Code of Conduct

1. Purpose

This Code of Conduct outlines the standards of behaviour and professional practices expected of all employees, contractors, and representatives of Comparable. It is designed to ensure that all interactions with customers, partners, and stakeholders are conducted in a manner that is:

• Honest and transparent
• Customer-focused
• Compliant with applicable laws and industry standards
• Consistent across all service verticals

This Code applies across all Comparable services, including: Energy, Telco, Health Insurance, and Finance.

2. Relationship with Industry Codes

Comparable is committed to complying with all applicable laws, regulations, and industry codes, including:

• The Privacy Act 1988 (Cth)
• Australian Consumer Law
• National Consumer Credit Protection Act 2009 (Cth)
• Energy Retail Codes and Guidelines
• Telecommunications Consumer Protections
• Private Health Insurance Intermediaries Association (PHIIA) Code of Conduct

This Code of Conduct is intended to support and complement these obligations. Nothing in this document is intended to limit, replace, or override any obligations under applicable laws or industry codes. Where there is any inconsistency, the stricter requirement will apply.

3. General Principles

All representatives of Comparable must:

• Act honestly, fairly, and professionally
• Prioritise the best interests of customers
• Provide clear, accurate, and not misleading information
• Ensure customers are able to make informed decisions
• Maintain confidentiality and protect customer information
• Comply with all internal policies and external regulatory requirements

4. Customer First Approach

Comparable is committed to delivering a customer-centric experience. We will:

• Take reasonable steps to understand each customer's needs, objectives, and circumstances
• Provide recommendations that are appropriate and relevant
• Avoid high-pressure or misleading sales practices
• Clearly explain product features, benefits, risks, and limitations

Customers will always be given sufficient information to make an informed decision.

5. Health Insurance Conduct (PHIIA Alignment)

When providing health insurance comparison and advisory services, Comparable will:

• Act in a manner consistent with the principles and intent of thePHIIA Code of Conduct
• Ensure that information provided is accurate, clear, and not misleading
• Clearly disclose our role as an intermediary and how we are remunerated
• Obtain explicit consent before collecting or using sensitive health information
• Respect customer privacy and handle sensitive information with heightened care
• Ensure that recommendations are based on customer needs and preferences, not remuneration

Comparable representatives must not: Misrepresent products, provide advice outside their level of training, or use coercive sales practices.

6. Transparency and Disclosure

Comparable is committed to transparency in all customer interactions. We will:

• Clearly explain our role in each vertical
• Disclose how we are remunerated
• Inform customers where third parties are involved
• Provide access to relevant documents, including: Privacy Policy, Remuneration Disclosure, and Credit Guide (for finance services)

7. Data Privacy and Security

We will collect only information that is necessary and relevant, obtain appropriate consent (particularly for sensitive information), protect customer data through appropriate security measures, and comply with all obligations under the Privacy Act and APPs.

8. Sales and Conduct Standards

All representatives must engage respectfully and professionally, clearly identify themselves and Comparable, inform customers if calls are recorded, follow approved scripts, and ensure all required disclosures and consents are obtained.

9. Training and Competency

Comparable ensures that all staff receive appropriate initial and ongoing training, are assessed for competency before engaging with customers, and are kept up to date with product, regulatory, and compliance changes.

10. Complaints Handling

Comparable is committed to handling complaints fairly and efficiently. We will acknowledge complaints promptly, investigate thoroughly, provide clear and timely responses, and use feedback to improve our services.

11. Monitoring and Compliance

Comparable maintains robust compliance processes, including quality assurance reviews of customer interactions, ongoing monitoring of sales and advice practices, internal audits, and corrective actions where required.

12. Conflicts of Interest

Comparable takes reasonable steps to identify and manage conflicts of interest. We work with a panel of providers, ensure staff focus on customer suitability, and maintain separation between remuneration structures and customer recommendations.

13. Breaches of This Code

Any breach of this Code of Conduct may result in retraining, disciplinary action, or termination of employment or engagement. Serious breaches may also be reported to relevant regulatory bodies.

14. Continuous Improvement

Comparable is committed to continuous improvement. We will regularly review this Code of Conduct, update policies in line with regulatory changes, and incorporate feedback from customers and partners.

15. Contact

Comparable (Ethical Prospecting Pty Ltd)

• Email: it@comparable.com.au
• Phone: 1300 754 155

16. Version Control