Politique des conflits d’intérêts
Summary of the conflict of interest policy
1. GENERAL FRAMEWORK
From 1 May 2015, the "AssurMiFID rules of conduct" apply. They are described in the law of July 30, 2013 aimed at strengthening the protection of users of financial products and services as well as the powers of the Financial Services and Markets Authority, and laying down various provisions. The Royal Decree of February 21, 2014 relating to “the rules of conduct and the rules relating to the management of conflicts of interest, established by law, with regard to the insurance sector” provides in particular for the obligation for insurance intermediaries to establish, implement and keep operational an effective conflict of interest management policy which must be established in writing. The conflict of interest legislation complements the basic MiFID rule. Our office abides by this rule by working in an honest, fair and professional manner for the benefit of our clients. Based on the above and the specifics of our activities, our office has developed a conflict of interest management policy, of which this document is a summary, which is available on our office website. The full version can be requested from our office.
2. IDENTIFICATION OF CONFLICTS OF POTENTIAL INTERESTS AND OUR OFFICE MANAGEMENT POLICY
Conflicts of interest may arise between:
- The insurance intermediary (natural or legal person including any person related to it such as, in particular, administrators, managers, persons who exercise control over the company, employees involved in the provision of intermediation services in insurance and sub-agents - hereinafter “related persons” and clients,
- Customers among themselves.
Taking into account the characteristics of our office, a map of potential conflicts of interest has been drawn up. The management policy as well as the concrete implementation measures are taken up with regard to the different types of potential conflicts of interest mentioned. Here are the potential conflict of interest groups:
- SPRL IN&CO is likely to make a financial gain or avoid a financial loss at the customer's expense;
- SPRL IN&CO has an interest in the result of an insurance intermediation service provided to the client or of a transaction carried out on behalf of the latter which is different from the client's interest in this result;
- SPRL IN&CO is encouraged, for financial or other reasons, to favor the interests of another client or group of clients over those of the client concerned;
- SPRL IN&CO has the same professional activity as the client;
- SPRL IN&CO receives an advantage from a person other than the customer in relation to the insurance intermediation service provided to the customer, in the form of money, goods or services, other than the commission or costs normally practiced for this service;
- Situations in which SPRL IN&CO would have a direct or indirect interest, equal to or greater than 10% of the voting rights or the capital of an insurance company.
- Situations in which one or more insurance companies would have a direct or indirect participation greater than 10% of the voting rights or of the capital of the company of SPRL IN&CO.
3. FOLLOWING PROCEDURE FOR MANAGING CONFLICTS OF INTEREST
Our office follows the following procedure for conflicts of interest:
4. 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 damaging the interests of the client 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 the source of these conflicts of interest. The final choice of follow-up reserved for the situation which is the basis of the conflict of interest concerned is up to the client. If a specific conflict of interest cannot be resolved, our office reserves the right to refuse the request of the client concerned, with the sole aim of protecting his interests.
5. MONITORING OF CONFLICT OF INTEREST MANAGEMENT POLICY
In accordance with regulations, our office regularly maintains and updates a register of conflicts of interest that arise and which involve a significant risk of harm to the interests of one or more clients. Mention of conflicts of interest in the register may lead to updating the list of potential conflicts of interest and vice versa. If necessary, our office updates / modifies its conflict of interest management policy.
Persons linked to our office are required to comply with internal instructions relating to the conflict of interest policy.