Marketplace

Our vision is to be the best partner for our customers' lifetime financial needs.

Excellent Customer Service

As a company, Eagle Star has a strong commitment to customer excellence in the marketplace. Eagle Star believes that providing superior value and outstanding service to customers is central to the future of its business. The main marketplace stakeholder for Eagle Star is insurance brokers and intermediaries. The company has won the IBA Service Excellence Award a record nine times (including the most recent award) and the inaugural PIBA Broker Service Award of Excellence in 2003. At the most recent IBA awards, Eagle Star was also named as providing the 'Best Pension Service' and 'Best Life Assurance Service'.

To achieve this high level of service, our customer support areas are divided into specialist and highly focused teams. Each team is a single point of contact and has ownership and responsibility for a complete and personalised service to our customers. We have an experienced and expert staff that care about what they do and are committed to continual training in technical expertise and servicing skills.

Findings of the Broker Service Excellence Surveys Overall Service Analysis

Source: IBA Service Excellence Survey 2003

The above graph indicates how well Eagle Star has performed relative to the best in the marketplace and the market average in 2002 and 2003.

With an overall score of 61.81% (61.55% in 2002) Eagle Star outperformed the market average of 57.87% (57.92% in 2002). This result established Eagle Star as the number one service provider in the market.

Eagle Star finished first place overall, improving its ranking from third in 2002.

PIBA carried out their first Broker opinion survey in 2003, with Eagle Star coming top. Eagle Star particularly shone in the areas of online service, broker support and product development.

Insurance Company	Score (Scale of 1 to 7)
Eagle Star Life (1st position)	4.85
Average of other companies	4.06
Source: PIBA Service Survey, Nov. 2003

LIMRA conduct a broker opinion survey every year which provides the company with valuable data such as the frequency with which brokers visit websites of life companies, the products and services they rate highly and how the various companies are perceived in terms of quality or innovation.

Eagle Star finished in second place overall in the LIMRA Survey in February 2004 and climbed one place in the LIMRA rankings with significant improvements across the board.

LIMRA Survey: Eagle Star Company Profile

Company Quality	2004 Position	Change in score from 2003
Modern	1st	+14
Caring	4th	+4
Innovative	1st	+16
High Quality	2nd	+9
Successful	3rd	+11
Safe	6th	-3
Dynamic Range of Products	1st	+14
Traditional	8th	-1
Bureaucratic	=6th	-3
Unhelpful	=6th	-1
Impersonal	7th	-2

Customer Solutions

We also attribute our service success to the fact that we recognise that each of our external Stakeholders; intermediaries, trustees of pension schemes, members of group schemes or individual clients, all have different needs. Eagle Star aims to go beyond 'customer administration' and provide a 'customer solutions' service. In other words, we listen to our customers. We deliver core key services as standard and within pre-agreed timescales. This means we can honestly say that we deliver on our promises. Personalised service, efficient customer management and accurate record keeping are all part of a normal working day at Eagle Star. In fact, as part of our customer service initiatives, in 2003 Eagle Star set up a dedicated business retention area with the sole objective of retaining customers.

We are also good at creating relationships with key customers or customer groups e.g. An Post and the Irish Medical Organisation.

"The speed and manner in which you were able to process this request was exceptional. I have always held Eagle Star Life in the highest regard and this no doubt, is due to the professionalism of special people like yourself."
Compliment from Broker to Customer Service Team Member

The majority of Eagle Star's business is generated through insurance intermediaries. Business is transacted by a qualified financial advisor within the insurance brokerage who provides the customer with appropriate advice and ensures a product that best suits the personal circumstances, needs and objectives of the customer is recommended.

Eagle Star also has important customer safeguards in place. For example, in line with Eagle Star's documented internal complaints procedure, the customer service area collates complaints across the organisation and monitors them on a weekly basis to identify any trends which need to be resolved or where customers have raised issues which need to be addressed. This continuing measurement process also helps towards the business objective of reducing customer complaints. We are fully compliant with the IIF and IFSRA codes of practice in this area, and are further fully committed to reducing the response time to complaints. Currently the company has a policy of addressing a customer complaint within three working days and we also endeavour to improve the quality of responses to complaints.

In order to ensure that any customer who complains obtains a quality response, all complaints are referred to customer service supervisors and all written responses are approved at a senior level. This is part of our standard complaints management procedure.

In addition, as part of our CR commitment, we now have a procedure in place for collating unsolicited letters of endorsement from customers and use these, not only as a staff motivator but also to identify positive trends about initiatives that work well and can be adapted on a wider basis across the organisation.

"Great job! I wish other insurance companies had updates as good as these!"
Compliment from Broker to Customer Service Team

Business Integrity

All business activities are based on the fundamental principle of observing the highest standard of integrity at all times. Eagle Star's reputation for professionalism, reliability and integrity is one of its most important assets. All employees are expected to maintain high ethical standards in their dealings, follow good business principles and avoid practices which might damage the company's reputation.

Eagle Star is a member of Zurich Financial Services Group, an insurance-based financial services provider with an international network. Founded in 1872, Zurich is headquartered in Zurich, Switzerland. It has offices in more than 50 countries and employs approximately 62,000 people. As part of Zurich Financial Services, the Eagle Star management team and employees in key positions in the company sign off each year to acknowledge their acceptance and adherence to Group compliance standards and core values.

The Group's core values and basic principles

Key Words	Principles
value & trust	we are passionate about building value and trust
what's required and right	we act lawfully and seek to do what is right
drive and fairness	we play vigorously but fair
respect	we treat others with respect
responsibility & accountability	we take personal responsibility
wise and prompt decisions	we make decisions using the right standards
social contribution	we are good corporate citizens

The Group's General Compliance Rules are an important part of Zurich's shared commitment to corporate responsibility. They apply to employees of Zurich Financial Services, its subsidiaries, like Eagle Star, and affiliates. A revision to this practice within the last year requires any employee serving as a director or officer, at the request of Zurich, in any non-Zurich company to disclose the relevant details. Each employee has a responsibility to maintain the trust placed in the company by its customers, shareholders, business partners and other employees and to protect confidential data relating to them. Such information must be safeguarded.

A written policy is in place in relation to an employee's disclosure of gifts and benefits in kind and has been communicated to all staff. This policy is important because we believe in competing based on the quality of our services and the value we offer to our customers and not on the basis of entertainment or gifts. Therefore, all staff are made aware that they should avoid situations in which their personal interest could lead to conflicts with their duties.

Eagle Star does not give or accept any improper payments or gifts.

Eagle Star also has a strict money laundering procedure in place, which is based on the money laundering guidelines issued by the Irish Insurance Federation (IIF). This procedure continues to be kept up-to-date, reflecting any changes to the IIF's money laundering guidelines. It is communicated to all staff and managers are fully briefed in this area.

Eagle Star values our customers but never assists any customer, no matter how profitable in any illegal activity.

Eagle Star has in place a specialist compliance function, which ensures that all independent intermediaries, who sell Eagle Star products, are regulated and authorised by the Irish Financial Services Regulatory Authority ('IFSRA'). This ensures greater professionalism and that customers are satisfied and will trust Eagle Star products now and in the future. All intermediaries have standard agency agreements with Eagle Star, which are cancelled in the case of non-compliance.

The Irish Financial Services Regulatory Authority ('IFSRA') was established on 1 May 2003 and is responsible for the regulation of all financial services firms in Ireland. IFSRA's mandate is "to protect consumers by helping them to make informed financial decisions in a safe and fair market, with sound financial institutions." Since its establishment, IFSRA has issued a code of conduct for compliant sales by insurance undertakings and Eagle Star's compliance function has been expanded to now advise on and monitor sales by its direct sales force and tied agents, to ensure compliance with these requirements.

Eagle Star issues all its customers with informative product guides to ensure that they make an informed purchase decision. Customers have an opportunity to cancel their policy within 15 days of receipt of policy documentation, if they feel it does not meet their needs. The company also has internal business procedures in place to help advise customers who might let their policies lapse and could be at risk of losing valuable financial protection.

Investment Security for our Customers

When people make an investment with Eagle Star, they want investment performance and security. We deliver these twin objectives through our investment strategy and investment management processes. The objective of Eagle Star's investment strategy is to achieve above average investment performance each year while carefully managing risk. By doing so we expect to produce top quartile performance in the long-term.

Controls & Investor Safeguards

Eagle Star provides good customer and investor safeguards through the operation of a
Front Office, Back Office system. For example, there is clear segregation of duties between the investment dealing area and the cash settlement and accounting and reporting functions.

To ensure independence and give extra security to our clients, Eagle Star chooses to use an external custodian who is not part of the Eagle Star or Zurich Group. Eagle Star uses Citibank as custodian across all funds managed by Eagle Star. We believe that holding securities at a third party custodian is best practice in this key area.

Eagle Star acts lawfully and seeks to do what is right.

Financial Dealing - Arms Length Relationships

Eagle Star maintains a list of approved financial institutions with whom we conduct banking business. This division of deposit and foreign exchange dealing among a panel of financial institutions ensures that risk is reduced by keeping within acceptable exposures to different financial institutions and thus protecting the funds.

Similarly, we maintain a panel of stockbrokers with whom we may transact share dealing and bond dealing business. The panel consists of Irish and international stockbroking firms and financial institutions.

To ensure independence we do not use banks or stockbrokers that are part of the Eagle Star or Zurich Group. By undertaking our financial dealing activities with institutions who have no direct relationship with Eagle Star we ensure that we always receive competitive rates on behalf of our customers.

Eagle Star avoids and discloses potential conflicts of interest.

Advertising

Eagle Star complies with the standards laid down by the code of Advertising of Standards Authority for Ireland (ASAI) for all its advertising. The ASAI has never issued an investigation into Eagle Star's advertising. Eagle Star also adheres to the guidelines for advertising and sales material as set down by the Irish Insurance Federation.

Eagle Star makes decisions using the right standards.

Safeguards for our own business

A business recovery plan is in place and is regularly updated in order to understand the crucial risks and exposures of the company and is designed to ensure a rapid response to any situation that may disrupt operations or control of the business.

Supplier Support

Eagle Star has in place a policy for payment of all bills within 30 days. As a member of IBEC we have signed an agreement for a code of practice on 'Prompt Payments'. The code is designed as a voluntary mechanism to promote good business practice in respect of accounts settlements. The Prompt Payment Code has been incorporated into our existing procedures and it requires that we:

• Have a clear and consistent policy to pay bills in accordance with contract.
• Ensure that the finance and purchasing departments are aware of the policy and adhere to it.
• Agree payment terms at the outset of a deal and stick with these terms.
• Do not extend or alter payment terms without prior agreement.
• Provide suppliers with clear guidance on payment procedures.
• Ensure that there is a system for dealing quickly with complaints and disputes and advise suppliers without delay when invoices, or parts of invoices are contested.

The Eagle Star accounts department has put in place procedures to ensure that we adhere to the code of practice for 'Prompt Payments'. This ensures that we have no major issue with suppliers with regard to payment of bills.

Marketplace Summary

In terms of financial products Eagle Star Life is renowned for innovative product design and delivering a quality product. We have investment management processes that provide investment security in a sound and ethical manner. We plan to continue to maintain our position in the market as the leading service provider.

Over the next year, we plan to:

• Continue to improve customer communication and make our customer literature as clear and understandable as possible.
• Continue our progress towards customer solutions and not just products.
• Continue to put in place better intermediary stakeholder measures.
• To monitor and continually reduce the number of complaints received on an annual basis.
• Continue to adhere to the code of practice for 'Prompt Payments' as part of our normal business practice.