Information on the conflicts of interest policy from our office

1.     Legal framework

The AssurMiFID code of conduct has been in force since 30 April 2014. It is based on the Law of 30 July 2013 on increasing the protection of recipients of financial products and services and increasing the powers of the FSMA, including additional provisions, as well as on the Royal Decree of 21 February 2014 on the rules for the application to the insurance sector of Articles 27 to 28bis of the Law of 2 August 2002 regarding supervision of the financial sector and financial services and the Royal Decree of 21 February 2014 regarding the legally enforced code of conduct and rules on the management of conflicts of interest in the insurance sector.

In accordance with this code of conduct, we are obliged to set out a written policy for managing conflicts of interest when providing insurance broking services.

The legal rules on conflicts of interest are supplementary to the general MiFID framework act. We respect this framework act by acting loyally, fairly and professionally in defence of our customers' interests when providing insurance broking services.

2.     What are the conflicts of interest?

When drawing up our conflict of interest policy, we started by identifying potential conflicts of interest within our company.

Conflicts of interest can arise between (1) our company and its associates and a customer or (2) between several customers. The conflict of interest policy takes account of the specific characteristics of our company and its potential group structure.

When assessing the potential conflicts of interest, we identified situations in which there is a substantial risk of damage to the customer's interests. These include:

• Situations where profits are made or losses are sustained at the expense of the customer;
• Situations where our company has a differing interest with respect to the result of the service or transaction;
• Situations where there is a financial incentive to prioritise other customers;
• Situations where the business activity exercised is the same as that of the customer;
• Situations where our company receives compensation from a person other than the customer for the insurance broking services provided;
• Situations where our company holds shares of at least 10% in terms of voting rights or capital in the insurance company/companies;
• Situations where the insurance company/companies hold(s) shares of at least 10% in terms of voting rights or capital in our company.

3.   What measures are we taking?

We are taking a large number of measures to ensure that the customer's interests come first. These include:

• An internal instruction notice;
• An adapted remuneration policy;
• A policy to ensure that our associates only provide broking services for insurance contracts where they understand the essential characteristics of those contracts and are in a position to explain them to customers;
• A policy whereby our company reserves the right to refuse to provide a service in the event of failure to find a practical solution to a specific conflict of interest, with the ultimate goal of protecting the interests of the customer;
• A code on receipt of benefits;
• A policy to ensure that all information our associates provide is correct, clear and not misleading.

Where necessary, we will modify and/or update the conflict of interest policy.

4.   What is the procedure?

5.   Specific transparency

When, in a particular situation, our measures do not provide sufficient guarantees, you will be informed by our office about the general nature and/or source of the conflict of interest in order to allow you to make a decision in consideration of the facts. You are always welcome to contact us for more information.