Introduction

We can only succeed as an insurance intermediary if we have a reputation based on the trust of our clients and trading partners. The way that we all act as Ed staff must be to protect that trust. We must behave in accordancest with the highest standards of personal and business integrity in our dealings with clients, trading partners and each other.

This Code of Conduct sets out our expectations and requirements of how we all should act.

This Code applies to all staff, managers, directors, consultants and temporary staff of all Ed/Junge businesses. It is every individual’s personal responsibility to comply with the Code.

This Code is not part of your contract of employment and does not create any contractual rights between you and any Ed/Junge company. However, if you do not comply with the Code you may be subject to disciplinary proceedings.

Guidance

The Code cannot cover every situation you might face, so you should use your good judgement and common sense. Always think about whether our reputation would be damaged by what you are considering. Remember, just because our competitors may do something does not mean that we should or can.

Laws and regulations or our own internal procedures may be stricter than what is set out in this Code, the highest of these standards applies in each case. The Code is the minimum standard of behaviour expected.

You cannot use or facilitate a third party to do something that you are not allowed to do yourself.

It is your responsibility to report wrongdoing or mistakes such as potential errors & omissions, so tell your line manager or other business leaders. Speak up if you have a concern about a transaction. If this does not work then use your local or the Group whistleblowing policy.

Laws & regulations

• We are committed to complying with all applicable laws, rules, regulations in the markets in which we operate

Clients

• You should always act with honesty, in good faith and in the interests of our clients
• Be clear about our role and our obligations to our client and their obligations to us
• Always provide objective and independent advice
• Conflicts of interest may not always be clear, but report them so that they can be properly managed. If they can’t be managed, then we cannot act in that situation
• Do not misrepresent costs or material facts
• Do not disclose client’s confidential information unless authorised by that client
• Do not seek or give (provide?) tenders or quotes that are inflated or false, or are subject to collusion

People

• We recruit and reward based on ability
• You should treat others respectfully and professionally
• Do not discriminate or use harassment when dealing with other members of staff
• Do not retaliate to or victimise staff who report issues or problems

Fraud, money laundering, bribery & corruption

• Do not assist clients or others to commit fraud, embezzle funds, launder money or hide the source of funds
• Do not trade with a party unless we have performed adequate due diligence
• Do not offer, give, entice, accept or facilitate bribes, improper payments or undue advantage
• Do not make any payments to government officials or employees of government owned businesses except valid premiums and claims payments
• Do not tell or tip-off anyone about any money laundering concerns that you might have concerning that person or company

• Do not disclose our confidential information or use it for personal gain unless authorised
• Do not allow personal interests to compete with your duty to Ed/Junge