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CODE OF BUSINESS CONDUCT FOR NORFOLK MUTUAL
INSURANCE COMPANY
PURPOSE
Norfolk Mutual Insurance Company (“Company”) is
committed to the highest level of personal and corporate ethical standards
in the conduct of its business.
This Code of Business Practice (“Code”) sets out
the minimum standards of business practices that the Company expects of
each employee and director to continue to earn the trust and confidence of
its policyholders and other stakeholders.
Norfolk Mutual Insurance Company is committed to
meaningful disclosure of our Company practices to consumers that is easily
understood, relevant to the sale of our insurance products or services,
mitigates real or potential conflicts of interest, and is easily comparable
in our marketplace.
Norfolk Mutual Insurance Company is committed to
providing information to the consumer that is clear, honest, relevant,
factual and as complete as is practical. The Company expects our
appointed business representatives to present our insurance products and
services on their merits including a full description of the benefits,
remuneration and price.
SCOPE
This Code of Business Practice applies to the
following:
- Members of the Board of Directors of Norfolk
Mutual Insurance Company
- Officers and other employees; and
- Independent contractors including contract
employees and appointed representatives, including Brokers and Agents,
engaged by and representing the Company
Strict adherence to the provisions of this Code
is mandatory and full compliance is expected under all circumstances.
If you should become aware of a contravention of
this Code we would request that you report the matter immediately to either
the Manager/President of the Company, or to the President/Chairman of the
Board of Directors of Norfolk Mutual Insurance Company.
ANNUAL COMPLIANCE ACKNOWLEDGEMENT
Each year, employees and directors are asked to
reaffirm their commitment to the Code, and to provide assurance that they
have complied with it over the previous year.
RELATIONS WITH CLIENTS
Client Privacy
To ensure the confidentiality and proper use of
personal information relating to its clients, employees, agents and
directors, the Company will conduct its business in accordance with its own
Privacy Code as well as in accordance with the Personal Information
Protection and Electronic Documents Act (PIPEDA).
Client Trust
The Company is committed to providing the highest
quality of personal service that can reasonably be expected. Honesty,
fairness and service are hallmarks of the way Norfolk Mutual Insurance
Company conducts business.
As mentioned above, information provided to
everyone with whom the Company does business must be clear, honest,
relevant, factual and as complete as is practical. The Company’s products
and services must be sold on their merits, with a full description of the
benefits and costs. Misrepresentation of either our products, or our
competitors’ products and services, is prohibited.
The Company expects that its Brokers and Agents
will document and explain to their clients their reasons for recommending a
particular product.
• A
Broker or Agent should conduct fact finding appropriate to the
circumstances and assessment of the client’s specific
needs;
• A
needs’ assessment should be flexible – the assessment should reflect
factors including the underlying risk, the client’s objective, and the
complexity of the product being sold; and,
• A
Broker’s or Agent’s product recommendation should meet the client’s
identified needs.
It is important that our brokers and agents
maintain a written account of this process for purposes of the client file.
This may include documentation such as information gathered from the
client; the needs assessment analysis; copies of any engagement letter;
product comparison information presented to the client; intermediary
disclosure documents addressing conflicts of interest; and any formal
suitability letters presented to the client.
The client’s file must be kept accurate and up to
date to demonstrate that the analysis process is ongoing. In addition, the
client has the right to request additional information.
RELATIONS WITH THE COMPANY
Company Assets
The assets of Norfolk Mutual Insurance Company
consist of property and information to which the Company is legally
entitled.
These assets are not to be used in any way for
personal gain. This applies not only to funds, facilities, equipment and
supplies, but also to intellectual property, client data and information
technology.
Conflict of Interest
Situations should be avoided where the personal
interests of employees or directors conflict, or might appear to conflict,
with their responsibility to policyholders or to the Company. The conduct
of employees and directors must be able to bear public scrutiny. The
Company Conflict of Interest Policy for Employees is available for
review through this link on our website.
Any external personal or business interests that
could compromise sound judgment or diminish an individual’s commitment to
the Company, or to the policyholder, must be avoided.
Employees and directors should not use their position
in the Company or confidential information acquired in connection with the
business of the Company to gain, either directly or indirectly, a personal
benefit for themselves or for others.
They should ensure that their actions or
decisions are free from the influence of any interest which might
reasonably be regarded as conflicting with that of the Company or the
policyholder. Situations must be avoided where your personal interests
conflict, or might appear to conflict, with your responsibility to policyholders
and to the Company.
The need to disclose conflict of interest applies
on an ongoing basis. In determining whether a conflict of interest might
exist which would require disclosure, you must consider whether it would
appear to a reasonable, informed person looking at the facts that you acted
both in the best interest of the policyholder and in the best interest of
the Company.
Employees and directors should make timely
disclosure to the Manager/President of the Company or to the
President/Chairman of the Board of Directors, in writing, of all personal
business, commercial or financial interests or activities where such
interests or activities might create, or appear to create, a conflict of
interest.
RELATIONS WITH REGULATORS
Compliance with Laws and Regulations
Norfolk Mutual Insurance Company and all persons
acting on behalf of the Company must comply with both the letter and the
spirit of all laws and regulations governing its business. They
must make every effort to become familiar with the law as it pertains to
the business carried out by the Company.
Human Rights
Norfolk Mutual Insurance Company supports and
conducts its business in accordance with human rights legislation. We
hire and promote people on the basis of their individual abilities and
compensate them on the basis of performance. Discrimination or harassment
in the workplace with respect to such matters as race, colour, sex, sexual
orientation, citizenship, age or handicap is strictly forbidden.
Norfolk Mutual Insurance Company observes a
policy of non-tolerance towards discrimination or harassment of any sort,
and matters will be dealt with strictly on that basis.
NOTE: Provincial regulations, if any, take
precedence over this Code of Business Practice.
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