1. Information on the policy on conflicts of interest
1.1. General principles.
For the conduct of its business, Euler Hermes Belgium (hereinafter
referred to as "EHB") has adopted the principle of managing in an
honest, equitable and professional manner any conflicts of interest
which may arise between EHB and its clients, a client and the insurance
broker or among its clients. In accordance with the applicable law, EHB
takes all necessary measures to identify and properly manage conflicts
of interest which give rise to a significant risk of damage likely to
harm the interests of its clients whether current, potential and former
clients (hereinafter the "Client").
Conflicts of interest may arise between:
- EHB and a Client;
- a concerned person and EHB and/or a Client of EHB;
- several EHB clients in connection with the provision of services by EHB to these Clients;
- a supplier of EHB and a Client.
For the purposes of its policy on conflicts of interests, the term concerned person refers to:
employee or Manager of EHB or a representative appointed by EHB as well
as any natural person whose services are made available to and are
provided under the control of EHB and who is involved in EHB's regulated
- an insurance broker, partner or equivalent;
natural person involved in the provision of EHB services or his
representative appointed under a sub-contract for the provision of
insurance services and activities.
1.2. Internal measures for the identification and management of conflicts of interests.
In order to identify these conflicts of interest, EHB focuses on
facts and also does its best to determine, in particular, if a concerned
person, or any other person:
- is likely to derive a financial gain or prevent a financial loss at the expense of the Client;
an interest in the outcome of a service provided to the Client or of a
transaction carried out on behalf of that Client, which is distinct from
the Client's interest in that outcome;
- has a financial or other
incentive to favour the interest of EHB and/or a Client or group of
Clients over the interests of EHB and/or another Client or an insurance
- has the same professional activity as the Client; and/or
or shall receive from a person other than the Client an inducement in
relation to the service provided to the Client, in the form of monies,
goods or services, other than the standard commission or fee for that
When a conflict of interest is identified, it must be managed rapidly, equitably and adequately.
Examples of basic measures laid out in the rules adopted by EHB are:
procedures to control the flow of information in situations involving
the risk of a conflict of interest likely to damage the interests of a
- appropriate controls to identify and manage multiple directorships and the concerned persons' interests outside the company;
measures for the protection of information on EHB's services and
activities when a conflict of interest is identified;
- where necessary, rules governing transactions by the personnel in their own name apply to the concerned persons;
- a review of the adequacy of EHB's systems and controls is carried out on a regular basis.
In the course of the management of a conflict of interest, it may
be appropriate to have recourse to additional measures when the basic
measures are not sufficient to adequately manage the potential
conflict. These measures may include in particular the setting up
“Chinese walls" on an ad hoc basis, specific to the transactions or
other additional measures for the separation of information.
EHB employees must ensure that they adopt fully independent
attitudes in their dealings with clients and insurance brokers. This is
why measures aimed at preventing any influence and guaranteeing an
independent attitude have been introduced: separation of departments,
prevention of improper intervention in some activities or services,
policy on gifts and invitations.
It is possible that, in spite of all measures taken for the
management of conflicts of interest, no definitive solution is found.
In these cases, the choice is to forego the service or transaction.
An additional support to the identification and management of
conflicts of interest is provided through procedures and guidelines
which have been set up in connection with other specific obligations.
For example, the Compliance Management System within EHB and the Euler
Hermes Group also includes a Code of Ethics and Conduct, an integrity
policy, a sponsoring and events policy.
2. Information EH Belgium's policy on inducements
Euler Hermes Belgium enters into cooperation agreements with
registered insurance brokers. These agreements govern the rights and
obligations of the parties, including the remuneration payable to
brokers in connection with the supply of insurance brokerage services.
Provided there is a valid mandate and if all conditions applicable
to the services provided are met, a commission representing a given
percentage of the commercial and political risk premium shall be paid.
This commission ranges between 7 and 15% based on the type of product,
the broker's specialisation, knowledge of our products and the quality
of services rendered. It is possible that an additional commission may
be provided for with the aim of improving the quality of service to the
Should you wish to have more information on these policies, the
Client can contact the Compliance at EHB by mail on the following
address: Euler Hermes Europe SA, Avenue des arts 56, 1000 Brussels,