Conflicts of Interest

Our approach.

We take the management of conflicts of interest seriously and recognise that it’s not only vital to ensuring that we are acting in the best interests of our clients at all times - but also to ensure that we are complying with our regulatory and professional obligations. We don’t see this as a “box ticking” exercise and it’s at the heart of what we do and how we interact with our clients.

The identification and management of potential/actual conflicts of interest is embedded in our client take-on process and we also have measures in place to ensure that conflicts continue to be considered and monitored at all stages of a client lifecycle. In addition, conflicts are a significant part of our considerations when developing new propositions.

We have a mandatory policy in place which colleagues across all of our group companies are required to follow (both in spirit and in strict compliance with its requirements). At the heart of this is ensuring that:

• all potential, perceived and actual conflicts are identified as early as possible;
•  we will only act where we can do so without inhibition and in the best interests of our clients;
•  we are open and transparent with our clients; and
•  we work with the relevant parties to agree and implement measures to manage any potential, perceived or actual conflicts (as you would expect, such measures will include ensuring that we are complying with any professional/regulatory obligations we may have).

As you might expect, our internal requirements for the management of conflicts apply not only to client conflicts but also other areas where conflicts could arise- for example the selection of suppliers and the potential for conflict between the interests of an individual and the interests of a client/the firm.

Our people

We have dedicated and trained conflicts champions for each of our Business Units who are responsible for providing their respective Business Units with advice, guidance and training on conflicts related issues. In addition, we have clear escalation points for more complex issues (whether to a member of our Management Board, Senior Actuary or legal team).

Last updated: 6 November 2020