What is the fiduciary duty of an insurer to an insured?

"Thus, it seems clear that any fiduciary duty existing between an insurer and its insured is governed by the terms of the insurance contract in effect between them; to the extent there is no contract, i.e., because the insurer has not extended coverage for the risk by which the insured has suffered a loss, the relationship between the parties is not controlled by principles of strict fiduciary responsibility." (Gibson v. Government Employees Ins. Co. (1984) 162 Cal.App.3d 441, 449-450, 208 Cal.Rptr. 511.)