Associate Handbook 2018

Lockton is further committed to meeting the requirements of the FCA TCF initiative to deliver improved outcomes for consumers.

The FCA focus on direct retail consumers because they require the greatest protection under regulation to ensure retail consumers receive fair treatment. Commercial customers and market participants are not included as they are considered likely to have the necessary experience and expertise to understand their own risks, with less need for regulatory protection and a greater obligation to look after their own interests. Lockton will apply improved outcomes to include commercial customers where it considers it fair and reasonable to do so.

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

Treating Customers Fairly

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This can be found on LockDocs under Procedures and Work Instructions.

10.24 Financial Crime

Lockton is committed to preventing financial crime, which includes fraud, bribery, corruption, and money laundering, malpractice and market abuse.

Lockton has a zero tolerance approach to financial crime and will investigate any instances identified in accordance with internal procedures and relevant laws and regulations. Lockton does not have any appetite for incurring fines, regulatory or legal censure, or adverse reputational damage. Senior management has ultimate responsibility and accountability for financial crime within their authority. Each division must maintain their systems and controls, identify instances of financial crime and be subject to risk based monitoring. Reasonable steps must be taken to verify the identity of clients, suppliers, agents and third parties. Relevant records should be retained and kept up-to-date as far as practicable. These procedures and controls must be compliant with local law and regulations. All Associates will be trained on and have access to information on the relevant legislation regarding financial crime, the recognition of suspicious activity, the requirements of local legislation and regulation, the group’s policy, standards and procedures. Certain modules such as anti-bribery and corruption and anti-money laundering are subject to an annual compulsory test. It is the responsibility of all Associates to report their knowledge or suspicions of unusual activity or financial crime to divisional management and / or group senior management or directly to the Head of CR&C as Money Laundering Reporting Officer. A private confidential report can also be made to the Whistleblowing Helpline.

Associates must take care not to warn or tip-off another person or client that is to be the subject of a suspicious activity report.

Any failure to report or tipping-off by an individual may amount to a crime under the Proceeds of Crime Act.