CONFLICT OF INTEREST POLICY - Willis Re

More documents

Recommendations

Info

Willis Re (Pty) Ltd Conflict of Interest Policy 1. Introduction 1.1. Willis’ Approach “A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another customer”. The purpose of this document is to provide guidance on Willis' policies and procedures for addressing actual, apparent and potential conflicts of interests (in this document "conflicts of interest") that arise in the conduct of its business either generally or specifically. In the context of its day to day business Willis routinely acts for a number of parties, including reinsureds and reinsurers and it is likely that Willis may find itself in a position where its duty to one party conflicts either with its own interests or with its duty to another party. There are a number of methodologies that can be put in place to address conflicts of interest but it is recognised that some of these may not be practical. Therefore, Willis has developed an approach to strike a balance to provide transparency whilst retaining the ability to service its client base in a manner appropriate to the client's needs. The insurance and reinsurance markets in which Willis operates are complex and there could be other relationships not described in this document which may create conflicts of interest. However, it is Willis' policy that where a conflict of interest is unavoidable or cannot be addressed within its policies and procedures the fact that a conflict of interest has arisen will be explained to the parties and information will be provided on the nature of the conflict. Whatever the circumstances Willis' policy is to act in the best interests of a client and to avoid prejudicing any party. Thus, where a conflict of interest arises for which there is no practicable solution Willis will withdraw unless the client consents in writing to Willis continuing to act. Willis' position on conflicts of interest is drawn to the attention of clients through either its terms of business agreement or its standard fee agreement. Employees must remain alert to the possibility of conflicts of interest and contact the Willis Re International Compliance Officer who will review and help the business to clear potential conflicts of interest which may be reasonably foreseeable. 1.2. Application of Policies and Procedures The policies and procedures set out in this document apply to all Willis Employees, and may apply to those to whom Willis may outsource some of its business activities. A failure to adhere to Willis' policies will be dealt with in accordance with Willis' disciplinary procedures. 1.3. What is a Conflict of Interest A Conflict of interest is any situation in which a provider or a representative has an actual or potential interest that may, in rendering a financial service to a client: a) Influence the objective performance of his, her or its obligations to that client; or b) Prevent a provider or representative from rendering an unbiased and fair financial service to that client, or from acting in the interests of that client Including, but not limited to: i. A financial interest; ii. An ownership interest; iii. Any relationship with a third party. Page 6 of 25
Willis Re (Pty) Ltd Conflict of Interest Policy A conflict of interest arises where Willis puts itself in a position where its duty to one party conflicts either with its self-interest or with its duty to another party. A conflict may arise where Willis has an interest or is likely to make a financial gain or avoid a financial loss at the expense of a client or where Willis has a financial or other incentive to favour the interest of one client over the interests of another client. For an employee a conflict of interest will arise when an employee's personal interest interferes in any way with the interests of any of Willis' clients. A conflict situation will arise when an employee takes actions or has interests that may make it difficult to perform his or her work objectively and effectively. A conflict of interest may also arise when an employee or a member of their immediate family, receives inappropriate personal benefits, including those not necessarily giving an economic benefit, as a result of their position in Willis (reference Willis Global Policy Manual - Our Ethical Code). Conflicts of interest may not always be clear-cut and if there are any concerns, questions or queries in relation to a matter immediate advice must be sought. Employees should speak in the first instance to their local compliance personnel who will liaise with the Willis Re International Compliance Officer. Failing to disclose concerns with potential conflicts of interests can have adverse implications for Willis and employees involved. 1.4. How does Willis manage Conflicts Of Interest Willis' approach to managing conflicts of interest is through a combination of adherence to the policies referred to below, transparency and, where required, the informed consent of the party or parties involved: 1.4.1. Willis Client Bill of Rights The Willis Client Bill of Rights represents our policy of independence and sets out 10 principles supporting Willis' commitment to upholding the highest standards of integrity. It guides our culture and our actions. 1.4.2. Willis Global Policy Manual The Willis Global Policy Manual brings together, at high level, policies on a range of subjects, particularly our Ethical Code and Whistleblowing Policy and Business Principles. It is designed to help employees know what is expected of them. The principles are common sense and when followed ensure that employees conduct themselves in a manner in which an unswerving commitment to integrity and mutual respect is a key hallmark. The Willis Global Policy manual incorporates: i. Our Ethical Code (including our Whistleblowing policy); and ii. Our Business Principles. Page 7 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 7: Willis Re (Pty) Ltd Conflict of Int
Page 27: Willis Re (Pty) Ltd Conflict of Int

CONFLICT OF INTEREST POLICY - Willis Re

Create successful ePaper yourself

Delete template?

Save as template?