CONFLICT OF INTEREST POLICY - Willis Re

Willis Re (Pty) Ltd Conflict of Interest Policy
2.4.7 Furthermore, each employee, in conducting work for clients in similar business sectors,
must always consider the following so that if the employee feels a positive answer applies
he or she should seek the assistance of his or her local compliance personnel or Willis Re
International Compliance Officer as a conflict of interest may arise or may have arisen:
i. Would I or Willis be acting differently in the handling and disclosure of information if
Willis only had one client in this business sector
ii. Do the clients have different interests and have they been recognised
iii. Has a client given Willis or me a piece of information on a "confidential" basis that
would affect the work done for the other party, if Willis could use it or disclose it
iv. The above questions are to be kept under constant review during the period of
conducting business for the client.
2.4.8 Where there exists a Confidentiality Agreement between the client and Willis, the Account
Executive is responsible for ensuring all employees involved with the client are aware of the
obligations under such agreement.
2.5. Employees’ Interests in Reinsurers
2.5.1. A conflict of interest may arise if employees, members of their immediate family or
associates have shareholdings or other financial interests in a particular reinsurer or
underwriting agency in circumstances where the Associate acts on behalf of a reinsured in
seeking to arrange or effect reinsurance through that reinsurer or underwriting agency.
2.5.2. Willis’ approach is that a conflict of interest will only be considered to arise if the employee's
interest in a reinsurer or underwriting agency represents more than 10% of the equity voting
rights or profit participating shares of that entity's capital. A member of an employee's
immediate family or Associate is defined as per the Financial Advisory and Intermediary
Services General Code of Conduct (refer to the definitions section above).
2.5.3. Willis employees, as part of a compliance verification questionnaire, will confirm whether or
not they have interests or 10% or more in the equity voting rights or profit participating
shares of the capital of a reinsurer or underwriting agency recommended to a client.
2.6. Dealing in the Shares of a Client or Reinsurer (insider trading)
2.6.1. A conflict of interest may arise if an employee uses information acquired in the course of
employment to purchase or sell the securities of a client company or reinsurer (e.g. shares).
2.6.2. Employees are subject to the policy set out in Willis Insider Trading Policy for dealing in
Securities (reference: Willis Global Policy Manual and Willis Insider Trading Policy) i.e.:
i. No employee should deal in Willis securities or the securities of a client if he or she is
in the possession, by reason of his or her employment, of "material inside"
information. Further, no employee should share with an Associate (including
immediate family members), “material inside” information that is "non-public" with the
intent of the Associate buying securities in Willis or a client, either for an employee or
any member of his or her family or with the expectation that the employee and
Associate will benefit from sharing the said information. Benefit is where a profit might
be made attributable to the fact that information was material inside information.
ii. Information is "material" if it has market significance in the sense that the disclosure of
such information is likely to affect the market price of the securities to which it relates.
Typical examples of such information are a company's financial results or a major
corporate transaction, such as a merger or large acquisition. Non-public information is
not material if there is no substantial likelihood that its public disclosure would have
any significant market effect.
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