2.1 Background

At the time of the sixth round of hearings, Freedom Insurance Group Limited (Freedom) marketed and distributed life insurance products directly to consumers by telephone. The case study examined Freedom’s sales and retention practices, both generally and in relation to an individual consumer. The Commission heard evidence from Mr Craig Orton, Freedom’s Chief Operating Officer.[1] The Commission also heard evidence from Mr Bruce Stewart, whose son was sold an insurance policy by Freedom in June 2016.[2]

At 3pm on 10 September 2018 – the first day of the sixth round of hearings and the day before Mr Orton was due to give evidence – Freedom notified the Commission of substantial changes to its business model.[3] Freedom told the Commission that it intended to cease selling all insurance products, except funeral insurance and loan protection cover, through outbound sales calls.[4] While Mr Orton accepted that this was a significant change to Freedom’s business model, Freedom was not able to produce any documents that directly recorded this decision.[5] I mention this not for the purpose of suggesting that Mr Orton’s evidence should be disbelieved,[6] but because I consider it remarkable that a decision of this kind would not be documented by a publicly listed company. Publicly available documents indicate that, after the Commission took evidence from Mr Orton, Freedom determined to suspend all direct sales of life insurance through outbound telephone calls.[7]