In accordance with the MiFID Directive, HDI Global SE, Branch for Belgium (hereinafter HDI) has taken the required measures to ensure that its business relationships take place in a correct and honest way, in line with the interests of its clients. One of the means to this end is for HDI to continually be alert to possible conflicts of interest. Consequently, HDI will implement all the administrative measures needed to identify, prevent and manage conflicts of interest.
Below follows a description of measures and stipulations contained in the HDI conflict of interest policy that aim to protect the interests of its clients should a conflict of interest arise.
2. What is a conflict of interest?
A conflict of interest exists when, in the performance of HDI's activities, the interests of the company, its clients and/or its employees conflict directly or indirectly, and the company is required to act in the interest of the client.
A conflict of interest arises when the company benefits from a situation in which the client runs a substantial risk of suffering damage.
If, despite the organisational measures taken by the company, a conflict of interest arises, the client will be informed in detail of the situation.
3. Possible conflicts of interest
A number of possible conflicts of interest within HDI's business activity were identified in order to take the measures required to prevent and effectively manage them. Possible conflicts of interest can arise in the interaction between the various activities.
Conflicts of interest can exist between:
- HDI and its shareholders or directors
- HDI and its subsidiaries or other affiliated companies
- HDI and its policyholders
- HDI and its employees
- HDI and the insurance intermediaries
a) Company relations
The Belgian Company Code, the HDI articles of association and Circular PPB-2007-6-CPB-CPA on good governance foresee various regulations involving possible conflicts of interest between HDI and its shareholders, directors and subsidiaries.
Correct execution of the insurance contracts to which policyholders can appeal.
If multiple policyholders are involved in the same damage claim, strictly delimited management will be applied in order not to damage the interests of the insured parties, and the affected policyholders will be informed of this in a timely manner.
HDI expects its employees to make a clear distinction between professional and personal activities, and to always ensure that personal interests and the interests of HDI do not become entwined.
When taking decisions, employees must promote the interests of the company as much as possible.
Consequently, no arrangements or policies may be made in which personal – direct or otherwise – involvement exists that could result in a conflict of interest.
d) Insurance intermediaries / persons offering insurance mediation services
Insurance intermediaries must promote the interests of clients in a loyal, fair and professional way; they must provide clients with sufficient information on the products offered, and this information must be correct, clear and not misleading.
Insurance intermediaries must also transparently inform clients concerning the compensation (“inducements”) they receive for the services they provide.
4. Managing possible conflicts of interest
HDI has implemented measures/suitable procedures to manage possible conflicts of interest.
4.1 Procedures in the case of conflicts of interest
HDI has given its employees written guidelines for preventing and handling conflicts of interest in order to adequately manage possible conflict situations.
These guidelines can be found among others in:
- the Working Regulations;
- the Deontological Code that requires our employees to always act in the interests of clients; employees are required to comply with
- this code by virtue of their employment;
- an adapted compensation policy that ensures independence on the part of our employees;
- general application of the four-eye principle.
The Compliance Officer monitors compliance with these procedures and if necessary will adapt them.
4.2 Training and supervision
HDI ensures that the relevant employees receive suitable training such that they are fully aware of their responsibilities and obligations, and are able to adequately manage conflicts of interest.
4.3 Information barriers (“Chinese walls”)
The information barriers in place at HDI are imposed via specific procedures that prohibit confidential information from being released by HDI employees to other employees of HDI or third parties in the context of their function.
This prevents the improper communication of confidential information.
This applies among others to the information concerning one and the same claim file that involves multiple policyholders with contradictory interests.
These information barriers are described in the Deontological Code.
4.4 Data protection and confidential information
Confidential internal information about the Talanx Group, clients or business relations that is acquired in the context of the function is protected and may not be used for personal advantage or for the advantage of third parties.
The legal and internal guidelines concerning the confidentiality, handling and processing of personal data must be followed..
HDI will provide confidential information to external parties only insofar as this is legally required or allowed.
HDI undertakes to proceed in accordance with the data protection regulation.
As an employer, HDI protects all the personal data pertaining to its employees in accordance with the applicable legal and regulatory provisions.
HDI attaches great importance to the transparency of the relations its personnel have with third parties and especially to the integrity of its employees.
HDI employees shall accept no gifts or donations unless these can be considered as customary and if they do not have excessive value.
All forms of bribery and corruption are unacceptable.
4.6 Sideline activities
HDI employees must always separate the interests of the company from personal interests or other paid activities; employees may not make commitments outside the group if these might lead to conflicting interests with HDI.
If a function or activity could be the occasion for a conflict of interest, the company will take suitable measures to prevent this.
4.7 Whistleblower programme
Employees who note a breach of company values and/or the internal code of conduct, or note unethical or illegal behaviour at HDI, may report this to the Compliance Officer or directly to Talanx.
The report will be investigated and where applicable the required measures will be taken to address the detected infringement or the unethical or illegal behaviour.
4.8 Handling of complaints
Complaints will be handled with the required attention, and (legal) problems that could surface on the occasion of a complaint shall be resolved as quickly as possible.
An overview of the complaints received is maintained by the Compliance Officer.
HDI will regularly, and at least once per year, verify that the content of its policy on conflicts of interest is still up to date.
This policy will be adapted in the case of changes to the legal framework or to our activities.