Our legal obligations

Southern Cross (SC) is a registered financial services provider in New Zealand and is governed by the Financial Markets Authority (FMA) and the Reserve Bank of New Zealand (RBNZ). The conduct of financial institutions (CoFI) regime, effective as of 31 March 2025, requires us to have a Fair Conduct Programme with effective policies, processes, systems, and controls, to ensure that we comply with the fair conduct principle.

What is the fair conduct principle?

In short, it means we need to treat our members fairly. This includes, but is not limited to:

• Paying due regard to consumers interests.
• Paying due regard to our members interests.
• Acting ethically, transparently, and in good faith.
• Assisting our members to make informed decisions.
• Ensuring that our services and products most likely meet the needs and requirements of our members (present and future) when viewed as a group.
• Not subjecting our members to unfair pressure, tactics, or undue influence.

What does this mean for your Employee Health Insurance Scheme

We, being Southern Cross, and you, as the employer, have entered into an arrangement for the purpose of administrating an Employee Health Insurance Scheme. This Scheme is for the sole benefit of your employees (our members), and it is agreed that we will not supply goods or services to you or your business as we contract directly with your employees (our members) for the purpose of providing them with private health insurance.

However, as we administer your Employee Health Insurance Scheme, it’s important we both adhere to the fair conduct principles. As such, we have outlined our respective roles and responsibilities below.

Our responsibilities

In addition to our obligations under our arrangement for your Scheme, we will:

• Ensure our products and services are suitable for our members (your employees) and are regularly reviewed.
• Provide the option for our members (your employees) to obtain personal financial advice anytime through our Nominated Representatives and/or Financial Advisers.
• Provide all communications in relation to a member’s (your employees and their family members if applicable) policy directly to the policyholder which includes, but is not limited to, renewal advice detailing new premiums, changes to our policy documents, change of concessions, prior approvals, claims information. All communications will be available through MySouthernCross on the Southern Cross website, or through the MySouthernCross app where the policyholder is registered for MySouthernCross.
• Provide notice to you as the employer, directly or via your Financial Adviser, of any changes to the Employee Health Insurance Scheme and or the policy that directly affect you as the Employer.
• Provide guidance and support on the administration of your Employee Health Insurance Scheme, including updating starters and leavers, and billing.
• Provide education sessions to our members (your employees) through a Southern Cross Account Manager, or your Financial Adviser as needed; either digitally, online, or in person – whichever is appropriate.
• Respond to complaints or disputes received from our members (your employees) in line with established timeframes.
• Respond appropriately to members (your employees) experiencing vulnerability.

Your responsibilities

In addition to your obligations under our arrangement for your Scheme, you will:

• Ensure that you do not provide any financial advice to your employees (our members). Health Insurance falls within the realms of financial advice, and in New Zealand anyone providing financial advice needs to be licensed with the FMA. You may provide factual information to your employees (our members), such as the name of your group Scheme, the plans available, the level of subsidy you’re providing, etc, but you may not make recommendations on which plan (if any) they should take up.
• Where we invoice you for premiums for your employees inform us/or your appointed Financial Adviser of any employee resignations or they are no longer eligible as soon as they’re received to ensure your employees (our members) are given sufficient time to arrange payment and/or transfer to a private membership (i.e., make sure they have the time and the opportunity to maintain their coverage with Southern Cross as they transition from your business).
• Only use sales aids, literature, and materials supplied by us or your Financial Adviser in the promotion of Southern Cross products.
• Direct your employees to contact us or your appointed Financial Adviser if they need:
  
  
  • Advice or have a query on their plan, benefits, and/or services.
  • Wish to make a complaint.
  • Wish to advise of any circumstance that are likely to increase vulnerability or difficulty in managing or using their coverage.
• Annually review, on the anniversary of your Employee Health Insurance Scheme, any/all collateral to ensure it correctly reflects the current arrangement. We will provide you/your Financial Adviser with any relevant updates at the time of your anniversary.
• Ensure that any new personnel who are appointed to look after your Employee Health Insurance Scheme have read and understood your responsibilities and have been sufficiently trained in the administration of your Employee Health Insurance Scheme.
• Comply with the fair conduct principle when promoting the benefits of the group scheme to employees.

Members Experiencing Vulnerability

It’s important that all our members are treated with care and respect and have a fair and reasonable opportunity to access the services that we provide.

We know that some of our members will have personal circumstances that mean they may be less able to make best use of their health insurance. In these situations, we recognise that we need to make additional efforts to ensure equality of access and care to such members.

Circumstances that may limit access might include:

• Health and physical factors – such as physical or mental health conditions.
• Language barriers – for example, where English is not your first language.
• Age-related issues – ranging from lack of access to technology to dementia or Alzheimer’s.
• Situational factors such as bereavement or other intense periods of personal stress.

We believe that every individual is different and has different circumstances. This means that as much as possible, we will respond to our members (your employees) as an individual in a way that is appropriate to their needs. Our customer-facing teams are trained to be aware of and respond appropriately to situations of customer vulnerability.

Our complaints process

Southern Cross is focused on providing support to our employer groups, and quality service to our members and have a complaints process and resolution Scheme to support that.

If you are dissatisfied with our service, you can raise a complaint directly with your Account Manager or Financial Adviser or by calling us on 0800 800 181.

If your employee is dissatisfied with our service, please refer them to our call centre on 0800 800 181, the Southern Cross online complaints form or to write to us at Complaints at Southern Cross, Southern Cross Health Society, Private Bag 99934, Newmarket, Auckland 1149.

We’ll acknowledge receipt of the member complaint within two working days or receipt (or as soon as practical after that time). If you or your employee are unhappy with our response, you can request that the complaint be reviewed by our Chief Operating Officer.

If our member is not satisfied with the outcome through our internal complaints process, we belong to the Insurance and Financial Services Ombudsman’s approved dispute resolution Scheme (IFSO). The IFSO is a free and independent dispute resolution service available to consumers that may help investigate or resolve complaints. For more information on our complaints process visit: www.southerncross.co.nz/society/contact/complaints 

Administering your Scheme

To ensure everything runs smoothly, where you, the employer, pays for health insurance, you need to let us and/or your Financial Adviser know when employees join and leave, so that we can:

• Invite them to join your Employee Health Insurance Scheme.
• Arrange continuation options if they’re leaving your employment.
• Ensure that premium payments are kept up to date.

Where premiums for your Employee Health Insurance Scheme are billed by invoice. The invoice, along with a schedule, is made available to your Scheme Administrator on our Work Scheme Gateway, with payment due 20th of the following month. If you do not have access to Work Scheme Gateway, these documents will be posted to you, but we do recommend that you sign up for Work Scheme Gateway if possible. Please see the section below for more information.

As most organisations have employees joining and leaving throughout the month, we capture these changes at an employee level, so that your organisation pays the correct premium for the period that each employee is eligible. There are a couple of steps to this process, and it’s important that your Scheme Administrator and Accounts Payable teams know where to access your Southern Cross invoices, and how and when to make payments, to ensure your Scheme doesn’t fall into arrears.

Work Scheme Gateway (WSG)
Work Scheme Gateway is our online tool to manage your Employee Scheme. It allows you to view, download, save or print your billing documents, where applicable. It also allows you to securely send payment files to us such as remittances and payment breakdowns, and you may also be able to use it to advise us of your new eligible employees.

Please request a detailed guide for Work Scheme Gateway from your Account Manager or Financial Adviser if you don’t already have one.

To request access or changes to your authorised Scheme Administrator, contact your Account Manager or Financial Adviser who will arrange for the Work Scheme Gateway access to be updated accordingly.

Billing and payment of premiums
On the 18th of the month an invoice for the subsidised amount charged for all policies under your Employee Health Insurance Scheme will be generated and made available on Work Scheme Gateway. On the last day of the month a Tax Invoice / Statement is generated and made available to you on Work Scheme Gateway. It’s important that your payment is made on the amount showing on this Tax Invoice / Statement as it captures all adjustments made to your Scheme during the billing period.

Payment is due on the 20th of the following month.

If further adjustments need to be made after the month end Tax Invoice / Statement, they will be captured and adjusted for in the following period. This way you can rest assured that with an ongoing wash-up your organisation will be billed the correct amount regardless of when employees join and/or leave your Scheme.

Legacy billing arrangement
If your Scheme has a legacy reconciliation payment method in place, your business will not receive an invoice. At your Scheme’s annual renewal, you will receive a schedule of all the employees in your Scheme and the premium required for each person. Payment is collected directly via your payroll office and then sent to Southern Cross.

Support is available
Talk to your Account Manager or Financial Adviser. Or contact our Premium and Policy Services team who can prepare a tailored detailed guide on billing, administration and payments for your Scheme.

Employee changes

New eligible employees
As noted in the administering your Scheme section, please advise Southern Cross or your appointed Financial Adviser within 30 working days of any employee becoming eligible to join your Employee Health Insurance Scheme.

This information is to be provided in the template and file format specified by Southern Cross and for each eligible employee shall include:

• Legal first and last name
• Work and personal email address
• Mobile phone number
• Date of birth

You may also be able to load your new eligible employees into the Manage Employees tab in Work Scheme Gateway. Talk to your Account Manager or Financial Adviser to find out more.

Employees no longer eligible
As noted in the administering your Scheme section, please advise Southern Cross and/or your appointed Financial Adviser within 30 working days of any Employee ending their employment or no longer eligible. Southern Cross will contact the Employee regarding continuing their Policy.

Please provide us with the following information for leavers: Employee first and last name, Policy number, and their last date of employment.

It’s important to note that we can only backdate removal of a policy from your Scheme back to a maximum of 30 days.

We (Southern Cross) are focused on good outcomes for our members, and we need your help to deliver these outcomes. If you have any questions or concerns or would like to discuss anything in this document, please contact us.