MANAGING CONFLICTS OF INTEREST

LMB Insurance (“the Company”) upholds the highest professional standards in confidentiality and compliance when managing client and third-party information and business best practices. We also ensure that the Insurers with which we place business are compliant through every step of the policy placement and management process.
 

Defining conflicts of interest
LMB’s conflicts of interest policy establishes the framework for managing business conflicts of interests between clients and describes the process by which potential conflicts will be resolved. This policy applies to all directors and colleagues of the company. LMB is committed to establishing and maintaining effective systems, controls and procedures which are designed to identify, prevent and manage conflicts of interest throughout our business operations.

We define a business conflict of interest as a situation in which an engagement with a particular client result in an interest, real or apparent, that is contrary to the interests of LMB or its clients.

Business conflicts of interest may include:

• Conflicts of interest which exist between clients;
• Conflicts of interest which exist between clients and insurers; and
• Conflicts of interest which exist between colleagues and insurers.

Identifying conflicts of interest
Circumstances or considerations that may qualify as a conflict of interest include whether:

• LMB could make a financial gain or avoid a financial loss at the expense of a client;
• LMB has an interest in the outcome of a service provided to the client, which is not mutually beneficial with the client’s interest in the outcome;
• The interest of an LMB client is different from the interest of another LMB client involved in the same matter of interest; and
• The product or service provided to the client will require LMB to investigate, offer an opinion or question the work performed on behalf of another LMB client.
   

Managing conflicts of interest
Our procedures for identifying, preventing and managing business conflicts of interest include:

• Addressing conflicts that are deemed significant based on an assessment of the level of risk involved in offering a particular product or service to a client;
• Identifying which products or services have the most risk for a potential conflict; and
• Contain a description of the communication protocols and information systems that will be used to manage potential conflicts.

Once a business conflict of interest has been identified, LMB Insurance must manage the conflict promptly and immediately notify the clients to which the conflict pertains.

One or more of the following procedures may provide potential resolutions for a conflict:

• Disclosing relationships to the relevant parties;
• Obtaining consent from the party at risk;
• Establishing information barriers (ethical boundaries); or
• Declining the service engagement or policy placement opportunity with the client.

Transparency and auditing
LMB will be required to maintain adequate records of the actions taken to manage a conflict. These records may include correspondence with a client in any form, including email or disclosures of contracts. LMB will make appropriate changes to its policies based on each annual review, as required.