In 2013, the CCPC opened an investigation into potential anti-competitive information sharing between private motor insurers via a software product provided by an intermediary software services provider, Relay Software Limited (Relay). The software product in question had been developed by Relay for use by insurance brokers. Insurance companies participating in the system provided their future pricing information to Relay for inclusion on Relay’s software platform. Insurance brokers subscribing to Relay’s software product could then access multiple insurance companies’ future pricing information in order to provide quotes to customers.
The CCPC investigated whether participating insurance companies had access, via Relay, to commercially sensitive information relating to their competitors’ future pricing intentions. In such circumstances, the CCPC was concerned that this could potentially lead to reduced price competition between participating insurers. Following engagement with the CCPC, Relay cooperated with the CCPC’s investigation and confirmed that mechanisms had been put in place to ensure that each insurance company using the Relay product had access only to its own pricing information. Relay has entered into an Agreement and Undertakings with the CCPC, under which Relay has committed not to supply any software to insurance companies unless the software complies with principles relating to information exchange agreed with the CCPC.
Allianz Plc, AXA Insurance Limited, Zurich Insurance Plc, RSA Insurance Ireland Limited and Sertus Underwriting Limited (an RSA Group company) cooperated with the CCPC’s investigation and have each entered into Agreements and Undertakings with the CCPC. The Agreements and Undertakings impose clearly defined restrictions on these insurance companies in relation to their access to the commercially sensitive information of competing insurance companies via intermediary software systems. Compliance with the Agreements and Undertakings will be monitored by the CCPC. Following receipt of the Agreements and Undertakings, which addressed the CCPC’s competition concerns, the CCPC’s investigation was closed in August 2016.