The “MiFID” legislation (also known as “Twin Peaks”) and the “IDD” legislation (pursuant to the insurance distribution directive) impact the Belgian insurance sector by imposing conduct rules and organisational requirements on insurers and insurance intermediaries to better protect policyholders. These conduct rules and requirements are based on the principle that insurance intermediaries and insurers must act in the best interests of their customers in an honest, fair and professional manner when insurance distribution services are offered.
The Belgian branch of AIG Europe SA fully supports this principle, and this document has been drafted to notify our customers of the same.
A. Your Insurer AIG and its supervisory authority
Your insurer is the Belgian branch of AIG Europe SA1 (AIG). AIG Europe SA is registered in Luxembourg with company number: RCS n° B 218806 whose registered office is at 35D, Avenue John F. Kennedy, 1855 Luxembourg. The Belgian branch office is located at Pleinlaan 11, 1050 Brussels, Belgium. RPM/RPR Brussels - VAT BE 0692.816.659.
AIG Europe SA has been authorised as an insurer by the Luxembourg Ministry of Finances, and is under the control of the Commissariat Aux Assurances, 7, boulevard Joseph II, L-1840 Luxembourg, GH Luxembourg, Tel: (+352) 22 69 11 - 1, firstname.lastname@example.org, http://www.caa.lu/. AIG Europe SA has also been authorised to establish branches in several countries, including Belgium. The Belgian branch of AIG Europe SA is registered with the National Bank of Belgium (NBB) under the number 3084. The NBB is located at de Berlaimontlaan 14, 1000 Brussels.
The annual reports on the solvency and financial situation of AIG Europe SA, if available, can be found at http://www.aig.lu/.
In Belgium, AIG offers its products mainly via independent brokers, who also need to comply with the Mifid/IDD legislation. AIG compensates these brokers through commissions which are a percentage of premium, at the time of each purchase and renewal of a particular insurance policy. Outside of specific insurance transactions, AIG may also, from time to time, obtain services from brokers with whom it works, for which it pays a fee.
1 On 1 December 2018 AIG Europe Limited, a company incorporated under the laws of England and Wales with its registered office at The AIG Building, 58 Fenchurch Street, London EC3M 4AB, United Kingdom and authorized by the UK Prudential Regulation Authority, has transferred its insurance portfolio underwritten by its European branches (excluding the United Kingdom) to AIG Europe SA via a cross-border merger.
B. Communicating with AIG
Unless AIG has informed you otherwise, you may communicate with AIG and obtain information in the language in which your insurance policy is written. The policyholder has in principle the choice between Dutch, French or, for some products, English.
You may communicate with us via e-mail, post, fax and phone (see the “contact” section below). If you contact us or your broker via e-mail, we will assume that you specifically opt for a communication (including for the provision of information) via electronic means, unless you advise us otherwise.
AIG does not provide any advice regarding proposed or sold insurance products.
D. Contact and Complaints Handling
For information or questions regarding our products or regarding your cover you may contact your broker.
You may also contact AIG directly:
· By e-mail: email@example.com
· By phone: 02 739 9000
· By fax: 02 739 9393
· By post: AIG Europe SA, 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 by us, then please let us know immediately as we really value your feedback. AIG takes all customer complaints seriously. You may address your complaints to us:
· By e-mail: firstname.lastname@example.org
· By phone: 02 739 9690
· By fax: 02 739 9393
· By post: AIG Europe SA, Complaints, Pleinlaan 11, 1050 Brussels
When contacting us, please provide your policy number and/or your claims file number and, if available, the name of the person you have been dealing with in AIG.
Complaints relating to your insurance policy can also be addressed in writing to the "Service Ombudsman Assurances ASBL", Square de Meeûs 35, 1000 Brussels, email@example.com, www.ombudsman.as.
Filing a complaint does not prejudice your ability to start legal proceedings.
As AIG Europe SA is an insurance undertaking established in Luxembourg, you also have (as well as the aforementioned complaints procedures) access to the Luxembourg mediation authorities for any complaint you may have regarding your insurance policy. The contact details of the Luxembourg mediation authorities are available on the website of AIG Europe SA: http://www.aig.lu/.
E. Conflicts of Interest Policy
In order to protect your interests, AIG has implemented a policy to avoid potential conflicts of interest that may arise between AIG and its customers or amongst its customers, and that could potentially have a negative impact on you.
The most important aspects of our conflicts of interest policy are summarised below.
1. What is a conflict of interest?
A conflict of interest, in relation to the offering of insurance distribution 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 customer(s) differ or are opposed to one another; or
· A situation in which the interest(s) of a (group of) customer(s) differs from the interest(s) of another (group of) customer(s).
2. How are conflicts of interest managed?
(i) Identification of conflicts of interest
Managing conflicts of interest efficiently is only possible where potential conflicts of interest that may arise are known. AIG therefore identifies situations that could, in the context of the provision of insurance distribution activities, lead to a conflict of interest. This is managed by the compliance department (with the cooperation of other departments).
Examples of potential conflicts of interest include:
· Making profit or suffering loss to the detriment of customers;
· An interest at the result of an insurance distribution service or transaction that differs from the interest of the client;
· A financial or other motive giving preference to the interests of other customers instead of the interests of the customer concerned;
· The abuse of a customer’s confidential information;
· The receiving or the offering of inducements (money, goods and/or services) and/or gifts that could jeopardize neutrality;
· The offering of insurance policies that do not meet the requirements and needs of the customer;
(ii) Measures to manage potential conflicts of interest
We expect all our employees to adopt an independent position when dealing with customers and as such, our employees do not receive any compensation or bonus linked to the sale of an insurance product.
To avoid a potential conflict of interest harming your interests or those of other customers, AIG has adopted appropriate organisational measures and compliance policies regarding, amongst others, the exchange and use of information, the training and supervision of its employees and the prevention of improper influencing, offering and/or receiving of inducements and/or gifts.
(iii) Notification of conflicts of interest
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 customer, AIG will promptly notify the customer about the existence and details of the conflict of interest to allow the customer to take an informed decision as to whether they wish to continue to use the relevant distribution service.
(iv) Registration of conflicts of interest
Conflicts of interest are registered with our compliance department.
(v) Training and communication
AIG provides its employees with training regarding the management of conflicts of interest and the rules and procedures are communicated 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 in relation to other specific obligations (e.g. policies on gifts and entertainment etc.). These codes of conduct positively contribute to and compliment the management of conflicts of interests.
AIG also monitors the remuneration and/or inducement that it may offer to or receive from its customers and/or third parties in relation to its insurance activities. It is important to AIG that such remuneration and/or inducement is not granted or received in a way that conflicts with the duty to act in accordance with the best interests of the customers.
F. How we use Personal Information
G. Would you like more information?
For more information, especially regarding our conflicts of interest policy, you can contact us in writing by:
• E-mail: firstname.lastname@example.org
• Post: AIG Europe SA, Belgian branch, Compliance department, Pleinlaan 11, 1050 Brussels.