Code of Conduct

CODE OF CONDUCT OF LPH INSURANCE BROKERS LLC
AS PER HEALTH INSURANCE LAW NO. 11 OF 2013 OF THE EMIRATE OF DUBAI, STANDARDS NOTICE NUMBER 2 OF 2015 (SN 02/2015)

LPH INSURANCE BROKERS LLC (the “Company”) is committed to applying the highest standards to its activities as an insurance broker. The objective of this Code is to establish professional business standards that need to be followed by the Company. Company requires all its employees to meet these standards and abide by this Code of Conduct, to maintain reputation of the Company. Each employee is required to sign a copy of this Code which will be retained in his/ her personal file kept with HR Department. Compliance with this Code will be monitored and documented by the Company and violation may result in Company taking disciplinary action against the employee.

APPLICABILITY

This policy is applicable to all the employees (full time, part time and consultants) and representatives of the Company (Each designated as a “Member” and collectively as “Members”).

CODE OF CONDUCT
A. GENERAL CODES OF CONDUCT
1. Public interest is paramount

Members must at all times place the public interest (including that of existing or potential clients be they employers or individuals) above their own.

2. Standards of advice

Any advice or recommendations that Members provide to the public, clients or potential clients must be impartial. Advice and recommendation must be based on relevant information and not be influenced by matters that may produce a benefit to themselves other than as provided for under their normal terms of remuneration.

3. Improving and maintaining competence

Members must seek continually to maintain and improve their professional knowledge, skills, and competence through regular self-learning, training and keeping up to date with regulatory, market and product developments. Members shall have good understanding of key features of different types of insurance products on which Member may give regulated advice.

4. Professional qualifications

Members commit to comply with any requirements issued by the concerned regulators to attain professional qualifications that may be mandated and agrees Company reserves the right to terminate the employment of anyone who does not have mandatory professional qualification.

5. Compliance

Members must obey all laws and regulations applicable to the market in which they operate, including laws relating to Anti Money Laundering and should avoid any conduct or activity that would cause loss or injury to others and to the Company.

6. Diligence

Members must exercise due care and diligence in the performance of their occupational duties.

7. Professional and ethical standards

Members must aspire to raise the professional and ethical standards of the insurance profession by adopting such standards and applying them at all times in their occupational duties.

8. Conduct with fellow professionals and regulators

Members must maintain dignified and honorable relationships with fellow insurance professionals (both inside and outside their own organization), with insurance companies, with regulators and with members of other professions.

9. Improving public understanding of health insurance

Members must assist in improving public understanding of health insurance, its benefits and limitations. They must never mislead the public or any client by way of the information they provide.

10. Reporting of breaches by other Members

It is a responsibility of a Member to report to his or her employer any breach or suspected breach by another employee, whether within the Company or outside the Company.

11. Duty to keep Confidentiality

Members shall respect the confidentiality of all information received and processed by them and shall take utmost care and effort to keep all such information confidential.

12. No Conflict of Interest

Members shall avoid

  • Conflict between any competing interests, or the interests of any associated company, person or group of persons, and their duties to all clients,
  • Conflict between any competing interests of one or more clients, stepping aside in one or all matters if such conflict cannot be resolved, and
  • Providing or accepting money, gifts, entertainment, loans or any other benefit or preferential treatment from or to any existing or potential clients or provider, other than occasional gifts, entertainment or remuneration, which are provided as part of accepted business practice, and which are not likely to conflict with duties to clients.
13. Breaches of the Code of Conduct

All breaches of the Code of Conduct will be recorded by the Company and maintained in a Register of breaches that will be available for inspection by the concerned regulatory authorities.

B. CODE OF CONDUCT TO BE FOLLOWED IN RELATIONS WITH CLIENT, IN ADDITION TO CODES UNDER SECTION A ABOVE
Members shall:

1. Act openly, fairly and respectfully at all times, providing all client with due respect, consideration and opportunity and act in their best interest. Members shall not take advantage of client’s inexperience, lack of education, lack of sophistication or ill health.

2. Be honest and trustworthy with clients and communicate with them in a clear, prompt and appropriate manner. Member shall obtain and provide relevant information, including all necessary documentation.

3. Recommend insurance Product which best meets Client’s needs and should source a sufficient range of relevant insurance Products. Before giving any recommendation, Member shall carry out a suitability assessment of the client’s objectives, circumstances, needs and priorities. Where client insists on a material decision contrary to the recommendation, Member should ask client for reasons, provide explanation and confirm the client decision and properly record it.

4. Give fair and impartial regulated advice. This should be advice that a reasonable licensed broker would consider suitable for the client.

5. Not provide inaccurate, misleading or incomplete information to client. Members shall not advice on matters on which he/ she is not trained or lacks the skills.

6. Inform client the best conditions and prices of providers, maintain and incorporate the supporting documents in duly organized records, negotiate for its interest, be represented before the providers, not receive any commission for negotiations.

7. Members shall inform clients about all aspects of insurance products they have purchased including any changes affecting a policy which occur during policy term.

8. Not to exert undue influence or pressure client into making a material decision.

9. Handle client assets carefully and in strict compliance with requirements under applicable laws and regulations.

10. Inform the procedures to be implemented by the client, once the insured danger occurs, and assist in the negotiations made with the Insurer on the claims resulting from such occurred danger; it shall notify the customer forthwith of the Insurer’s decision on accepting or refusing to provide the insurance coverage of such claims.

11. Inform the client in writing 20 business days prior to the expiration of the insurance document, for its renewal.

12. Get the letter of authorization signed from client, in the format approved by Company and Insurance Authority.

13. Act only within the limits of personal competence and any limits of authorization.

14. Act in financially honest and prudent manner, including ensuring the protection of any money and or property held on behalf of client.

C. CODE OF CONDUCT TO BE FOLLOWED IN EMPLOYMENT RELATIONSHIP, IN ADDITION TO CODES UNDER SECTION A & B ABOVE
Members shall;

1. Not make improper use of information obtained as an employee or disclose or allow to be disclosed, information confidential to their employer.

2. Seek to be a responsible employee and be honest and trustworthy at work.

3. Act openly, fairly and respectfully at all times, treating other Members, colleagues, customers and suppliers with equal respect, consideration and opportunity.

4. Aim to take every opportunity to improve their professional capability, knowledge and skills.

5. Accurately and completely account for and report in employer records all business dealing.

6. Follow the Complaint handling procedures as per the company’s approved procedures.

D. CODE OF CONDUCT TO BE FOLLOWED IN RELATIONS WITH REGULATORS AND LAW, IN ADDITION TO CODES UNDER SECTION A, B & C ABOVE
Members shall;

1. Respect all Laws and abide by all Regulations that affect their business.

2. Ensure they deal with regulators in an open, transparent and co-operative manner.

E. CODE OF CONDUCT TO BE FOLLOWED IN RELATIONS WITH THE COMMUNITY AND PUBLIC, IN ADDITION TO CODES UNDER SECTION A, B, C & D ABOVE
Members should recognize the important wider role that they play as professionals and should:

1. Seek to advance the reputation of financial services, financial planning, insurance and associates trades through their own conduct.

2. Operate in a way that respects environmental concerns and issues.

3. Act in a socially responsible manner within the countries and societies in which they operate.

4. Strive to be trusted individuals and fulfill their responsibilities to the societies and communities in which they operate professionally.