1. Governance and Business Culture
Broker should design, implement, communicate and monitor compliance with codes of
conduct, and/or policies and procedures that reinforce a culture of treating customers fairly.
Broker must meet the required statutory proficiency qualifications, and act with the due
skill, care and diligence appropriate for the product involved and the disclosed personal
circumstances and financial needs of the customer.
2. Conflicts of Interest
Broker must develop, implement, monitor and communicate a conflict of interest
management policy to all officers, directors, employees, and applicable third-party
contractors involved in the product life cycle.
3. Disclosure to Customer
Broker should ensure that customers always receive information that is easy to understand,
is clear regarding risks and limitations, makes sure important information is prominently
displayed and is based on the personal circumstances and needs of the consumer.
4. Product Promotion
Broker must ensure that their promotional material is accurate, not misleading and consistent
with what the customer reasonably expects the product to achieve.
Broker must ensure the products offered are in the best interest of the customer, having
regard for the customer’s needs and circumstances.
The recommendation or advice should be documented and reflect the linkage between factfinding,
needs assessment and product. The financial services customer should be able to
understand why the recommendation was made.
6. Disclosure to Policyholder
Broker shall take all reasonable steps to disclose information to the consumer regarding any
contractual changes during the life of the product, and any other information relevant to the
consumer (e.g. corporate or legislative changes that may affect the consumer).
7. Complaints Handling and Dispute Resolution
Broker should analyze complaint data to identify individual or systemic issues that are
adversely affecting customers and take corrective action, as necessary.
Broker should monitor complaints-handling processes and outcomes to ensure their ongoing
8. Protection of personal information
Broker must comply with applicable privacy legislation, including legal requirements to obtain
consent prior to accessing or using a consumer’s personal information (e.g. obtaining a credit
report), and to notify customers of a privacy breach.