Associate Handbook 2018

 Lockton undertakes to ensure that there are appropriate systems and controls in place to manage conflicts. These will be managed either by avoiding a situation where a conflict could arise or by disclosing the existence of a potential conflict to the client and agreeing how to manage that conflict.  Lockton believes that avoiding all potential Conflicts of Interest may not always be in the best interests of the client. In such cases, Lockton will provide the client with the opportunity to give their informed consent as to whether or not they wish to accept the potential conflict and Lockton’s proposal to manage the conflict.

 Lockton will obtain the informed consent of a client to any potential conflict prior to the client placing an order with Lockton.

 Lockton will pay due regard to the information needs of its clients and communicate any information to them in a way that is clear, fair and not misleading.

 Lockton will decline to act for the client unless, in the particular circumstances of the case, disclosure and informed consent are sufficient to enable it to reconcile the conflict.  Lockton will, if a client asks, promptly disclose all earnings that it (or any associated Company) receives in connection with the contract of insurance in question. The earnings will be expressed in cash terms or, to the extent it cannot be indicated in cash terms, the basis for the calculation of the earnings will be given. The disclosure to the client will be in a durable medium. Lockton will include all forms of remuneration from any arrangement it may have in connection with the insurance contract, including arrangements for sharing profits, for payments relating to the volume of sales, and for payment from premium finance companies in connection with arranging finance for a non-investment insurance contract  Lockton will also provide a client with details of the amount of any fees (or the basis for calculating any fees) relating to an insurance contract before the client incurs liability to pay the fee or before the contract is concluded, whichever occurs first

All Associates are expected to be familiar with and comply with the following guidelines :

 Conflict of Interest Policy and Transparency Policy

10.4

Ethical Standards (Personal Conflicts, Gratuities, external)

Personal conflicts of interest

In acting on behalf of clients of Lockton, Associates must ensure that the interests of Lockton or their own interests do not conflict with the interests of the clients.

Associates may have a personal conflict of interest for a number of reasons including:

 Where an Associate, or their immediate relatives, carry out a prominent public function whether in the UK or abroad

 where Associates have been offered or accepted a gratuity or excessive entertainment