending on their marital or relationship status. As a result, marital or relationship status is commonly used in these jurisdictions as a rating factor to calculate car insurance premiums. Since September 2003, the Applicants have been collecting statistical data about the marital status of their customers. The reason for collection of the information has been two-fold: firstly, for marketing purposes so that the Applicants may tailor their marketing strategy to the particular demographics of their customers; and secondly, to observe whether similar claims trends exist in the Australian car insurance market to justify using marital status as a rating factor. The statistical data collected by the Applicants displays very similar trends by marital status as those experienced by the relevant Budget Group companies operating in the United Kingdom and South Africa. In accordance with its usual underwriting practices (adopted by all insurance companies), the Applicants wish to price their motor vehicle insurance policies in a way that is consistent with their claims experience. The Applicants are confident that their analysis provides a reliable basis for them to price their motor vehicle insurance policies in a way which accurately reflects the different risk associated with insured persons of different marital status. The purpose of this Exemption Application is to allow the Applicants to offer motor vehicle policies to individuals at prices which may differ depending on the marital status of the regular driver, without breaching the Act. In most Australian states this is permitted without an exemption, as long as the pricing is done by reference to reliable statistical analysis of the relative risks. COLLECTION OF DATA The data has been provided for a five year period ending 30 September 2008. The data is collected when a policy is sold. Details about the policy, the vehicle and the customer, such as the marital status of the regular driver of the vehicle, are collected and stored in the Applicants' mainframe database system . When a prospective customer applies for a policy, they are required to indicate the marital status of the regular driver of the vehicle by selecting from the following options: separated; divorced; married; cohabiting; single; and widowed. MARITAL STATUS REPORT The Applicants have generated a Marital Status Report (the Report) based on the collected data. Results by marital status are shown in the Report for each of the following groups: males; females; insureds aged 16 24 years; insureds aged 25 39 years; and insureds aged 40 and above. For each category of policy holder, the data also provides details including: claims frequency; average claim size; and the claims ratio. For the purpose of determining pricing equitability across portfolio segments, the claims ratio is the primary measure. The claims ratio indicates the value of the claims made by customers, compared to the premium income earned from those customers. If a category of customers has a lower than average claims ratio, it means they perform more profitably than the average customer. A higher than average claims ratio indicates the converse position. The indication is that cohabiting and married males and females perform significantly more profitably than the average, while all other categories of customers perform less profitably than the average. OTHER INFLUENCING FACTORS It was recognised that the analysis might be distorted by an interaction of marital status with the age of the driver, recognising that there may be more young drivers in the singles segment and young drivers generally perform less profitably. To test this, the Applicants have categorised their customers into the following age brackets: 16 24 years; 25 39 years; and 40 99 years. By excluding drivers under 40 years of age, the data shows that the differences by marital status are lessened, but still material. PREMIUM ADJUSTMENT When the Applicants review their performance to improve profitability or competitiveness, a notional price adjustment is calculated for each segment of the portfolio of customers. The goal is to ensure that each segment of the portfolio achieves the same financial performance as the overall portfolio. This allows the Applicants to be competitive compared to others in the market and ensure the Applicants are not exposed to risks that are under priced. If the exemption sought is granted, the Applicants may use marital status as a rating factor. This could allow them to more accurately and commercially price their products and offer increased discounts to their customers who perform more profitably. There could be a price increase for certain customers. ISSUES FOR CONSIDERATION The granting of an exemption is discretionary. When exercising a function under s44 of the Act, the Commission is to consider the following matters: whether the exemption is necessary; whether granting an exemption consistent with the objects of the Act; and whether it is appropriate to grant an exemption subject to terms and conditions? An exemption can be granted on whatever terms are appropriate to ensure maximum consistency with the legislation. Nothing in the regulations limits the power of the Commission to consider any other matters when exercising the Commission's functions under s44 of the Act. THE EXEMPTION MUST BE APPROPRIATE AND REASONABLE Assessing this broad question can involve consideration of the following matters: consistency with the spirit of existing exemptions; and the degree of tension between the objectives and scheme of the Act and the proposed exemption. The Act provides for a specific exemption for sex discrimination in the insurance area: section 41 provides that nothing in Division 1 or 2 makes discrimination by the insurer against the client unlawful if: the discrimination is on the ground of the client's sex; and the discrimination is in the terms on which an insurance policy is offered to, or may be obtained by, the client; and the discrimination is based on actuarial or statistical data from a source on which it is reasonable for the insurer to rely; and the discrimination is reasonable having regard to the data; and if the client gives the insurer a written request for access to the data - either: the insurer gives the client a document containing the data; or the insurer: makes a document containing the data available for inspection by the client at such time or times, and at such place or places, as are reasonable; and if the client inspects the document - allows the client to make a copy of, or take extracts from, the document. The proposed exemption is not dissimilar to the existing specific exemption for the insurance area based on sex. The Applicants are confident that the statistical data they have accumulated over the five years to 30September 2008 provides a reliable basis for them to price their motor vehicle insurance policies in a way which accurately reflects the different risk associated with drivers of different marital status, just as they currently price motor vehicle insurance policies according to the different risk associated with drivers of different sex and age status. It is consistent with the objectives and scheme of the Act to grant an exemption to the Applicants. The exemption sought fits well within the scheme of the existing exemption which reflect Parliament's intent to permit insurance companies to classify risks and set premiums in accordance with accepted actuarial practice. There is no reason to assume that Parliament intended that people deserved less protection on the basis of their sex than they should receive because of their marital status. Rather, it is more likely that Parliament was not conscious that there might be different risk associated with different marital status. THE EXEMPTION MUST BE NECESSARY For an exemption to be granted it must be necessary. This means the activity would otherwise be likely to be unlawfully discriminatory. In order to establish whether an exemption is necessary, an Applicant is only required to show an arguable case that the circumstances might constitute discrimination to which the Act might apply. If the exemption sought is not granted, the Applicants, by pricing motor vehicle insurance policies according to marital status and collecting data about a customer's marital status for that purpose, will likely contravene the following provisions of the Act: Section 22(b) Section 22(b) relevantly makes it unlawful for a person who provides goods or services to discriminate against a person on the grounds of marital status in the terms on which those goods or services are provided. Section 22(c) Section 22(c) relevantly makes it unlawful for a person who provides goods or services to discriminate against a person on the grounds of marital status in the manner in which those goods or services are provided. 'Marital status' is defined in section 4 of the Act to include being: single, or married, or married but living separately and apart from one's spouse, or divorced, or widowed, or in a de facto relationship. Section 27 Section 27 makes it unlawful to request or require a person to provide information which could be used to discriminate against a person in the provision of goods and services. There are no relevant exemptions that apply to discrimination on the basis of marital status in the insurance area. There is certainly an arguable case that if the Applicants supply insurance to persons on more or less favourable terms based on their marital status or request information regarding a person's marital status for the purposes of determining the terms on which the insurance will be offered, there will be a breach of the Act. WHETHER THERE ARE ANY NON-DISCRIMINATORY WAYS OF ACHIEVING THE OBJECTS OR PURPOSES FOR WHICH THE EXEMPTION IS SOUGHT The Applicants cannot avoid discriminating if they are to price motor vehicle insurance policies in a competitive way and in a manner consistent with how their international associates within the Budget Group and other international insurers price motor vehicle insurance policies. The Applicants have only asked for the exemption to apply in circumstances which mirror the specific exemptions for discrimination in the insurance area that is, for the exemption to apply, the discrimination must: be based upon actuarial or statistical data from a source on which it is reasonable to rely; and be reasonable having regard to the data and any other relevant factors. It is of course possible that the Applicants will have to defend future conduct where it is alleged that the discrimination is not based on actuarial or statistical data from a source on which it is reasonable to rely and/or is not reasonable having regard to the data or other relevant factors. The exemption will not absolutely shield the Applicants against litigation under the Act. They are shielded only to the extent that the data is reasonable, has been obtained from a reasonable source and the discrimination is reasonable having regard to that data and any other relevant factors. Any litigation which follows would focus on the reasonableness of the data and the reasonableness of the discrimination having regard to that data. If the Applicants can establish these factors, then the exemption would apply. WHETHER THE PROPONENT OF THE PROPOSED EXEMPTION HAS TAKEN REASONABLE STEPS, OR IS ABLE TO TAKE ANY REASONABLE STEPS, TO AVOID OR REDUCE THE ADVERSE EFFECT OF A PARTICULAR ACT OR ACTION BEFORE SEEKING THE EXEMPTION The Applicants have been unable to take any reasonable steps to avoid or reduce any adverse effect of the relevant acts and actions prior to applying for this exemption, and remain unable to do so. The Applicants do not currently discriminate on the basis of marital status in the provision of its insurance policies. THE PUBLIC, BUSINESS, SOCIAL OR OTHER COMMUNITY IMPACT OF THE EXEMPTION In Olympic Roads & Transport Authority (ORTA) Exemption Application it was held by Member Tahmindjis that 'community interest has clearly been held to be a factor to weigh in the exercise of discretion'. A similar approach was adopted by President Sofronoff QC in Boeing Australia Holdings Pty Limited & Ors Exemption Application. If the Applicants are permitted to use marital status as a rating factor, it would allow them to more accurately and commercially price their products and offer increased discounts to their customers who perform more profitably. This would result in a positive business impact for the Applicants and a positive social and community impact to customers who perform more profitably. It is not unlawful for insurance companies to discriminate on the basis of relationship/marital status in certain Australian jurisdictions. Anti-discrimination legislation in Western Australia, Victoria, Tasmania, the ACT and Northern Territory permit discrimination in the insurance area, on the basis of any attribute, if the discrimination is based on actuarial or statistical data from a reasonable source and the discrimination is reasonable having regard to that data. On 27 January 2009, the Queensland Anti-Discrimination Tribunal granted an exemption expiring five years from that date in the following terms: That it is not unlawful for the Applicants to discriminate on the basis of relationship status in relation to the terms on which insurance is provided if the discrimination is based on reasonable actuarial or statistical data from a source on which it is reasonable for the Applicants to rely; and is reasonable having regard to the data and any other relevant factors. The Applicants will not decline a claim made under an insured's motor vehicle insurance policy on the basis that the insured failed to disclose his or her relationship status or any change in the relationship status; and The Applicants will not refuse any application for insurance or insurance renewal on the grounds of the information a person provides about their relationship status. If the exemption the subject of this application is granted, it will permit the Applicants to move towards a national uniform rating procedure. This will also avoid potential increases and decreases in a customer's premium (based on marital status) when they move interstate. TERMS OF EXEMPTION ANY CONDITIONS OR LIMITATIONS TO BE CONTAINED IN THE PROPOSED EXEMPTION The proposed exemption sought is limited by the following terms: For an Applicant to take the benefit of the exemption, the discrimination must: be based on reasonable actuarial or statistical data from a source on which it is reasonable for the Applicants to rely; and be reasonable having regard to the data and any other relevant factors. Were the exemption granted on these terms, the Applicants would be shielded only to the extent that the data is reasonable, has been obtained from a source on which it is reasonable to rely, and the discrimination is reasonable having regard to that data and any other relevant factors. The propose terms would make the exemption of the same scope as the exception under the Act relating to sex discrimination (section 41) in the terms on which insurance services are provided. If the exemption is granted on the proposed terms, the scope of the discrimination it would permit would be no more broad than discrimination currently permitted in other states and territories. The exemption is sought for a period of five years. .. Minter Ellison Solicitors for the Applicants Dated: 7 September 2009  Since August 2005, A&G has been authorised by the Australian Prudential Regulatory Authority (APRA) to carry on general insurance business in Australia. Accordingly, it has been collecting statistical data about the marital status of its customers from that date. Prior to August 2005, the statistical data was collected by A&G's related UK company, Budget Insurance Company Ltd (BIC). BIC was also authorised by APRA to carry on general insurance business in Australia. BIC's general insurance business was transferred to A&G on 12 May 2008 pursuant to a Federal Court order in accordance with the requirements of the Insurance Act 1973 (Cth). BIC was deregistered in Australia on 14 April 2009.  Section 44 of the Sex Discrimination Act 1984 (Cth).  Temporary exemptions under the Sex Discrimination Act: Commission Guidelines (24 April 2008).  Stevens & Ors v Fernwood Fitness Centres Pty Ltd (1996) EOC 78805.  See, for example, Zurich Insurance Co. v. Ontario (Human Rights Comm. (1992), 16 C.H.R.R. D/255 (S.C.C.) [Eng./Fr. 46 pp.] in which the Supreme Court of Canada held that the insurer was entitled to fix insurance premiums higher for young, single men because it came within the exemption of being 'based on reasonable and bona fide grounds' contained in the Ontario Human Rights Code.  [2000] QADT (9 August 2000).  [2003] QADT (19 November 2003).      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