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Code of conduct (Insurance and CFSMS)

Last reviewed on 06 February 2018

This document sets out what we expect from you and all our colleagues.

This document forms part of your terms and conditions of employment that you agreed to when signing your principal statement of terms and conditions of employment.

If you fail to follow the practices and procedures set out within this document it may result in you being managed in line with the misconduct policy which may ultimately lead to your dismissal.

If you have any questions relating to this document, please talk to your manager.

If you feel there is a conflict between the information set out in this section and any legislation or local practices again please raise this with your manager or the HR team.

This section contains information on the following subjects:

  • Treating the customer fairly.
  • European insurance mediation directive.
  • Acting in the organisation’s interests.
  • Conflicts of interest.
  • Fair practices.
  • Risk management.
  • Management of personal finances.
  • Financial crime.
  • Information security.
  • Communications (including contact with our regulators)

Treating the Customer Fairly

Treating customers fairly is at the heart of our strategy. Putting our customers first in all we do is key to ensuring our customers are treated fairly. Our approach to putting customers first is defined for all colleagues as follows:

  • I put myself firmly in our customers’ shoes before I act..
  • I understand how I affect the experience we create for our customers.
  • I play my part in treating our customers fairly.
  • I am reliable, flexible and understand without a doubt that we exist for our customers.
  • I understand our products and how we compare with our competitors.
  • I don’t assume to know what our customers want.
  • I don’t ignore customer feedback

We also measure ourselves against our Customer Promise. We want our customers to say we’ve been easy, fair, personal and responsible. The experience we need to build for our customers must deliver this at every interaction.

Easy

We help our customers in a smooth, easy and straightforward way and make things simple to understand. We minimise the number of contacts customers need to make to get what they want. We don’t make it difficult for customers to change, renew or close their products with us and we are always approachable and helpful.

Fair

We’re fair because we do what’s best for our customers and not just what’s best for profit. We’re upfront and honest in the way we deal with customers and through our products and services they get a fair deal and are treated fairly. We always do what we say we are going to do.

Personal

We don’t ‘process’ our customers – we care for them by valuing them and providing advice and services that are relevant to our customers’ needs, not just what’s easiest for us. We listen and understand our customers and make them feel like we are always working in their best interests. We recognise and respect our customers as the individuals they are.

Responsible

We genuinely take ethical and environmental issues into account when looking after customers’ interests and operating our business. We do what’s right for our customers and society and customers know they can trust us with their money.

However, fairness does not mean always being the cheapest or the best, nor does it mean always giving customers what they want as a satisfied customer may not have been treated fairly. It doesn’t mean treating customers all the same, catering for the lowest common denominator or taking away the customer’s responsibility to make their own financial decisions. Fairness must be a balance between what is in the interests of the individual customer and of the business as a whole.

Roles Covered by the European Insurance Mediation Directive

There are some roles within our business that are governed by the FCA’s rules derived from the European Insurance Mediation Directive. If this Directive has a part to play in your new role your manager will let you know.

We are required to ensure that any individuals responsible for, or directly involved in, ‘insurance mediation activities’ are of ‘good repute’.

The scope of ‘insurance mediation activities’ is broad, but includes advising on or arranging contracts of insurance. As an example, colleagues in customer facing roles are likely to be involved in arranging contracts of insurance, as are those involved in arranging reinsurance cover.

If you are responsible for, or directly involved in insurance activities that are covered by the directive, you will be asked to complete (when starting your role and on an annual basis) a ‘Fitness and Propriety Questionnaire’. This will cover, for example, criminal offences linked to crimes against property or financial activities, and bankruptcy, and is designed to demonstrate whether or not you meet the FCA’s ‘good repute’ requirements.

Whilst you are required to complete the questionnaire annually, you mustn’t wait until you receive it to make your manager aware of any event that may or will affect your ability to meet the requirements.

Failure to meet these ‘good repute’ requirements may result in suspension from your role pending consideration of your individual circumstances and of the options available e.g. permanent redeployment into an alternative role. However where no alternative options are available or appropriate we may have to consider the termination of your contract.

Acting in the Organisation’s Interests

While you are working with us you are expected to act at all times with integrity and honesty in your business and personal dealings to prevent our reputation being damaged by your actions.

You must not use company property, information, or position for personal gain, or to compete with our business directly or indirectly. You have a responsibility to act in a way that properly advances our interests when the opportunity to do so arises.

During your working hours, the use of personal mobile phones, or other devices should not interfere with you carrying out your role.

Conflict of interest

A conflict of interest exists where a person’s private interest interferes with, or could interfere with, the interests of our business or its customers, e.g. influencing us to use a supplier that is owned by a family member or friend.

We want to protect you from having your integrity questioned, which is why we ask you to speak to your manager if you feel there may be a conflict of interest. This will allow your manager to assess the situation and take any appropriate actions. In the unfortunate event of a conflict of interest causes damage to our business or its reputation and it not being raised with your manager, this may result in the misconduct policy being used to manage the situation.

Below are some examples of where a conflict of interest may arise; this is not an exhaustive list of examples and you are asked to talk to your manager if you are concerned about any conflicts of interest:

Your account (an account is any type of product including insurance policies) – To prevent your actions being questioned you should not carry out any transactions on your own accounts other than as a customer using normal customer channels such as internet banking.

Friend and family member accounts (an account is any type of product including insurance policies) – You may not view or carry out transactions on the accounts of family members or friends. Should you have third party authority to access a customer account this must only be done through normal customer channels.

Customer accounts – You may only access or carry out transactions on a customer’s account with the prior authority of the account holder through regular channels and/ or if required to do so for the purpose of carrying out your role. You should not access customer’s records, even if your user ID allows you access, unless there is a business need to do so.

Investments – If you wish to invest money in a company, you should not invest money in companies whose business would cause a conflict of interest with ours, e.g. a supplier, or a company owned by someone who is a customer of our business.

Also, you should not be advising your partner or any other member of your family, whether as a trustee or otherwise in a professional capacity in relation to their investments. If you are in any doubt about your investments, you must ask your manager for advice.

Relationships at work – There are examples in all workplaces where relatives, husbands and wives and partners work in the same business. This can sometimes cause real or perceived conflicts of interest. These are most likely to arise where the parties in the relationship are in a direct or indirect management relationship or are involved in the same activities, processes or controls. Whether relationships at work are or can be perceived as a conflict of interest depends on the individual circumstances. If you have a relationship with another colleague, we ask that you let your manager know within a reasonable timeframe of any:

  • personal relationship that might result in your objectivity or integrity being challenged
  • relationships that you form with a colleague with whom you have a management relationship, whether direct or indirect or where you work on the same processes and systems.

Your manager will be able to take the appropriate steps to protect your integrity being brought into question. If for any reason you feel that you are unable to talk to your manager, then a member of the HR team will be able to help you.

Additional or secondary employment – If you wish to take up any work with another company, set up a business or take up a directorship, you should discuss this with your manager and will need to obtain written permission before commencing any secondary employment. This is to ensure that the additional work will not interfere with your commitments to us or adversely affect any relationships with customers.

There are some circumstances where we may refuse permission for you to undertake secondary employment. These circumstances may arise in the following situations:

a conflict of interest may arise, e.g. you will be working for a direct competitor the employment is likely to damage your reputation or the reputation of our business your work performance is likely to be adversely affected the working arrangement fails to meet the requirements of the Working Time Regulations.

Fair Practices

Bequests

You are only allowed to accept a bequest (e.g. to be left something) under the terms of a customer’s will if you can clearly demonstrate that the customer’s wishes were not influenced, in any way, by activities you undertook whilst working for here.

If you are found to have exerted inappropriate influence over the customer you will be advised to decline the bequest and the matter will be managed within the misconduct policy.

Gifts and Hospitality

The purpose of offering business gifts and hospitality is to further business relationships and this must not conflict with our duty to our customers.

There are monetary limits placed on the value of gifts and hospitality that you may accept from external individuals and companies. This is to minimise the risk of bribery and the impact on our organisation, or perceived bribery and the reputational damage this could cause.

If you are offered a gift or hospitality and the monetary value exceeds the limit set out in the gifts and hospitality policy, you must notify your manager before accepting and always record whether they are accepted or declined. The details of any offer of gift or hospitality must be recorded on the gifts and hospitality register which can be found on the Intranet.

Money (in all its forms, e.g. cash, cheques or vouchers) must not be offered or accepted as a gift and if you are offered money you must inform your manager.

You should be comfortable that the gift or hospitality you are being offered is for a genuine business reason, does not create expectations and would be appropriate to disclose to our customers. If in doubt, refer to your manager for guidance before offering or accepting business gifts or hospitality.

It is never acceptable to offer or accept services, benefits, gifts or hospitality in circumstances in which it may be construed as an incentive to influence a business judgement in your favour or that of a third party. If this occurs, it will be investigated and may be managed within the misconduct policy.

For further information please refer to the Gifts and Hospitality Policy on the Intranet.

Risk Management

Managing both internal and external risk is essential to enable our business to remain financially strong and achieve its objectives. Risk Management is a planned and systematic approach to identifying, evaluating and controlling risk. There will be frameworks, processes and controls in place within your department that have been agreed to manage risk in the area you work. These will be explained to you by your manager and while working for us we expect you to follow them.

Management of your Personal Finances

We expect you to manage your personal finances in a way that does not negatively impact on your ability to carry out your role, expose our business to unnecessary risk or lead to an individual’s integrity being questioned.

If you are experiencing any sort of financial difficulty, we have a number of sources of help advice and support available. It’s always a good idea to seek help as early as possible as there is often more that can be done and seeking advice need not be embarrassing.

For all colleagues within the organisation the following areas of support are available:

If you hold a Co-operative Bank Account, the Money Management team within Debt Management will support you if you are in early stages of financial difficulty. The team can be contacted on 0845 606 6435 between the hours of 8am and 7pm Monday – Friday and 9am – 1pm Saturday. There are a wide range of things they can do to help and may be able to provide some short-term support.

If your debt problems are so great that you are considering or undergoing a formal insolvency process including Bankruptcy and Individual Voluntary Agreement, you must seek assistance. Advice can be obtained from the following external organisations:

Your manager is also a good first point of contact, they will be able to advise you of the support available and in some business areas advise of any additional policies that may be used to support you and manage any risk to the business. This is of particular importance for colleagues who undergo ‘fitness and propriety’ checks to ensure they meet the FCA’s ‘good repute’ requirements.

Financial Crime

Preventing Fraud

Every business in the financial sector must take steps to reduce the risk of fraud by colleagues, customers or members of the public. Our customers trust us to look after their money and data and to proactively investigate any unusual activity on their accounts.

In some areas of the business, to help us prevent financial crime we may ask you not leave personal items such as handbags, mobiles and diaries on or around your desktop, either attended or unattended. At all times, you must strictly adhere to customer identification procedures to ensure customers’ money and data are protected.

If you suspect that someone is involved in a fraudulent activity, you must immediately report this to your manager or raise your concerns in the way described in the Whistleblowing Policy. Examples of when to talk to your manager are if you suspect:

  • someone has been approached to give customer account information to unauthorised persons inside or outside the organisation
  • a customer’s security code and/or SPI (Secure Personal Information) / URN (unique reference number) have been compromised and could be used to gain funds fraudulently
  • a process is not being followed appropriately, which could have implications for a customer or the organisation.

Fraud is a criminal offence and anyone suspected of fraudulent activity, either as an employee or as a customer, will be investigated. In addition to an internal investigation, the matter and any potential evidence will be referred to the police for prosecution where appropriate. We may also provide details of any fraud committed by colleagues to external, industry-wide fraud databases.

Fraud prevention databases have been established for the purpose of allowing employers to share data on their employee fraud cases. Should our investigations identify fraud or the commission of any criminal offence by you when applying for, or during the course of your employment with us, we will record the details of this on the relevant fraud prevention databases. This information may be accessed from the UK and other countries and used by law enforcement agencies and by us and other employers (and potential employers) to prevent fraud.

For more information on fraud prevention refer to the fraud policy on the Intranet.

If you want to receive details of the relevant fraud prevention databases through which we share information, then please contact HR Services on 0330 606 1001.

Money Laundering

Money laundering is a process by which criminals attempt to hide and disguise the true origin and ownership of the profits from their criminal activities to avoid prosecution, conviction and confiscation of the funds.

All financial organisations, are required by law to prevent and detect money laundering or the financing of terrorism through their products and services. If an organisation is used for money laundering or to finance terrorism, they can face legal and regulatory penalties along with reputational damage.

There are three individual principle offences detailed in the regulations:

  • Money laundering or assisting a money launderer.
  • Tipping off or prejudicing an investigation.
  • Failure to report suspicions.

You must always keep alert and be aware of any suspicious activities so that you can make a report should you hold a suspicion.

We have a legal duty and regulatory obligation to ensure that we have strict anti-money laundering and counter terrorist financing measures, systems, procedures and controls in place to help combat these risks. These controls need to be proportionate, risk-based and followed effectively to reduce the risk to our business.

New colleagues will receive training on the prevention and detection of money laundering; this training is repeated on a regular basis by all colleagues. Where specific procedures exist to prevent money laundering, your manager will discuss these with you.

If you have any suspicions of money laundering or terrorist financing taking place, or being attempted within our business, this must be reported immediately through the Risk Event Reporting process.

Mandatory Core Knowledge Training

We have a responsibility to provide all colleagues with the correct amount of mandatory core knowledge training. The process around providing mandatory knowledge training demonstrates to our regulators that as a business we have a robust framework and process in place that allows users to have a sufficient understanding around the financial sector we operate in and the principles that govern us. This is achieved through a curriculum of mandatory training modules that all colleagues must complete at the beginning of their employment and then on an annual basis thereafter. Your manager will be able to provide you with more information on the process you will need to follow. Upon receipt of an invite, it is important that you complete the mandatory core knowledge training within the agreed timescales. If this is not completed, it will be escalated to your manager.

Bribery and Corruption

Bribery is the offering, promise of or acceptance of any incentive, gift or advantage for personal gain, corporate gain or a breach of trust, all of which go against our bribery policy. The Bribery Act 2010 provides for four bribery offences:

  • Bribing – the offering, promising or giving of an advantage.
  • Being bribed – requesting or agreeing to receive or accepting an advantage.
  • Bribing a foreign public official.

Where an organisation fails to prevent bribery from being committed. It does not matter whether the offence was committed in the UK or abroad. As an organisation, we must comply with the requirements set out in the Bribery Act 2010.

It is never acceptable to offer, give or accept services, benefits, gifts or hospitality in circumstances in which it may be construed as an inducement to favourably influence a business judgement. If in doubt, you must ask your manager for advice in advance or refer to the Bribery Policy.

Not complying with the Bribery Act is a criminal offence and carries strong punishment. It could lead to reputational damage to our business, negative impact on our customers, imprisonment of individual employees and/or directors and unlimited fines.

Whistleblowing

We are committed to carrying out our business in a responsible, honest and ethical way. If you have a genuine and serious concern regarding breaches of legal or regulatory obligations, including but not limited to, health and safety, criminal behaviour – including internal fraud - dishonesty or breaches of internal policy, then you are strongly encouraged to raise your concerns.

There are a number of ways of doing this:

Option 1: You should raise your concerns to your manager in the first instance or, if this is not appropriate, to a senior manager within your department or directorate. Alternatively there are contact details of the organisation’s dedicated internal whistleblowing contacts in the Whistleblowing Policy which is available on the Intranet. You may raise your concerns verbally or in writing.

Option 2: If the nature of the matter is such that you cannot raise it with your manager or another internal contact, or if you have followed the channels in Option 1 and you still have concerns, please contact “Speak Up” on 0800 374199. “Speak up” is an anonymous, free and confidential service operated by Expolink.

It is a completely independent organisation with impartial staff trained to handle calls relating to disclosures of wrongdoing made in the public interest. You can phone in complete confidence knowing that your call will not be traced or recorded. All information, with the exception of your name if you so wish, will be passed by Expolink to our Risk and Internal Audit teams for further enquiry or investigation.

Option 3: If you have followed and concluded steps 1and 2 and you reasonably believe that appropriate action has not been taken to address the concerns you have raised, then you should report the matter to the proper Relevant Authority. This is most likely to be the Financial Conduct Authority, but a full list of public bodies to whom you can make a disclosure is available in the Whistleblowing Policy.

Your concerns will be taken seriously and, where appropriate, investigated further. If you have a reported a reasonable belief that any of the actions detailed above are taking place, then you will not be penalised or suffer a detriment in your employment because you have raised your concerns.

More information can be found in the Whistleblowing Policy, which is available on the Intranet, or ask your manager for a copy.

Information Security

The protection of customer and colleague information is extremely important to us. It must all be treated as confidential. We don’t want sensitive or confidential information to be used in a way that could have a negative impact on a customer or colleague. Imagine how you would feel finding out that a company you trusted to look after your personal information had lost it. Would you be happy about this?

This is why it is vital you understand how you can protect information while working for our business. Everyone has a responsibility to handle sensitive and confidential data securely and to not expose our business to the risk of data loss, and it is important for you to familiarise yourself with our policies and ensure you follow them.

The policies that support us in doing this are the Information Risk Policy and the Acceptable Use Policy. These can be found on the Intranet and provide guidelines on how to protect and handle confidential data.

If you have any concerns about your ability to do this follow these controls or have any suggestions for improvement in your local working area, you should discuss these with your manager.

Using Office Systems

You must always use the office systems in a responsible way and follow any procedures that are in place.

Office systems including computers, telephones, email and internet facilities are provided for the purpose of doing your job. Their misuse can potentially create liability for the organisation and put its reputation at risk.

You must not use your system access privileges to view your own product information or data except where you are specifically authorised to do so.

You must keep secret and never loan or share your access mechanisms e.g. user id and password to anyone as you are personally responsible for any actions that take place on your user id.

Limited, appropriate personal use of the systems is acceptable but must not interfere with or disrupt your work activities or those of your colleagues. However all use of the systems, including email, the internet, voicemail and text messages is monitored and therefore cannot be considered as private.

By passing or causing compromise of any security mechanisms/ processes, whether physical or electronic, or transmitting confidential data will be treated seriously and may result in appropriate conversations taking place that could lead to the termination of your contract. It may also be considered a criminal offence.

Communications

While employed with us you are expected at all times to maintain the highest standards of professionalism and integrity in your communications with colleagues, customers, clients and the public. These standards apply to communications that are verbal, written and electronic – including but not limited to faxes, email, texts, telephone, voicemail and the internet. Business records and communications often become public and you should always avoid exaggeration, insulting remarks, guesswork or any inappropriate comments, whether in systems or documents. This also applies to any communications or comments you make outside of work, for example via social networking sites where these have or could damage the reputation of our business.

In relation to your role you are not permitted to make unauthorised contact with our regulators. Any communications with the regulators will need to be sanctioned by the appropriate Executive. For further information please contact the Regulatory Risk Advice Team.

Further Information

If you have any questions about the information contained within this booklet, please talk to your manager in the first instance. Other sources of information include:

HR Services – 0330 606 1001
Trade Unions - NACO 0161 351 7900
Unite - 0161 903 2085
Employee Assistance Programme, operated by Validium - 0800 970 1030

If you need this information in an alternative format please contact your manager.