Conflict of Interest Policy
- GENERAL FRAMEWORK
Our firm's top priority is to act in an honest, fair, and professional manner that best serves the interests of its clients.
In this context and in accordance with the law, our firm has taken appropriate measures to identify, prevent, and manage conflicts of interest that may arise in the course of its activities.
Taking into account the above and the characteristics of our activities, our office has developed a conflict of interest management policy, a summary of which is provided in this document. Upon request, you can obtain further information, which will be provided to you on a durable medium.
IDENTIFICATION OF POTENTIAL CONFLICTS OF INTEREST
Conflicts of interest may arise between:
– our office (including any person associated with it, such as
, directors, managers, persons exercising control over the company, employees involved in the provision of insurance intermediation services, and sub-agents – hereinafter “associated persons”) and clients.
– clients among themselves.
Taking into account the characteristics of our office, we have identified potential cases of conflicts of interest. Here are a few examples:
– A situation in which a financial gain can be made or a financial loss avoided at the expense of the customer.
– Our office has an interest in the outcome of an insurance intermediation service or a transaction carried out that is different from the customer's interest.
– Our office is encouraged, for financial or other reasons, to favor the interests of another client or group of clients over those of the client concerned.
– Our office is engaged in the same professional activity as the client.
– Our office receives from a person other than the client a benefit in connection with the insurance intermediation service provided to the client, in the form of money, goods or services, other than the commission or fees normally charged for this service.
– Our office also acts as an intermediary in banking and investment services and as a real estate agency.- CONFLICT OF INTEREST MANAGEMENT POLICY
Our office has implemented a series of measures to manage conflicts of interest that may arise. These measures include the following:
– compliance by staff and any other person associated with the office with an internal instruction note setting out the principles and measures to be observed in the management of conflicts of interest.
– an appropriate policy on the remuneration of staff and any other persons connected with the firm
– a policy on gifts or other benefits
– organizational measures to ensure the confidentiality of data
provided by clients.
– organizational measures for separate management where necessary.
– a policy on arbitration advice.
– a policy whereby, if a specific conflict of interest cannot be resolved, our office reserves the right to refuse the request of the client concerned, for the sole purpose of protecting their interests. - CUSTOMER INFORMATION
When the organizational or administrative arrangements made by our office to manage conflicts of interest are not sufficient to guarantee, with reasonable certainty, that the risk of harming the customer's interests will be avoided, our office will inform them in writing or on any other durable medium, before acting on their behalf, of the general nature and/or source of these conflicts of interest. The final choice of how to deal with the situation giving rise to the conflict of interest lies with the client.
If a specific conflict of interest cannot be resolved, our firm reserves the right to refuse the request of the client concerned, for the sole purpose of protecting their interests. - MONITORING OF THE CONFLICT OF INTEREST MANAGEMENT POLICY
In accordance with regulations, our office maintains and regularly updates a register of conflicts ofinterest that arise and that pose a significant risk of harming the interests of one or more clients. The mention of conflicts of interest in the register may lead to the list of potential conflicts of interest being updated and vice versa.
If necessary, our office updates/modifies its conflict of interest management policy.
Persons associated with our office are required to comply with internal instructions relating to the conflict of interest policy.