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Chartered Insurance Institute
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Conflicts of interest

CII members are expected to conform their activities to the CII Code of Ethics. 

Members work in a variety of industry capacities. Some are senior managers and are in a position to influence the behaviour of firms. Firms should have in place a conflict management policy appropriate to their business model, including size and organisational structure, the expertise of clients, the nature of the services or products sold or administered and the type of activities engaged in.

Senior management have a key role in setting the cultural standards of their organisation. The culture of a firm can be a key mitigating tool for the proper management of conflicts of interest. But the values and ethics of individuals who work in the firm in capacities other than senior management should also be given appropriate weight as a corrective to potential institutional malpractice.

Corporate governance should be structured in such a way that conflicts are highlighted and resolved.

Disclosure plays an important role in minimising the risk of conflicts of interest and should be full and accurate. Disclosure alone, however, is not enough and subsequent management of a conflict has equal importance. Particular attention should be paid to remuneration and bonus structures, gifts and hospitality.

A process for resolving ethical problems within a firm should be established.

A path is suggested in this paper for CII members to take should they be subject to problems which are beyond their own power of resolution.

Some key questions for CII members to ask themselves:

  • Am I acting fairly towards this customer (or my employer)?
  • Is what I am about to do or propose in the best interests of the customer?
  • Am I being objective in giving opinions and statements?
  • Am I being honest and truthful?
  • Would I like to be treated in this way if I were a customer?
  • If I act for this customer will it prejudice any obligations I owe to any other client?
  • Why am I being asked to lunch (or to an event/function)?
  • How would my actions look to, or be perceived by, a third party or my employer, and does this matter ethically?
  • How would my actions look to the CII?
  • Should I refer my actions to my line manager or another appropriate person or the CII?