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10/4          W01/March 2018  Award in General Insurance




                         Highest ethical standards  Honesty, trustworthiness and reliability underpin this section of the Code. It deals
                         and integrity           with avoiding taking unfair advantage of a client, a colleague or a third party. It
                                                 prohibits the giving and receiving of gifts and benefits that imply, or appear to
                                                 imply, an improper obligation.
                                                 Members must also promote professional standards and encourage the use of
                                                 ethical codes within their firms.
                                                 This section also covers CII membership and the use of CII status. It includes a
                                                 requirement to advise the CII of material changes in circumstances that affect
                                                 either of these. Operating professionally extends to being financially responsible,
                                                 including the need to remain solvent.
                         Acting in the best interests of  The fair treatment of clients is a key theme of the Code. Members should
                         each client             encourage their firms to place the fair treatment of clients at the centre of their
                                                 corporate culture. Emphasis is placed on understanding and meeting client needs
                                                 and providing comprehensive information so that an informed decision can be
                                                 made by the client. Promises about product performance and after sales service
                                                 must be true. Confidentiality and the need to avoid conflicts of interest are also
                                                 dealt with.
                         High standard of service  Communication with clients must be accurate and straightforward. Transparency
                                                 (including fees and other costs) and suitability are the main elements of this
                                                 section, which also emphasises the need for a member to ensure their knowledge
                                                 and expertise is kept up to date, meeting any CPD requirements.
                         Treating people fairly  The focus of this section is the avoidance of unfair discrimination on grounds of
                         (non-discrimination)    age, disability, gender reassignment, pregnancy and maternity, marriage and civil
                                                 partnership, race, religion or belief, sex or sexual orientation. It relates to the
                                                 equality and diversity laws in the member’s country. Rules require that each
                                                 person is treated as an individual and emphasise openness, fairness, respect and
                                                 opportunity.


                         Activity
                         Take a look at the CII Code of Ethics, in appendix 10.1, consider your everyday working life and measure your
                         approach to your work and actions against the principles (and the key questions posed) as far as they apply to your
                         job role.



                        B     ‘Fit and proper’ requirements

                        To safeguard the interests of consumers, it is crucial that insurers are soundly and prudently managed,
         Is crucial that
         insurers are soundly  and it is essential that individuals in key positions do not pose a risk to the interests of the insurer and
         and prudently  their stakeholders.
         managed

                        B1 Risks of unsuitability
                        Research into the experience of insurers has demonstrated that a significant cause of financial
                        difficulties resulting in bankruptcies or ‘near misses’ can be problems with incompetence or operating
                        outside areas of expertise, lack of integrity or conflicting objectives, or weakness in the face of
                        inappropriate group decisions.
                        It is necessary therefore to set standards on fitness and propriety for ‘significant owners’ and ‘key
                        functionaries’, and for the assessment of the compliance with these standards, or ‘fit and proper’
                        testing, by regulators.
                        A significant owner is defined as a person (legal or natural) that directly or indirectly, alone or with an
                        associate, exercises control over the insurer.
                        Key functionaries are individuals defined by legislation, such as board members, directors and senior
                        management of an insurer, who must meet fit and proper requirements. The key functionaries identified
    10                  may differ depending on the structure of the insurer.
    Chapter             Performance of ‘fit and proper’ tests by regulators also helps address financial crime, such as money
                        laundering.
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