Additional Comments/Dissenting Report from Hon Andrew Gee MP, Independent Federal Member for Calare
The Committee has worked in a commendably co-operative and productive way with respect to this inquiry.
I support the recommendations made in the main report.
However, I believe that more recommendations are needed.
This additional report should be viewed as a supplementary opinion to the main report.
Reforming the insurance industry is a significant undertaking. While the main report incorporates many recommendations and amendments which I suggested, there are further recommendations that can be made to facilitate change to this industry which is so badly and obviously needed. Those additional recommendations are included in this supplementary report below.
Throughout the course of this inquiry the Committee has heard evidence from policyholders about their treatment by insurers that is deeply disturbing and disgusting.
The debilitating effects this has had on traumatised policyholders is tragic.
It must be stopped.
The storms and floods that hit central western New South Wales in November 2022 were catastrophic and devastating for our region and its residents.
Two lives were tragically lost in Eugowra which was the scene of the largest helicopter rescue in Australia’s history.
Across the communities of our region, including Eugowra, Molong, Cudal, Canowindra, Manildra and Wellington, infrastructure, homes and businesses were destroyed. The stress, fear and anxiety amongst our local residents from not only having survived the ordeal of their lives, but also facing an uncertain future, was palpable.
When disaster struck, our residents naturally turned to their insurers for help, and issues arose almost immediately.
For example, NRMA had been the insurer of choice for many local residents in Eugowra yet, in the immediate aftermath of the disaster, many residents reported problems in being able to talk to claims personnel. It took the company ten long days after the disaster to arrive at Eugowra Showground with a mobile claims unit to assist homeless residents. This was a source of anger amongst residents which grew stronger as the response to the disaster unfolded.
As the exhausting days of recovery wore on, problems with insurers just grew and grew.
I held public meetings in our electorate of Calare where residents were able to tell and share their stories.
It was empowering. Residents noted striking similarities in the way in which insurers were treating their policyholders.
These included: policyholders not having key provisions in their insurance contracts explained to them; claims processing being unnecessarily dragged-out; sub-standard and inconsistent expert reports; shoddy treatment by contractors and insurance company representatives; claims being unnecessarily knocked back; and policyholders being offered and accepting “low-ball” cash settlements because they were too exhausted to fight anymore.
It was clear that the rebuilding and recovery process has been made much harder, and the tragedy much worse, by the cold-hearted and shocking response of insurers to policyholders.
There were so many issues being raised about insurers that local residents and I began calling for a parliamentary inquiry.
To the credit of the government, it called one. The announcement for this inquiry was made, appropriately, at Eugowra, in July 2023.
This inquiry soon revealed what we in the central west of New South Wales long suspected – that the experiences of our residents were not unique and that many other Australians had been through the same insurance ordeal when faced with natural disasters.
For the first time a real spotlight has been put on the industry, and what it has revealed are unconscionable and systemic industry failures that exist at every step of the insurance process.
The evidence taken by this inquiry amounts to a withering and damning indictment of the insurance industry. While some in the industry may be ashamed of it, I suspect many are not.
Communities like Eugowra are a long, long way from the boardrooms of capital cities.
While not every insurance company did the wrong thing, the hell that a number of these large insurers have put policyholders though should not be sugar-coated.
Words should not be varnished when describing it.
The narrative put forward to this inquiry by the Insurance Council of Australia and a number of insurers was, in effect, that the floods of 2022 were unprecedented. This and other excuses such as poor planning decisions since the time of Governor Macquarie and European settlement, COVID, labour shortages and the war in Ukraine, all resulted in some customers having poor experiences.
Examples of this attitude and these excuses are littered throughout the written submissions and oral testimonies of insurance industry and company representatives.
But as we know, major natural disasters are not new to Australia or insurance companies.
There is simply no excuse for what a number of these corporations did to their policyholders and the Australian public should not let these insurers get away with this arrogant spin.
When insurance company representatives came to give evidence before this inquiry there appeared to be a complete lack of insight on the part of some of them as to the pain and suffering they had inflicted upon their own customers.
Notwithstanding that an army of public relations consultants had no doubt prepared many insurance company representatives for their appearances before this inquiry, in some cases getting apologies and acknowledgments for the living hell they had put their customers through was like pulling teeth.
As I have said, some insurers did do the right thing and some did genuinely try and assist residents in our area, but the fact remains that the industry giants clearly do not like the spotlight being put on industry practices or the healthy profits that they continue to enjoy.
This profitability has come as a high cost to many of their fellow Australians.
The reality is that the Australian insurance industry has had a good thing going for a long time.
It has donated to both sides of politics. It’s a strategy that has served it well.
In the midst of healthy profits, it has been left to largely self-regulate.
Insurance companies don’t just answer to shareholders they also answer to the nation. They don’t just have insurance contracts with our residents and businesses, they also operate with a social license.
The Australian public needs to be vigilant and not be afraid to revoke their licenses to operate when egregious behaviour comes to light. This Inquiry has exposed plenty of that.
The evidence from policyholders about their callous treatment at the hands of insurers was truly shocking.
Ms Kirsty Evans is a solicitor from Molong, New South Wales, whose firm in Orange carried out free legal work for numerous vulnerable clients as they struggled with insurance companies. She gave evidence about one of her clients, Mr Tracy Scott:
Mr Scott paid his insurance premiums and had his claim accepted by the insurer, however some 18 months later he is still battling to return to his home. He is a vulnerable customer and his vulnerabilities are well-known to the insurer. In circumstances where the insurer failed to communicate properly with third-party suppliers, Mr Scott is reliving his trauma all over again by having to explain himself and continues to fight to be believed by his insurer. He is now experiencing stress and ongoing trauma at the hands of his insurer.[1]
…
Tracy had been paying significant premiums to GIO for coverage of over $1 million during the life of his policy. His claim was accepted without issue. However, the Building Contractor GIO sent to undertake the strip out and rectification works did not meet professional standards and caused further damage to his property. The initial builder damaged the concrete slab with jack hammers, damaged wooden window sills, cracked tiles in the bathrooms, threw tiles and rubble down the drains leading to additional plumbing work, destroyed the rockery garden, and dumped building rubble and old carpet in the garden beds and lawns, so Tracy couldn’t mow.[2]
Significantly, when Tracy tried to tell GIO about his concerns with the initial builder, he was accused of lying….[3]
He has said to us that he felt he had been “fobbed off as old and stupid” before our involvement. It was not until after this inspection, 10 months after the flood, that Tracy’s claim was referred to a “Specialist Customer Care Team” due to his vulnerability. Why this had not been identified earlier remains unexplained.[4]
Tracy was diagnosed with internal bleeding in early February 2024, resulting from ulcers caused by stress. Tracy is convinced that the significant stress since the flood event, living in a caravan for 18 months, and dealing with the insurance claim and builders, has caused his medical condition. The chronic illness and pain have a significant impact on his mood and his ability to manage his PTSD. He underwent surgery on 6 May 2024.[5]
Ms Heba Elkurdi, owner of a gym in Molong that was destroyed in the floods, stated:
My experience with the insurance company was very confusing and emotionally distressing.[6]
And then dealing with the insurance was a bit of a shock to me. I just didn't expect it to be so inconsistent. For me, the biggest thing was there was no concrete process. Dealing with the insurance was total confusion. I had no idea where I stood. I had loans and banks chasing me, memberships that I owed to members, and not know where I stood with that. How do I move forward?[7]
You tend to repeat yourself. It is quite a traumatic experience. Yes, it's just something you don't really need to go through after losing everything, but then not having the security after you've paid the premiums and you think you had security. You're pretty much out there on your own going, 'What do I do now if I lose everything?' It's pretty scary to be put in that position. Definitely case management and better understanding, and that one point of contact would have made things a lot more straightforward for me.[8]
Ms Kirsty Evans gave the following evidence about the experience of one her clients, Molong business owner, Ms Sarah Bone:
But the continued delays, the lack of service providers in providing realistic quotes, and then the unwillingness of the service provider to actually do the work after the quote was provided caused significant delays, which means the time period for her business interruption had expired. Plus she was receiving a penalty. It's a circumstance where NRMA failed her at every level. They failed her at every single point of her claim. Her experience is why I'm here—and collectively for everyone as well—but Sarah's experience should not have to occur. It shouldn't be, 'That's one. It's enough. We accept that errors happen.' Sarah's experience should not happen to anyone ever. The insurance industry let her down.[9]
Mr Phillip Davis, who had his home destroyed in Molong gave evidence of repeated “low-ball” offers of settlement made by his insurer:
Every time you turned around, they'd lowball you an offer. The first was $96,000 to rebuild the house, and we said no. The next one was $114,000, from memory, and I said, 'If you can build the house and repair it for that cost, you come and do it, because there's no way in the world'—the couple of people I got to quickly walk through and have a look were estimating 300 grand alone, just to fix the house back up to where it was.
Then it went stagnant and nothing happened for months. You'd ring them and there'd be nothing.[10]
Mr Davis’s wife, Ann-Maree, gave evidence of the tactics used by insurers to secure a cash settlement:
They rang me. Phillip's been looking after all of the contact with the insurance company, but they rang me one day and said that they couldn't contact Phillip and they'd been trying for days. I said, 'No, that's a lie, because he's always got his phone on him.' I think they were trying to get me to agree to something, without Phillip knowing, because I was at work and Phillip was at work. I was like, 'No, you need to ring him. Don't talk to me. I'm not accepting anything without him knowing.'[11]
After a public spotlight was put on the Davis’ case, the insurer agreed to build a new house which was what Mr and Mrs Davis were entitled to under their policy.
Ms Kaylene Philpott, Owner, Director and Manager of Molong Post Office and Newsagency described the stress of arguing with insurers about what was flood damage (not covered) and what was storm damage (covered) stating:
We first lodged our claim—we waited—it was back in the December. Come February, I got a phone call at about midday saying, 'We can't help you. This is all flood water; you're not covered for flood. You've got no insurance.' With that, I went to pieces, shut the shop and said, 'I'm not going back near the place.' I took the afternoon. I just went home and I think I cried all afternoon. We'd put our hearts and souls into the business.[12]
Then we had a building assessor come out, and they did a scope of work on our building. They came back with a ridiculous offer of like $20,000, and we just went 'no way'. We replaced one counter in August 2022, and it cost us $20,000. That's just one counter.[13]
Mr Brian Smith and Mrs Lesley Smith had their house in Eugowra destroyed. They were denied their claim for footings despite evidence of a log smashing into the side of the house and nearby homes being picked up by the floodwater and floating away. They were further denied a claim for roof repairs despite evidence of a rescue helicopter hovering above it for 15 to 20 minutes with the rotor downwash causing it to sag.
The Smiths were then subjected to months of low-ball cash settlement offers from their insurer while their house sat vacant on their property in a decaying, mouldy state.
Mrs Lesley Smith, stated at the inquiry’s public hearing in Eugowra:
It took 14 months of media coverage, help from Mr Gee and Legal Aid to finally get a settlement. While we are very grateful for the help and support, it should not have come to the point where this was needed. At no stage through the whole process were we offered a builder to come and fix our home; it was always a cash settlement. Our home has just been demolished and we are hoping to be in our new home before Christmas. We struggle to understand why the process took so long to settle and why things were refused due to the age of the building. When you take out insurance, you are asked when the house was built. If they have no intention of paying the full policy, why charge such high premiums?[14]
Mr Smith added:
You'd explain the same thing over and over again to a different person. Instead of being given to one person to handle your case, you'd be ringing up and getting someone different, so you'd have to explain the whole thing again and then be put on hold while they checked into it. You could be on the phone with them for two or three hours, and that's wrong.
It's been incredibly stressful. You're put through a lot of stress for no reason. How hard is it? We pay our premiums and we're in a contract with the insurance company and, when it comes time for them to honour their side of it, they don't.
It's stressful. Not only that; after our house was declared unliveable and we can't do anything with it, they're still taking premiums from us.
From the time we put the initial claim in to when we cancelled it, the house was unliveable; it was full of mould. They haven't offered to have it rebuilt for us, which is part of their deal—payment or get it rebuilt—so they haven't lived up to their part of the contract, as far as I'm concerned. It's hard to explain. It makes you very angry.[15]
Mr Hugh Ellis of Eugowra gave this evidence:
Although we cancelled this policy, they continued to take our monthly premium for five months. They sent us a policy renewal notice, despite our policy having been cancelled. They would not return our calls or answer our emails. We were shocked at the lack of respect shown to us after being loyal customers for nearly 40 years—where we paid hundreds of thousands of dollars to them during our time as farmers and didn't make a claim. Everything is set up in the insurer's favour. We understand that insurance companies are businesses and that they need to make money, but we would ask them to understand that we're not just a policy number.[16]
Mr David Norris said this of his family’s experience in Eugowra:
… we've had 63 years of consecutive insurance with NRMA, both the house and the hotel… 63 years is loyalty to a business. Loyalty only goes one way, and I think the townspeople of Eugowra have witnessed that firsthand.[17]
Mrs Carole Shennan, Senior Support Worker, Disaster Relief and financial councillor, CatholicCare, Wilcannia-Forbes gave this evidence at Eugowra of trauma-hit policyholders:
What we see sitting in front of us, straight from the early stages—and it is still happening now—is there are lots of tears and lots of emotion. These people have been through an absolute disaster, and it has been extremely traumatic. A lot of people thought they were going to lose their life on that day. That's a huge life-changing event. And then to make a phone call to an insurance company, and just to be told straightaway that you're not covered for flood.
They're of the years where there's trust and you expect people to have your back. As soon as they make the claim, they're told 'no'; that they didn't understand what was in their policy at all. It's never been explained to them.
As far as we know, no insurance companies have rung any clients to see how they are. There's only one insurance company that we know of that has ever done that.[18]
Mr Sean Haynes, a Eugowra homeowner, stated at the same hearing:
I do believe that all insurers need to start listening or supporting their policyholders. When a policyholder goes to them, it's in that policyholder's time of need and it's about ensuring they respond with respect and dignity to ensure the policyholder is appropriately managed and dealt with through that time of need. What we've all seen is that policyholders are being treated poorly in response to their making a claim, and that's not why we take insurance. We believe that there's a backstop there, and that's why we take insurance out, to provide that level of reassurance…but when you're then placed in this situation that loyalty and trust you have with them disappears.[19]
As the testimony above highlights, the flood and storm events of 2022 were devastating for thousands of residents and businesspeople. Lives, homes and livelihoods were all tragically lost.
The toll taken on physical and mental health has been immense.
The reality is that there is a massive power imbalance between policyholders and insurance companies. This inquiry has exposed it.
At the end of the day, if a policyholder wants to fight a knock-back from an insurer, they’re going to have to fork out big dollars for an expert hydrology report, a building report and a solicitor. If you’ve lost everything or your business is in ruins, there is just no prospect of fighting back.
This imbalance and disparity needs to be corrected. Change is clearly needed.
This Inquiry and reports need to be a pivotal moment in the way that insurers deal with disaster hit policyholders because one certainty that we have is these natural disasters will keep occurring.
I wish to thank all who gave evidence to this inquiry.
For many having to re-live the trauma they suffered has been very difficult.
It is my hope that by telling their stories, collectively they can be a catalyst for long-overdue change and reform to this industry.
I also extend a heartfelt thank you to the countless unsung heroes around our nation who risked their own lives to save others during these devastating disasters, and also to those who worked with such care and compassion to help so many to rebuild their lives and recover from such tragic loss. This work continues to this day.
We were privileged to meet many of these great Australians over the course of this inquiry and their kindness will never be forgotten.
Change to the insurance industry simply must happen. One issue that stands out is the need to reform the provision of sub-standard and over-priced “expert” reports which are plaguing the industry, but there are many more.
Some reforms which I support have been recommended by other bodies. For example, I am broadly supportive of the recommendations of the Independent Review of the General Insurance Code of Practice as they relate to hardship.
Further recommendations are set out in this supplementary report below.
Recommendation 1
That the Insurance Council of Australia introduces a Code of Conduct for Assessors and Experts which would include provisions that the expert:
(a)has read the Code of Conduct and agrees to be bound by it;
(b)must exercise their independent, professional judgement in relation to the issues the subject of the report;
and that an expert’s report must identify:
(c)the expert’s qualifications as an expert on the issue, the subject of the report;
(d)the facts, and assumptions of fact, on which the opinions in the report are based;
(e)the expert’s reasons for each opinion expressed;
(f)any literature or other materials utilised in support of the opinions;
(g)any examinations, tests or other investigations on which the expert has relied;
(h)what damage occurred to the property;
(i)what reasonable maintenance has not been undertaken by the consumer;
(j)whether the failure to maintain would have made a significant difference to the outcome and damage sustained to the property; and
(k)where applicable, explain the causal link between the failure to maintain and how that resulted in a material contribution to the damage sustained to the property.
Recommendation 2
That the requirement to abide by the above-mentioned Code of Conduct for Assessors and Experts be stipulated in the General Insurance Code of Practice and that this Code of Conduct also be annexed to the General Insurance Code of Practice.
Recommendation 3
That in addition to the establishment of an expert panel of hydrologists referred to in Committee Recommendation 7, a scheme be established by the Australian Government and insurers that provides for policyholders to access funds to pay for expert building reports when disputes are escalated to the Australian Financial Complaints Authority.
Recommendation 4
That external experts and third parties involved in the claims settlement process, such as cleaners and removalists, be included in the “Service Supplier” definition of the General Insurance Code of Practice.
Recommendation 5
That the General Insurance Code of Practice be amended to provide that external experts should not be permitted to make recommendations on claims decisions unless they are suitably trained and qualified claims assessors.
Recommendation 6
That the General Insurance Code of Practice be amended to provide for insurers applying greater control and oversight of the performance of building contractors, assessors and experts and the reports they prepare.
Recommendation 7
That insurers be required to update the current cash settlement factsheet with input from consumer advocates to include detailed information in plain English regarding the advantages and disadvantages of accepting a cash settlement and that this be incorporated into the General Insurance Code of Practice.
Recommendation 8
That the General Insurance Code of Practice be strengthened to provide a clear framework for the offering and acceptance of cash settlements including the information and clarity that policyholders need to fully understand the significant implications of, and risks associated with, cash settlements.
Recommendation 9
That paragraph 90 of the General Insurance Code of Practice should be amended to exclude cash settlements.
Recommendation 10
That the General Insurance Code of Practice be amended to stipulate that an insurer must provide a complete breakdown (un-redacted) of the costs covered by a cash settlement in a cash settlement offer.
Recommendation 11
That the General Insurance Code of Practice be amended to provide that when making offers of cash settlements, insurers are required to take into account the higher cost of labour and materials after disasters.
Recommendation 12
That the General Insurance Code of Practice be amended to oblige insurers to ensure that the quotations being relied upon in cash settlement offers are clearly understandable and transparent for policyholders.
Recommendation 13
That insurers be required to accommodate the preferred communication mode nominated by a policyholder during the claim processing period.
Recommendation 14
That in the event of full or partial denial of a claim, insurers be required to provide to the policyholder the reason(s) for the denial and a copy of the evidence relied upon for the denial.
Recommendation 15
That the General Insurance Code of Practice be amended to provide that:
Recommendation 16
That Paragraph 81 of the General Insurance Code of Practice be strengthened by defining what amounts to sufficient reasons for a full or partial denial of a claim and requiring insurers to clearly explain their decisions in clear, plain English, rather than just referring to Product Disclosure Statements.
Recommendation 17
That paragraph 81 of the General Insurance Code of Practice be strengthened to guarantee that claims decision communications automatically include copies of assessment and expert reports that the insurer has relied on when making the decision.
Recommendation 18
That the General Insurance Code of Practice stipulates a timeframe in which an insurer must make a settlement offer on an accepted, or partially accepted, claim.
Recommendation 19
That the General Insurance Code of Practice be amended to stipulate a timeframe for an insurer to commence actioning repair/recovery work on an accepted claim.
Recommendation 20
That the General Insurance Code of Practice be amended to provide that insurers be required to move complex claim applications or claim processes unresolved after a reasonable period to a case-management system and further that the period referred to is clearly defined in the General Insurance Code of Practice.
Recommendation 21
That Paragraphs 70 and 146 of the General Insurance Code of Practice be strengthened to:
Recommendation 22
That insurers better resource and train employees to communicate with consumers in a transparent manner, clearly informing them on when their claim will be assessed and how their claim is progressing.
Recommendation 23
That Australian Security and Investments Commission’s (ASIC) 2022 letter outlining its expectations of insurers with respect to claims handling and severe weather events be codified in the General Insurance Code of Practice.
Recommendation 24
That the broad discretion contained in paragraphs 77, 83 and 84 of the General Insurance Code of Practice that allows insurers to avoid claims timeframe obligations should be removed.
Recommendation 25
That ASIC and the Australian Prudential Regulation Authority be resourced to collect and publish recurrent data on claims handling timeframes, outcomes, disputes and dispute resolution across all insurers.
Recommendation 26
That the General Insurance Code of Practice be amended to include obligations for insurers to consider premium hardship support options to help consumers maintain cover. In this regard consideration should be given to including options such as short-term premium waivers and discounts, deferral of premium payments, and removing the loading for monthly premiums.
Recommendation 27
That paragraph 96 of the General Insurance Code of Practice Code be strengthened to ensure that employees/consultants of insurers dealing with vulnerable consumers have the required level of expertise.
Recommendation 28
That all insurers be required to engage in operational scenario planning to better prepare for more frequent extreme weather events.
Recommendation 29
That in view of the increasing frequency and impact of severe weather events, insurers should allocate adequate ongoing resourcing to their claims handling, complaints management and dispute resolution functions.
Recommendation 30
That the General Insurance Code of Practice be amended to require insurers to provide policyholders with a plain English explanation of the policy and its terms upon the taking out of an insurance policy and at each renewal of that policy.
Recommendation 31
That the General Insurance Code of Practice be amended to provide that when claims are denied based on existing “wear and tear” or lack of maintenance, insurers must:
Recommendation 32
That the General Insurance Code of Practice be amended to provide that insurers be required to tell consumers what is required by an insured for a property to be maintained, including the minimum actions they need to take to avoid not being covered because they have failed to ‘maintain’ their property.
Recommendation 33
That the General Insurance Code of Practice be amended to provide that insurers must notify policyholders (either at the time of taking out a policy or at renewal), when they are of the opinion that they are underinsured or that the sum insured no longer covers the full cost of rebuilding.
Recommendation 34
That the General Insurance Code of Practice be amended to strengthen and provide greater transparency on breaches, the reporting of breaches and sanctions.
Recommendation 35
That the General Insurance Code of Practice be made mandatory for all insurers as well as being contractually enforceable by consumers against insurers.
Recommendation 36
That the Australian Government provide place-based community legal centres and financial counsellors to be provided with ongoing, adequate funding to engage and inform community members about their rights in relation to insurance policies in preparation for, and in response to, disasters.
Recommendation 37
That the General Insurance Code of Practice be amended to require insurers to:
Recommendation 38
With respect to Committee Recommendation 46, not only should the General Insurance Code of Practice be approved by ASIC, but there should also be designation of enforceable code provisions.
Hon Andrew Gee MP
Independent Federal Member for Calare
16 October 2024
Footnotes
[1]Cheney Suthers Lawyers, Submission 61, p. 1.
[2]Cheney Suthers Lawyers, Submission 61, p. 1.
[3]Cheney Suthers Lawyers, Submission 61, p. 2.
[4]Cheney Suthers Lawyers, Submission 61, p. 2.
[5]Cheney Suthers Lawyers, Submission 61, p. 3.
[6]Ms Heba Elkurdi, Committee Hansard, 7 May 2024, Molong, p. 13.
[7]Ms Heba Elkurdi, Committee Hansard, 7 May 2024, Molong, p. 13.
[8]Ms Heba Elkurdi, Committee Hansard, 7 May 2024, Molong, p. 17.
[9]Ms Kirsty Evans, Committee Hansard, 7 May 2024, Molong, p. 17.
[10]Mr Phillip Davis, Committee Hansard, 7 May 2024, Molong, p. 25.
[11]Ms Ann-Maree Davis, Committee Hansard, 7 May 2024, Molong, p. 27.
[12]Ms Kaylene Philpott, Committee Hansard,7 May 2024, Molong, p. 28.
[13]Ms Kaylene Philpott, Committee Hansard,7 May 2024, Molong, pp. 28-29.
[14]Mrs Lesley Smith, Committee Hansard, 8 May 2024, Eugowra, p. 26.
[15]Mr Brian Smith, Committee Hansard, 8 May 2024, Eugowra, pp. 29-30.
[16]Mr Hugh Ellis, Committee Hansard, 8 May 2024, Eugowra, p. 40.
[17]Mr David Norris, Committee Hansard, 8 May 2024, Eugowra, p. 39.
[18]Mrs Carole Shennan, Committee Hansard, 8 May 2024, Eugowra, p. 7.
[19]Mr Sean Haynes, Committee Hansard, 8 May 2024, Eugowra, p. 32.
Insurers' responses to 2022 major flood claims survey
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