CODE OF CONDUCT

SCOPE

This policy applies to all Company colleagues and individuals/entities working with or acting on behalf of the Company (including any third parties). This includes interactions with government agencies and officials.

REFERENCE

This policy should be read in conjunction with the following documents:

  • Anti-Bribery and Corruption policy (PPC_PD-08).
  • Whistleblower policy (PPC_PD-09).
  • Disciplinary Action policy (PPC_PD-12).
  • Business Entertainment policy (PPC_PD-11).
  • Prevention of Sexual Harassment policy (PPC_PD-04).

BUSINESS ETHICS

All individuals/entities covered within the scope of this policy shall:

  • Obey all applicable laws, regulations, professional standards that govern our business.
  • Create and maintain culture of honesty, trust and integrity.
  • Act in good faith, responsibly, with due care, competence and diligence.
  • Never compromise or alter our ethical standards for any reason.
  • Value and expect high ethical standards, and encourage reporting of unethical or illegal behavior.
  • Always consider client interest above all else.

The Code sets out the standards of behavior required of all directors, officers, agents and colleagues whenever they are acting on Anviti’s behalf:

  • Always act with integrity; taking pride in what we do
    • Work in a way which positively impacts our clients, colleagues, communities.
  • Develop unmatched teams
    • Treat everyone with respect, dignity and sensitivity.
    • We are committed to encourage diversity and provide equal opportunities to all.
  • Deliver distinctive client value
    • Fair dealing and market practices.
    • Compete fairly and honestly for business.
    • Maintain confidentiality of client and business partner information.
    • Manage and avoid conflicts of interests.
  • Deliver business results with excellence o Maintain highest ethical standards.
  • Build capability through innovation.

CLIENT RELATIONSHIP

Anviti, and anyone acting on behalf of the company, will make sure to:

  • Conduct its dealings with clients with utmost good faith and integrity at all times.
  • Act with care and diligence.
  • Ensure that the client understands their relationship with the insurance broker and on whose behalf the insurance broker is acting.
  • Treat all information supplied by the prospective clients as completely confidential to themselves and to the insurer(s) to which the business is being offered.
  • Take appropriate steps to maintain the security of confidential documents in their possession.
  • Hold specific authority of client to develop terms.
  • Understand the type of client it is dealing with and the extent of the client’s awareness of risk and insurance.
  • Obtain written mandate from client to represent the client to the insurer and communicate the grant of a cover to the client after effecting insurance.
  • Obtain written mandate from client to represent the client to the insurer/ reinsurer; and confirm cover to the insurer after effecting re-insurance, and submit relevant reinsurance acceptance and placement slips.
  • Avoid conflict of interest.
  • Obtain necessary documents required under KYC norms.

SALES PRACTICES

Anviti, and anyone acting on behalf of the company, will make sure to:

  • Not employ agents or canvassers to bring in business.
  • Identify itself and explain as soon as possible the degree of choice in the products that are on offer.
  • Ensure that the client understands the type of service it can offer.
  • Ensure that the policy proposed is suitable to the needs of the prospective client.
  • Give advice only on those matters in which it is knowledgeable and seek or recommend other specialist for advice when necessary.
  • Not make inaccurate or unfair criticisms of any insurer or any member of the Insurance Brokers Association of India or member of such body of insurance brokers as approved by the Authority.
  • Explain why a policy or policies are proposed and provide comparisons in terms of price, cover or service where there is a choice of products.
  • State the period of cover for which the quotation remains valid if the proposed cover is not effected immediately.
  • Explain when and how the premium is payable and how such premium is to be collected, where another party is financing all or part of the premium, full details shall be given to the client including any obligations that the client may owe to that party.
  • Not indulge in sourcing of business by ourselves or through call centers by way of misleading calls or spurious calls.
  • Ensure that the consequences of non-disclosure and inaccuracies are pointed out to the prospective client.
  • Make it clear that all the answers or statements given are the client’s own responsibility.
  • Ask the client to check details of information given in the documents and request the client to make complete disclosure.
  • Explain to the client the importance of disclosing all subsequent changes that might affect the insurance through the duration of the policy.
  • Disclose, on behalf of the client, all material facts within our knowledge and give a fair presentation of the risk.
  • Explain the procedures to follow in the event of a loss.
  • Not indulge in any sort of money laundering activities.

INSURANCE POLICIES

Anviti, and anyone acting on behalf of the company, will make sure to:

  • Provide a list of insurers participating under the insurance contract and advise any subsequent changes thereafter.
  • Explain when the premium is payable with consequences of any delay in payments of premiums.
  • Ensure that the client pays the premium before the date specified under the contract.
  • Explain all the essential provisions of the cover afforded by the policy recommended so that the client understands the policy.
  • Draw attention of the client to any warranty, major or unusual restrictions, exclusions under the proposed policy and explain how the contract may be cancelled due to such non-disclosure.
  • Provide the client with written confirmation that insurance has been effected or if the final policy wording is not included then the same shall be forwarded as soon as possible.
  • Ensure that its client is aware of the expiry date of the insurance even if it chooses not to offer further cover to the client.
  • Ensure that renewal notices contain a warning about the duty of disclosure including the necessity to advise changes affecting the policy, which have occurred since the policy inception or the last renewal date.
  • Ensure that renewal notices contain a requirement for keeping a record (including copies of letters) of all information supplied to the insurer for the purpose of renewal of the contract.
  • Ensure that the client receives the insurer’s renewal invitation well in time before the expiry date.
  • Give prompt advice to the client of any requirements concerning the claim.
  • Forward any information received from the client regarding a claim or an incident that may give rise to a claim without delay, and in any event within three working days.
  • Advise the client without delay of the insurer’s decision or otherwise of a claim; and give all reasonable assistance to the client in pursuing the claim.

IRDAI GUIDELINES

All individuals/entities within the scope of this policy shall comply with the applicable IRDAI policies:

  • Broker Code of Conduct
  • Trained broking staff
  • Segregation of money
  • PI policy limits
  • Maintenance of records (accounting, business and internal controls)
  • Claims consultancy and Co-broking (restriction)
  • Sharing of reinsurance revenue (restriction)
  • Specific functions of the broker for insurance and reinsurance business
  • Code of conduct for client interaction and sales practice
  • Maintenance of records for client complaints, advertising etc.
  • Specific approvals required for on-line broking, telemarketing activities etc.
  • Adherence to KYC norms
  • Adherence to AML regulations

NON-DISCRIMINATION

At Anviti, we are committed to equal employment and advancement opportunities for all individuals and all employment decisions at Anviti are based on merit, qualifications and abilities. Anviti does not discriminate in employment opportunities or practices on the basis of race, color, religion, sex, national origin, age or disability.

This policy governs all aspects of employment, including selection, job assignment, compensation, discipline, termination, career advancement and access to benefits and training opportunities and resources.

Colleagues are encouraged to highlight questions or concerns about discrimination in the workplace and are free to escalate these issues to the attention of their respective Managers. Anyone found to be engaging in unlawful discrimination will be subject to disciplinary action, including termination of employment.

UNETHICAL CONDUCT

Colleagues are discouraged from engaging in any act or practice that is related to corruption and/or any prohibited business practice. Gifts, loans, fees, rewards, any advantages or offers of hospitality must generally be refused (unless it is an official recognition) if they contravene with the company values and policies.

NON-DISCLOSURE/CONFIDENTIALITY

The protection of confidential business information and trade secrets is vital to the interests and success of Anviti. Such confidential information includes, but is not limited to, the following examples:

  • Compensation data.
  • Financial information.
  • Marketing strategies.
  • Pending projects and proposals.
  • Proprietary design and development processes.
  • Personnel records.
  • Conversations between any persons associated with the Company.

All colleagues are required to sign a Non-Disclosure Agreement (NDA) as a pre-condition to employment at Anviti and would be personally liable for breach of this arrangement. Any colleague involved in improper use or disclosure of trade secrets or confidential business information will be subject to disciplinary action, including termination of employment and legal action, even if they do not directly benefit from the disclosed information.

OUTSIDE EMPLOYMENT

Colleagues are not permitted to hold any external assignments or jobs, unless authorized by Anviti. Anviti’s office space, equipment and materials may not to be used for any external assignments or employment.

DRESS CODE / GROOMING / CONDUCT

Dress, grooming, and personal cleanliness standards contribute to the morale of all colleagues and affect the business image the company presents to its customers and visitors.

Anviti expects every colleague to be in business formal / business casual / smart casual attire at all times when in the office premises. If a colleague has business/customer meetings or is working in the customer premises, then only business formal attire is recommended.

Any attire which would be interpreted as obscene is strictly not allowed. Also, attire that affects the professional atmosphere (e.g. torn jeans, shorts, dirty shoes, slippers, floaters etc.) is to be strictly avoided.

Note that any actions of the following nature would invite immediate action as per the Disciplinary Action policy:

  • Long absence from the office without approved leave (more than 7 working days).
  • Coming to the office in an inebriated condition.
  • Flouting company policies and/or repeat incidents and/or chronic failure to observe company policies.

SECURITY OF PERSONAL BELONGINGS

All colleagues are responsible for the safety of their belongings.

VISITORS AT WORKPLACE

Only authorized visitors are allowed in the workplace.

OTHER GUIDELINES

Colleague behavior at work (and in certain limited respects outside of work) is the key concern as encompassed by but not limited to:

  • Personal behavior and performance e.g. attendance, co-operation, commitment and honesty.
  • Co-operation with supervisors and management: e.g. health and safety, security, operational procedures, harassment/intimidation.
  • Work-based relationships: e.g. with other colleagues, managers, customers and suppliers.
  • Respect for Company and customer/supplier data and property: e.g. security, usage, and confidentiality.
  • Respect for copyright materials especially proprietary software: e.g. use of only licensed software.
  • Proper protection of all Information assets and prevention of breach of principles of confidentiality, integrity and availability of information assets (including, but not limited to Company/Customer IP, Confidential information (soft/hard form) and customer/partner/vendor supplied items).
  • Behavior prejudicial to the interest of the Company, other colleagues, customers and suppliers will lead, at management’s discretion, to the appropriate disciplinary action in accordance with the disciplinary procedure.

Definitions

  • Government official/agency/entity/client:
    • Any political party or official thereof.
    • Any candidate for political office.
    • An Colleague or officer of an entity owned or controlled by the government.
    • An officer of any public organization.
    • An officer of an entity owned or controlled by the government.
    • An officer of the statutory regulators e.g. IRDA, RBI, Income tax etc.
    • A person who is acting in an official capacity of any government or a government controlled organization.
    • Any person, entity or organization who or which is named, suggested or for the benefit of the above listed categories.

If there is a doubt regarding the ownership of the entity, then the following criteria need to be used.

  • If the government holding is less than 10%, then it is not to be treated as a government entity.
  • If the government ownership is between 10% and 25% without any government nominee on the Board, then it is not to be treated as a government entity.
  • If the government ownership is more than 26%, then it is to be treated as a government entity.

Any queries seeking clarifications on any aspect of this policy may be directed to the Compliance Officer or a PPC representative.