APPENDIX 2
Memorandum submitted by AXA Sun Life plc
1. INTRODUCTION
1.1 AXA Sun Life is a leading provider of
life, disability and pension products for the UK market.
1.2 The effective provision of private insurance
(as opposed to public, social insurance) is dependent on the ability
to pool a reasonable number of similar risks.
1.3 The process of underwriting seeks to
group applicants for insurance into broadly equivalent risk groups.
The aim is thus to provide insurance coverage to the maximum number
of applicants.
1.4 Advances being made in the understanding
of genetics have the potential to provide further information
for the underwriting process.
2. ISSUES SURROUNDING
THE USE
OF GENETIC
TEST RESULTS
BY INSURANCE
COMPANIES
2.1 AXA Sun Life is aware of the problems
that arise because of developments in genetics and of fears these
developments inspire in the public at large. We believe there
are several important issues to be faced:
— Is personal genetic information different
from other medical information or family history?
— General lack of understanding of
the principles of insurance and confusion between private insurance
and social insurance.
— The financial effects of lack of
disclosure of genetic information.
— The need to establish the predictive
value and reliability of genetic tests.
— The paramount importance of the confidentiality
of all medical information.
— Agreement on the definition of a
genetic test.
3. AXA SUN LIFE'S
POLICY ON
THE USE
OF GENETIC
TEST RESULTS
3.1 AXA Sun Life follows the ABI Genetic
Testing Code of Practice.
3.2 One of the fundamental principles underlying
the code is that we do not request as a precondition of obtaining
life insurance that any applicant undergoes a genetic test. However,
applicants will be asked to reveal the results of tests previously
undergone. This will not be required of applicants for life assurance
required to be taken out to obtain a private house purchase mortgage
of up to £100,000. (Also see point 5 below).
4. SCIENTIFIC
EVIDENCE AND
ADVICE
4.1 We have followed the advice of the Genetics
Committee of the ABI. Currently we only take account of relevant
and reliable tests as indicated by the ABI's Genetic Advisor.
5. APPROVAL OF
TEST RESULTS
BY THE
GAIC
5.1 Currently we only include test results
for the following seven conditions, as indicated by the ABI's
Genetic Advisor: Huntingdon's Disease, Early onset familial Alzheimer's
Disease, Hereditary breast and ovarian cancer, Myotonic dystrophy,
Familial Adenomatous Polyposis, Multiple endocrine neoplasia and
Hereditary motor and sensory neuropathy.
5.2 In the event that a test approved by
the ABI's Genetic Advisor is not subsequently approved by GAIC,
we will re-underwrite those applications where an adverse underwriting
decision has been made.
5.3 Our policy is to keep abreast of scientific
developments in the genetic area. Currently we are not aware of
any reliable tests for multifactorial disorders and do not anticipate
using such tests in the foreseeable future.
5.4 We would only wish to use tests that
were shown to be scientifically reliable and which demonstrated
a significant expected difference in mortality or morbidity.
6. CURRENT REGULATORY
SYSTEM
6.1 The current regulatory system has shown
that the insurance industry has acted responsibly and sensitively
thus far. There does not appear to be any reason why the policy
of self-regulation cannot continue.
6.2 In order to ensure that the current
regulatory system remains effective it is essential that the insurance
industry maintains its dialogue on genetics and its practical
applications and implications with all parties concerned: the
public, the Government, the medical profession and in particular
the geneticists.
19 January 2001
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