CONFLICT OF INTEREST POLICY - Willis Re

More documents

Recommendations

Info

Willis Re (Pty) Ltd Conflict of Interest Policy 5. Conflict Of Interest – Prohibited Behaviours 5.1.1 A conflict of interest may arise where an employee conducts his or her activity for a client in a manner which does not adhere to Willis' policies and procedures; particularly: i. The policy of independence, the Willis Client Bill of Rights; ii. Transparency on remuneration; and iii. Ethical behaviour policies and in particular anti-bribery and corruption policies. 5.1.2 The following behaviours, which if undertaken by an employee, would create a conflict of interest in that an employee would not be acting in the best interests of Willis' clients. These behaviours are prohibited, and it is recognised that the following is not an exhaustive list: a. Falsifying accounting or reinsurance/insurance documentation; b. Misleading a client about the reinsurance cover and/or its cost; c. Failing to explain the terms of coverage particularly exclusions to a client; d. Providing the client or a reinsurer with inaccurate or inadequate information about a reinsurance risk or claim; e. Provide a service to the client without the required levels of knowledge and skill; f. The solicitation of a quote from a reinsurer that is intentionally higher, or otherwise intentionally less favourable to the client or prospective client, than quotes provided by other reinsurers; g. The solicitation of a quote from a reinsurer that is designed not to be selected by the client or prospective client; h. The solicitation of a quote from a reinsurer that is designed to present to the client or prospective client a false appearance of competition among reinsurers; i. The solicitation of an inflated quote from a reinsurer in order to allow Willis subsequently to appear to have lowered the quote through negotiations with the reinsurer; j. The solicitation of an inflated quote from a reinsurer so that Willis can earn a higher commission on the business; k. An agreement by Willis to place a reinsurance contract with a reinsurer but only on the condition that the reinsurer retrocedes retrocession business through Willis or an affiliate; l. Any arrangement whereby the award of reinsurance business to a reinsurer is conditional on the reinsurer’s agreement to provide other business to Willis or its affiliate; m. A reinsurer or reinsurance contract is selected or recommended which is not in the best interest of the client because that placement will result in a higher commission (or other compensation or incentives) for Willis; n. Willis places, or refuses to place, business with a reinsurer pursuant to some agreement or arrangement whereby Willis allocates clients among reinsurers; o. A quote is presented to a client without support from a reinsurer and this basis is not fully disclosed to the client; p. Reinsurers are specifically requested to decline a quote, or falsely certifies that it has declined, so as to enable Willis to place reinsurance with another reinsurer; q. Reinsurers quotes are solicited from reinsurers for the purpose of preventing other brokers from soliciting competitive quotes from those same reinsurers; r. Misleading others within Willis about the creditworthiness of a client or reinsurer; s. Providing false or inaccurate information; t. Misleading reinsurers about the nature of risks to be covered; and u. Retaining undisclosed brokerage on a fee based account 6. Queries Contact your local compliance personnel or Willis Re International Compliance Officer. Page 24 of 25
Willis Re (Pty) Ltd Conflict of Interest Policy 7. Financial Interests and Associates 7.1. Financial Interests offered to Willis Re (Pty) Limited representatives Willis Re will not offer any financial interest to a representative for: i. Giving preference to the quantity of business secured to the exclusion of the quality of the service rendered t our clients; or ii. Giving preference to a specific product supplier/reinsurer; or iii. Giving preference to a specific product of a product supplier/reinsurer. 7.2. List of Willis Re (Pty) Limited Associates¹ The following entities are Associates of Willis Re (Pty) Limited: Holding company Willis Europe B.V incorporated in Amsterdam Ultimate holding company Willis Group Holdings plc incorporated in Ireland Subsidiaries Motheo Reinsurance Consultants (Pty) Limited 1993/000306/07 7.3. Third Parties¹ in which Willis Re (Pty) Limited holds an ownership interest Motheo Reinsurance Consultants (Pty) Limited 1993/000306/07 7.4. Third Parties¹ who hold an ownership interest in Willis Re (Pty) Limited There are no third parties who hold an ownership interest in Willis Re (Pty) Limited ¹ As defined in the FAIS General Code of Conduct Page 25 of 25
Page 1 and 2: WILLIS RE (PTY) LTD FSP: 24845 CONF
Page 3 and 4: Willis Re (Pty) Ltd Conflict of Int
Page 25: Willis Re (Pty) Ltd Conflict of Int

CONFLICT OF INTEREST POLICY - Willis Re

You also want an ePaper? Increase the reach of your titles

Delete template?

Save as template?