BUSINESS CONDUCT POLICY

Regulation governing Corbroker - Corretores de Seguros, S.A.'s Business Conduct Policy

Article 1 - Scope

This Regulation lays down the principles that Corbroker – Corretores de Seguros, S.A., hereafter Corbroker, has adopted regarding its relationships with policyholders, insured persons, beneficiaries or injured third parties.
The principles set out in this Regulation reflect Corbroker’s vision, mission and values, and express the behaviour expected of all the company’s employees, including its sub-agents, and of all those who, on Corbroker’s behalf, provide services to policyholders, insured persons, beneficiaries or injured third parties.

Article 2 - Equity, diligence and transparency

Employees shall contribute to ensuring that all policyholders, insured persons, beneficiaries or injured third parties receive fair, diligent and transparent treatment, with respect for their rights.

Article 3 - Information and clarification

When performing their duties, employees shall ensure that policyholders, insured persons, beneficiaries or injured third parties, taking into account their profile and the nature and complexity of the situation, are provided with all information that is required by law and with sufficient clarification to enable them to make an informed decision.

Article 4 - Personal data

Processing of the personal data of policyholders, insured persons, beneficiaries or injured third parties, whether by automated or non-automated means, shall be carried out in strict compliance with the applicable legal rules and the technical and organisational security rules that are appropriate to the risks involved in processing the data.

Article 5 - Prevention and handling of conflicts of interest

Employees shall inform Corbroker of all situations that may give rise to conflicts of interest, and shall refrain from intervening in such situations;
Conflicts of interest are deemed to exist when employees have a direct or indirect interest in the situation or in the process underway, or when their spouses or first-degree relatives by blood or marriage, or companies or other collective bodies in which they directly or indirectly participate, have a similar interest.

Article 6 - Speed and efficiency

Employees shall perform the duties or tasks for which they are responsible, with rigour and quality, aiming to quickly and efficiently manage processes relating to Policyholders, Insured Persons, Beneficiaries or Injured Third Parties, namely in the area of claims and complaints.

Article 7 - Suitable qualifications

Corbroker guarantees that its employees, particularly those who have direct contact with policyholders, insured persons, beneficiaries or injured third parties, are suitably qualified, so as to guarantee quality when attending clients, in person or otherwise.

Article 8 - Complaints management policy

Corbroker has implemented a complaints management policy, pursuant to Article 28 of Law 7/2019, of 16 January, and ensures that it is executed, monitored and checked.

Article 9 - Compliance with the business conduct policy

Corbroker ensures that the rules contained in this Regulation are disseminated and explained, in order to guarantee that they are executed, monitored and checked.