Associate Handbook 2018

 To assist in this aim, Lockton maintains appropriate systems and controls whereby Compliance requirements have been incorporated into Lockton’s processes, policies, procedures, work instructions and insurance practices, as well as providing relevant information, instruction, training, monitoring and supervision.

 Lockton considers that compliance is a management responsibility ranking equally with finance, marketing, and commercial matters.

 The Board has delegated the Head of CR&C to be responsible for compliance and risk management oversight, with direct access to the Chief Executive Officer. The Head of CR&C has authority to delegate the management of compliance functions to designated Compliance Officers but retains ultimate responsibility to the senior management for all aspects of compliance.  The Head of CR&C will regularly review working practices to monitor and measure compliance so as to ensure that all members of staff are aware of relevant compliance regulations and have access to them.  Business leaders are responsible for ensuring that all business activities within their business areas comply with applicable statutes, laws, and the rules and regulations of the relevant regulatory bodies; and for reporting all known (or suspected) non- compliance matters or breaches to the Head of CR&C at the earliest possible opportunity.  Each Associate has a responsibility to co-operate with management in implementing processes and procedures to ensure compliance with relevant regulations and to conduct their activities in such a manner that the Associate does not create an exposure for Lockton or themselves to a breach through careless or ill-considered action.

10.23 Lockton TCF policy statement

The fair treatment of customers is an integral part of the Lockton culture and is embedded in the behaviour, practices and documented policies and procedures. This also allows for the different treatment of customers that is flexible and fair depending on their different size, expertise and experience.

At Lockton our commitment is ‘We live service!’ and to ensure the fair treatment of customers in accordance with regulatory, agency and legal principles, Lockton will:

 conduct business with integrity and with due skill, care and diligence

pay due regard to the client's interests and needs

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 provide information in a way that is clear, fair and not misleading

 avoid conflicts of interest or ensure that conflicts are managed effectively

 arrange adequate protection of client assets where the Company is responsible for client assets, including client money; and

 maintain a complaints procedure to ensure fair treatment of clients who are not satisfied for any reason with the service provided