Olsen-Sottile Insurance Brokers Inc. | Niagara

Niagara's choice for Auto, Home, Life & Commercial Insurance

Fair Treatment of Customers


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.

5. Advice

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.