On 30 April 2014 the “Mifid” legislation, also known as “Twin Peaks II”, entered into force in the insurance sector in Belgium. This new legislation imposes new conduct rules and organisational requirements on insurance and insurance intermediaries in view of better protecting the client.
These conduct rules and requirements are based on the principle that insurance intermediaries and insurers must serve the interests of their clients in a loyal, equitable and professional manner when insurance intermediation services are offered.
AIG Europe Limited, Belgian Branch fully supports this principle. This document is drafted in this context, with the aim to inform our clients.
A. Your Insurer AIG and the supervisory authority
Your insurer is AIG Europe Limited, Belgian branch (hereafter: AIG). AIG Europe Limited is registered in England. Company number: 01486260. Registered Office: The AIG Building, 58 Fenchurch Street, London EC3M 4AB, United Kingdom. Belgian branch office located at Pleinlaan 11, 1050 Brussels, Belgium. RPM/RPR Brussels - VAT BE 0847.622.919.
AIG Europe Limited is an insurer authorised by the UK Prudential Regulation Authority, 20 Moorgate, Londen EC2R 6DA, UK. The Belgian branch of AIG Europe Limited is registered with the National Bank of Belgium (NBB) under the number 1136. The NBB is located at de Berlaimontlaan 14, 1000 Brussels.
In Belgium, AIG offers its products mainly via independent brokers, which need to respect the Mifid legislation on their turn.
B. In which language and how to communicate with AIG
You can communicate with AIG and obtain information in the language of your choice. This language will be the language of your insurance policy. The policyholder has the choice between Dutch, French and for some products English.
You can communicate with us via e-mail, mail, fax and phone (see “contact” section below).
C. Contact - Complaints handling
For concerns, information and questions regarding our products, your cover or our service you can contact your broker.
You can also contact AIG directly:
• By e-mail: firstname.lastname@example.org
• By phone: 02 739 9000
• By fax: 02 739 9393
• By mail: AIG Europe Limited, Pleinlaan 11, 1050 Brussels
At AIG we believe that you deserve to be treated in a courteous, fair and prompt manner. Our goal is to provide an excellent service to all of our customers.
If despite our efforts, there is ever an occasion when you feel let down, then please let us know immediately as we really value your feedback. AIG takes all customer complaints seriously. You can address your complaints to us:
• By e-mail: email@example.com
• By phone: 02 739 9690
• By fax: 02 739 9393
• By mail: AIG Europe Limited, Complaints, Pleinlaan 11, 1050 Brussels
Please always mention your policy number and/or your claims file number and, if available, the name of your contact person with AIG.
Complaints relating to the insurance policy can also be addressed in writing to the "Service Ombudsman Assurances asbl", square de Meeûs 35, 1000 Bruxelles, firstname.lastname@example.org, www.ombudsman.as.
Filing a complaint does not prejudice the possibility to start legal proceedings.
D. Conflict of interests policy
In order to protect your interests, AIG has implemented a policy to avoid potential conflicts of interests that exist or could raise between AIG and its clients or amongst its clients, and that could have a negative impact for the client.
The most important aspects of this conflict of interests policy are summarized here below.
1. What is a conflict of interest?
A conflict of interest in relation to the offering of insurance intermediation services can be defined as follows:
• A situation in which the interests of AIG or one of the members of the AIG group (including its directors, effective leaders, employees, contractors, etc.), and those of its clients differ or are opposed to one another;
• A situation in which the interest of a (group of) client(s) differs from the interest of another (group of) client(s).
2. How are conflicts of interests managed at AIG?
The management of conflicts of interests consists in different steps:
(i) Identification of conflicts of interests
An efficient management of conflicts of interests is only possible, provided that the conflicts of interests that could potentially arise, are known. AIG therefore identifies situations that could, in the context of the provision of insurance intermediation activities, lead to a conflict of interest. The listing thereof is managed by the Compliance department (with the cooperation of other departments).
Examples of conflicts of interests that are identified, are i.a.:
• Making profit or suffering loss at the detriment of clients;
• An interest at the result of an insurance intermediation service or transaction that differs from the interest of the client;
• A financial or other motive to give preference to the interests of other clients instead of the interests of the concerned client;
• The abuse of confidential information regarding clients;
• The receiving or the offering of inducements (money, goods and/or services) and/or gifts that could jeopardize a neutral position;
• The offering of unsuitable insurances or insurance policies that do not meet the requirements and needs of the client;
(ii) Measures to manage potential conflicts of interests
We expect from all our employees to adopt an independent position when dealing with clients.
To avoid that a potential conflict of interest could harm your interests or those of other clients, AIG has adopted appropriate organisational measures and compliance policies regarding i.a. the exchange and use of information, the training and supervision of its employees, the prevention of improper influencing, offering and/or receiving of inducements and/or gifts, etc.
(iii) Notification of conflicts of interests
In the event that it would be impossible to adequately manage a conflict of interest or if the adopted measures would not sufficiently protect the interests of the client, AIG will notify the client timely about the existence and particularities of the conflict of interest to allow the client to take an informed decision as to whether or not take out and/or pursue the intermediation service.
(iv) Registration of conflicts of interests
Conflicts of interest are notified to our compliance department. The conflicts of interest that could harm the clients’ interests, are kept in a central register.
(v) Training and communication
AIG provides its employees with trainings regarding the management of conflicts of interests and the rules and procedures are the object of specific communications to employees.
(vi) Policies and codes of conduct
The AIG group of companies has adopted codes of conduct and compliance policies that cover different activities and subject matters, which are implemented in relation to other specific obligations (e.g. policies on gifts and entertainment etc.). These codes of conduct contribute to the management of conflicts of interests.
AIG moreover pays attention to the remunerations and/or inducements that it could offer to or receive from its clients and/or third parties in the context of its insurance activities. AIG finds it important that such remunerations and/or inducements are only granted or received to the extent that they contribute tot the improvement of the service to the client. Also on this level AIG thus cares about the interest of the customer.
E. More information?
For more information, especially regarding our conflict of interests policy, you can contact us in writing by:
• e-mail: email@example.com
• mail: AIG Europe Limited, Belgian branch, Compliance department, Pleinlaan 11, 1050 Brussels.