Conflicts and financial crime

A managing general agent underwrites on behalf of others. That is the business, and it is also where our conflicts come from. We would rather name them than imply we do not have any.

The conflicts inherent in what we do include these:

• we underwrite on behalf of more than one reinsurer, and the same risk may be attractive to one and not to another;
• we allocate lines between the reinsurers on our panel, and how we allocate affects each of them;
• we are remunerated by commission on the business we write, which is an interest in writing business;
• we receive competing approaches on the same risk from different brokers, and how we handle them affects which broker earns the placement;
• we handle claims under delegated authority on business we ourselves underwrote.

Our starting point is disclosure. Where a conflict cannot be avoided or managed so that the risk of damage to a counterparty is removed, we tell that counterparty about it and let them decide.

• We maintain a conflicts of interest policy and a register of the conflicts we have identified, which we review.
• Our underwriting decisions are recorded with the reasons for them and the person who made them, so that an allocation or a declinature can be examined afterwards rather than taken on trust.
• Claims decisions are subject to the authority limits agreed with the reinsurers carrying the risk, and are referred beyond those limits rather than settled within them.
• Bluefriars Brokers Limited, as our principal, oversees the regulated business we conduct, and has access to that record.

If you believe a conflict has affected how we dealt with you, tell us through our complaints procedure and we will investigate it.

We screen the parties to the business we write against the applicable sanctions regimes, and we screen at inception and on an ongoing basis rather than once.

We do not write business we cannot screen, and we do not write business that screening tells us we should not.

Where a sanctions issue arises on business already written, we act on it and report it where we are required to. We do not treat a licence, an exemption or a wind-down provision as a matter for our own judgement where the law requires an authority’s.

We carry out customer due diligence on our counterparties, keep the records the Money Laundering Regulations 2017 require, and report suspicion where the law obliges us to. Our people are trained to recognise the signs of money laundering in the business we write and to escalate rather than resolve them alone.

Records collected for these purposes are kept for five years and then deleted, unless we have a specific legal ground to keep them longer. Our privacy notice sets that out.

We do not offer, give, request or accept bribes, facilitation payments or anything else intended improperly to influence a business decision, and we do not permit anyone acting for us to do so. This applies wherever we do business and whatever local practice may be.

Hospitality and business entertainment are permitted where they are proportionate, transparent and recorded. Anything that could reasonably be read as buying a decision is not.

If you have a concern about any of this, including a concern you would rather raise confidentially, write to us at duncan@quorinspecialty.com. You can also raise it with Bluefriars Brokers Limited as our principal, or with the Financial Conduct Authority directly.