Code of Conduct for Authorised Insurance Representatives

CODE OF CONDUCT FOR AUTHORISED
INSURANCE REPRESENTATIVES
November 2021

The Code of Conduct for Authorised Insurance Representatives
The Principles of Conduct of Finance Business ......................................................................................4

1. Introduction....................................................................................................................................6
   1.1. Citation, commencement and application......................................................................................6
   1.2. Background....................................................................................................................................6
   1.3. Framework.....................................................................................................................................7
2. Interpretation..................................................................................................................................7
3. Integrity..........................................................................................................................................9
4. Skill, Care and Diligence.............................................................................................................10
5. Training and Competency............................................................................................................11
6. Conflicts of Interest .....................................................................................................................11
7. Gathering information from Customers.......................................................................................11
8. Giving Information to Customers................................................................................................12
   8.1. General Standards........................................................................................................................12
   8.2. Pre-inception Standards...............................................................................................................14
   8.3. Post-inception Standards..............................................................................................................15
   8.4. Renewals......................................................................................................................................15
9. Long Term Pure Protection Products..........................................................................................16
   9.1. Additional Requirements.............................................................................................................16
   9.2. Code of Conduct for Financial Advisers .....................................................................................16
10. Transitional Period Explanatory Note .........................................................................................17
11. Revocation ...................................................................................................................................17

The Principles of Conduct of Finance Business

1. Integrity
   A licensee should observe high standards of integrity and fair dealing in the conduct of its business.

2. Skill, Care and Diligence
   A licensee should act with due skill, care and diligence towards its customers and counterparties.

3. Conflicts of Interest
   A licensee should either avoid any conflict of interest arising or, where a conflict arises, should ensure fair treatment to all its customers by disclosure, internal rules of confidentiality, declining to act, or otherwise. A licensee should not unfairly place its interests above those of its customers and, where a properly informed customer would reasonably expect that the licensee would place his interests above its own, the licensee should live up to that expectation.

4. Information about Customers
   A licensee should seek from customers it advises or for whom it exercises discretion any information about their circumstances and investment objectives which might reasonably be expected to be relevant in enabling it to fulfil its responsibilities to them.

5. Information for Customers
   A licensee should take reasonable steps to give a customer it advises, in a comprehensible and timely way, any information needed to enable him to make a balanced and informed decision. A licensee should similarly be ready to provide a customer with a full and fair account of the fulfilment of its responsibilities to him.

6. Customer Assets
   Where a licensee has control of or is otherwise responsible for assets belonging to a customer which it is required to safeguard, it should arrange proper protection for them, by way of segregation and identification of those assets or otherwise, in accordance with the responsibility it has accepted.

7. Market Practice
   A licensee should observe high standards of market conduct, and should also comply with any code of standard as in force from time to time and issued or approved by the Commission.

8. Financial Resources
   A licensee should ensure that it maintains adequate financial resources to meet its finance business commitments and to withstand the risks to which its business is subject.

9. Internal Organisation
   A licensee should organise and control its internal affairs in a responsible manner, keeping proper records, and where the licensee employs staff or is responsible for the conduct of finance business by others, should have adequate arrangements to ensure that they are suitable, adequately trained and properly supervised and that it has well-defined compliance procedures.

10. Relations with the Guernsey Financial Services Commission
    A licensee should deal with the Commission in an open and co-operative manner and keep the regulator promptly informed of anything concerning the licensee which might reasonably be expected to be disclosed to it.

The Guernsey Financial Services Commission (“the Commission”), in exercise of the powers conferred on it by section 18 of the Insurance Managers and Insurance Intermediaries (Bailiwick of Guernsey) Law, 2002, as amended (“the Law”) hereby makes the following code of conduct:

1. Introduction
   1.1. Citation, commencement and application
   1.1.1. This code of conduct may be cited as the Code of Conduct for Authorised Insurance Representatives (“the
   Code”) and shall come into operation on 1 April 2017.
   1.1.2. The Code applies to all Authorised Insurance Representatives unless specifically agreed otherwise by the
   Commission in accordance with section 1.1.3.
   1.1.3. The Commission may in its absolute discretion by notice in writing to a licensee exclude or modify the
   application of any provision of the Code if the Commission is satisfied that any such derogation will not be prejudicial to the interests of customers.
   1.2. Background
   1.2.1. Section 15 of the Law requires a licensee to authorise one or more authorised insurance representatives
   to act on his behalf. The effect of this authorisation is that the licensee has responsibility for the actions and conduct of the authorised insurance representative.
   1.2.2. Section 3(1) of Schedule 4 Minimum Criteria for Licensing to the Law requires an authorised insurance
   representative to be a fit and proper person to hold that position.
   1.2.3. The Code is an extension of the Principles of Conduct of Finance Business, which were issued by the
   Commission in February 1991. The Principles of Conduct of Finance Business should be observed by authorised insurance representatives at all times.
   1.2.4. In addition, under section 18 of the Law, the Commission has made the Insurance Intermediaries Rules
   2021 (“the Intermediaries’ Rules”).
   Rule 7.2.1(3) of the Intermediaries’ Rules requires a licensee to take reasonable steps, including the establishment and maintenance of procedures, to ensure that its officers and employees act, to the extent applicable, in conformity with, amongst other items, their own and their employer’s relevant responsibilities under the Law and the rules made thereunder. Rule 7.4.1(2) of the Intermediaries’ Rules requires a licensee to have adequate and effective systems of control in place to ensure that its authorised insurance representatives comply with the Code. Rule 7.2.5(2) of the Intermediaries’ Rules requires a licensee to create and implement a training and competency scheme for all authorised insurance representatives appropriate to the nature and scale of the licensee’s business. Rule 7.9.1(1) of the Intermediaries’ Rules requires a licensee to establish, implement and maintain an effective conflicts of interest policy.

1.3. Framework
1.3.1. The purpose of the Code is to set a framework of behaviour for authorised insurance representatives. The
Code is also intended to apply in circumstances where advising or arranging is carried out via electronic means, such as automated websites, application software (apps) or any other software.
1.3.2. No code of conduct can be exhaustive in all circumstances. In areas where the Code is not specific,
authorised insurance representatives should be guided by the Code’s underlying spirit.
1.3.3. Lack of mention in the Code of a particular act or omission should not be taken as an indication that such
an act or omission constitutes reasonable conduct.
1.3.4. In instances where regulatory requirements do not appear to have been met, which would include poor
conduct by an authorised insurance representative, this may be investigated by the Commission. Nevertheless, claims against the licensee and their employees for compensation are matters for determination by the Channel Islands Financial Ombudsman or the Courts.
1.3.5. A person should not use the term “authorised insurance representative” unless authorised to do so by their
licensee.
1.3.6. The Code is designed for compliance by all authorised insurance representatives advising on or arranging
general insurance and long term pure protection products in or from within the Bailiwick of Guernsey and those advising on or arranging Guernsey policies outside the Bailiwick of Guernsey.
2. Interpretation
For the purposes of this code:
“add-on policy” means a policy or benefit which is sold as a complementary cover to a primary policy, and is provided by a separate insurer for a separate premium; “authorised insurance representative” means an individual authorised in accordance with section 16 of the Law and is a fit and proper person in accordance with section 3(1) of Schedule 4 to the Law; “the Code” means the Code of Conduct for Authorised Insurance Representatives; “the Commission” means the Guernsey Financial Services Commission; “conditional selling” means circumstances where the purchase of an insurance policy to protect a product, service or asset is required in order for the customer to secure that product, service or asset, and that policy must be purchased from the same firm and from a specified insurer. For example, a lender requiring protection against the inability of the borrower to maintain payments under a credit agreement in the event of death, illness or injury; “customer” means the client as defined in the Insurance Intermediaries (Conduct of Business) Rules 2014, meaning any person with or for whom a licensee carries on, or intends to carry on, insurance intermediary business;

“durable medium” means paper or any electronic storage which enables the customer to retrieve information addressed to him, in a way that is accessible for an adequate time period for the purposes of the information, or for the licensee to retain information in relation to a customer; “fair presentation of risk” is a term from the Insurance Act 2015 which applies to any commercial policy of insurance written under United Kingdom law, and in the context of the Code means to disclose every material circumstance which the customer knows or ought to know, or to provide the insurer with sufficient information to put that insurer on notice that it needs to make further enquiries for the purpose of revealing those material circumstances; “the Intermediaries’ Rules” means the Insurance Intermediaries Rules 2021; “insurance intermediary business” means performing, by way of business, any of the activities defined in section 2(5) of the Law; “intermediary services” means activities undertaken in the course of carrying on insurance intermediary business; “the Law” means the Insurance Managers and Insurance Intermediaries (Bailiwick of Guernsey) Law, 2002; “licensee” means a licensed insurance manager or a licensed insurance intermediary that has authorised the authorised insurance representative pursuant to section 15 of the Law; “long term insurance product” consistent with the Intermediaries’ Rules, means any policy or product falling under Schedule 1 to the Law excluding permanent health, credit life assurance and any contracts on human life that are renewable annually; “long term pure protection product” consistent with the Intermediaries’ Rules, means long term business (as defined in Schedule 1 to the Law) where the benefits are not determined by reference to:
a) the value of, or the income from, the value of property of any description; or b) fluctuations in, or an index of, the value of property of any description; “material” in relation to a circumstance, representation or fact means it would influence the judgement of a prudent insurer in determining whether to accept the risk and, if so, on what terms; “other relevant legislation or Code of Conduct” means any legislation enacted to enable the Commission to supervise the carrying on of insurance business. Other codes of conduct include Codes of Conduct of professional bodies that authorised insurance representatives may belong to, for example, the Chartered Insurance Institute or the Institute and Faculty of Actuaries; “reasonable search” is a term from the Insurance Act 2015 which applies to any commercial policy of insurance written under United Kingdom law, and in the context of the Code means a search of the information available to the customer in order to discover and disclose material circumstances.

3. Integrity
   An authorised insurance representative should:
   3.1. take reasonable steps to comply with all relevant laws, regulations, rules, codes, guidance, principles and
   instructions when dealing with customers;
   3.2. take reasonable care to not damage the reputation of the Bailiwick of Guernsey, the licensee, the
   Commission or the profession generally;
   3.3. in the conduct of insurance intermediary business, provide advice objectively and not act in any way
   which is contrary to the Code or any other relevant legislation or Code of Conduct or Practice;
   3.4. take reasonable steps to know and understand his responsibilities as an authorised insurance
   representative;
   3.5. take reasonable care to comply with their licensee’s policies and procedures. If a conflict arises which
   could result in the authorised insurance representative breaching any part of this code, the authorised insurance representative should seek guidance from the licensee’s compliance officer;
   3.6. immediately inform the licensee should the authorised insurance representative breach any part of the
   Code;
   3.7. allow themself to be supervised by their licensee;
   3.8. conduct themself with honesty and with integrity;
   3.9. fairly treat any person or organisation with whom they deal in their professional environment and above
   all, treat customers fairly;
   3.10. recognise that some customers might be classed as vulnerable and take reasonable account of their needs;
   3.11. not make inaccurate or unfair criticisms of any financial institution;
   3.12. have proper regard for the wishes of a customer who seeks to terminate an insurance policy or switch to
   another insurance intermediary;
   3.13. not use or disclose any information acquired from his customers except in the normal course of
   negotiating, maintaining or renewing a contract of insurance, or in handling a claim for a customer, unless the written consent of the customer has been obtained beforehand or disclosure of the information is required by law or in fulfilling regulatory requirements;
   3.14. draw to the attention of an appropriate person within the licensee anything relating to the licensee’s
   business that may reasonably be expected to be disclosed to the Commission; and
   3.15. deal with the Commission in an open and co-operative manner.

4. Skill, Care and Diligence
   An authorised insurance representative should:
   4.1. act with a reasonable standard of skill, care and diligence;
   4.2. take reasonable care to avoid errors wherever and whenever it is reasonably possible to do so. An
   authorised insurance representative should do all that is reasonable to assist the customer and their licensee;
   4.3. be competent to verify that any policy being issued to the customer is accurate, or, if not, refer to a suitably
   experienced authorised insurance representative;
   4.4. give advice only on those matters in which he is competent and should seek advice from or recommend a
   suitably experienced authorised insurance representative where necessary;
   4.5. ensure as far as possible that where advice is being given, the policy is suitable for the demands and needs
   of the customer;
   4.6. where advice is being given and where a choice of insurer is available to the authorised insurance
   representative, use his judgement objectively in the best interests of his customer;
   4.7. generally, deal with correspondence promptly;
   4.8. convey instructions and relevant information to or from customers, insurers or other appropriate parties
   clearly, accurately and in a timely manner; and
   4.9. keep proper records.
   Guidance Note
   A proper record should:

1. be kept in a durable medium;
2. include, as a minimum, details of information gathered, advice given, policies arranged,
   conversations, meetings, agreed actions and tasks relevant to meeting the customer’s demands and needs;
3. be readily retrievable and understandable by a peer practitioner who reasonably could continue to
   advise the customer or make arrangements for their insurance in the absence of the authorised insurance representative; and
4. be kept in accordance with the licensee’s record keeping policy.
   In the following specific circumstances an authorised insurance representative should:
   4.10. in the event of becoming aware of a potential or actual claim, know and understand the policies and
   procedures put in place by the licensee and take reasonable steps to carry these out;

4.11. where the licensee has authority from an insurer to bind cover, know and understand the terms of that
authority and take reasonable care not to act outside that agreement and the authority given to him by the licensee; and
4.12. not arrange an add-on policy where the customer has not consented to this. In arranging an add-on policy,
only do so when the customer has positively chosen that policy in addition to the primary policy.
5. Training and Competency
An authorised insurance representative should:
5.1. take reasonable steps to comply with any training and competency scheme implemented by their licensee;
5.2. take reasonable steps to keep up to date with technical matters, changes in the market to products,
legislation and regulation to the extent that these relate to the products and/or services upon which they are authorised to advise or arrange;
5.3. allow themself to be assessed and monitored for competence by their licensee and maintain proper learning
and continuing professional development records; and
5.4. address any areas for improvement as identified by their licensee.
6. Conflicts of Interest
An authorised insurance representative should:
6.1. be able to identify potential conflicts of interest and refer them to their licensee in accordance with the
licensee’s conflicts of interest policy; and
6.2. not act in a manner which is inconsistent with the prioritisation of the interests of the customer ahead of
all others.
7. Gathering information from Customers
An authorised insurance representative should:
7.1. pay due regard to the duties of disclosure, reasonable search and fair presentation of risk as it relates to
the customer and themself and reasonably seek to gather sufficient information so that adequate disclosure, or where appropriate, a fair presentation of risk can be made to insurers and/or underwriters; Guidance Note An authorised insurance representative should take reasonable steps to help the customer make adequate disclosure, or where appropriate, a fair presentation of risk and to make an informed decision. It is up to the authorised insurance representative and the licensee to decide what level of explanation should be supplied to the customer. In particular, the actual customer should know and understand how and why a claim might be reduced or rejected and they should know the effect of not complying with the terms or conditions of the policy.
7.2. gather sufficient information to give suitable advice and/or arrange an insurance policy to meet the
customer’s demands and needs; and

7.3. take reasonable steps to identify the knowledge of the customer when gathering information and deciding
what information to gather, in the absence of which, the customer should be considered a layman for insurance purposes. Guidance Note When considering the knowledge of the customer, it might be helpful to consider a structure along the following lines:
Insurance Layman: Generally all personal and commercial customers will fall into this category. If this is the judgement of the authorised insurance representative, then the Code should be followed in its entirety. Experienced Insurance Layman: A person who deals with insurance matters on a regular basis and has acknowledged in writing that they do not need all explanations at inception repeated at renewal. However, at the inception of a policy, the customer is considered to be an insurance layman. The fact that a customer has dealt with insurance matters regularly for some time is, on its own, not sufficient evidence that the person concerned is other than an insurance layman (e.g. a customer purchasing motor insurance each year). Insurance Sophisticated: This is likely to be a person who, on a full or part time basis, is responsible for negotiating, placing or managing relevant insurance business and where there is evidence that they have worked in that part of the insurance industry. This classification may also include other insurance professionals who are less experienced in a matter than the authorised insurance representative. Peer Practitioner: This is another insurance broker working at the same level and in the class of business being advised on and/or arranged.
8. Giving Information to Customers
8.1. General Standards
Prior to providing intermediary services to a customer, an authorised insurance representative should:
8.1.1. whenever possible, make an appointment before visiting a prospective customer;
8.1.2. where unsolicited calls are unavoidable, yet deemed to be in the customer’s best interests, ensure that they
are made on a day and at a time likely to be convenient to the customer;
8.1.3. when making contact, by any medium of communication with a prospective customer, for the purpose of
marketing, advising on, or arranging insurance intermediary business, identify himself, his licensee and explain the purpose for contact at the outset;
8.1.4. disclose to the customer the range, scope and any limitations in the insurers and/or products upon which
he is able to provide advice and/or arrange;

Guidance Note
Limitations to be disclosed would include where a licensee offers policies from a single or limited number of insurers.
8.1.5. clarify to the customer, when no advice is being sought or given, that the suitability of any policy has
not been assessed by the authorised insurance representative, and the selection of the policy is a decision for the customer to make;
8.1.6. where a customer is seeking, or the authorised insurance representative is providing advice on one or
more specifically requested products only, the limitation of that advice to not extend beyond those products and the responsibilities of the authorised insurance representative should be confirmed to the customer; and
8.1.7. disclose to the customer any involvement in conditional selling and explain its consequences now or in
the future.
In the course of providing intermediary services to a customer, an authorised insurance representative should:
8.1.8. if requested by the customer, disclose to the customer any and all remuneration to be received in
connection with a transaction. If the amounts are not known, then the basis of calculation should be provided;
8.1.9. pay due regard to the information needs of the customer and communicate information in a timely manner
and in a way which is clear, fair and not misleading in terms that the customer can understand and upon which the customer can make an informed decision;
8.1.10. take into account the knowledge of the customer when deciding what to explain. In the absence of any
judgement being made, the customer should be considered a layman for insurance purposes. Relevant guidance is available under section 7.3; and
8.1.11. not make comparisons with another type of policy unless he explains the differing terms, outlining the
advantages and disadvantages of each policy as they might affect that customer and the identified demands and needs of that customer.
8.1.12. An authorised insurance representative must explain the features, benefits and limitations of any add￾on policy which they wish to bring to the customer’s attention.
Guidance Note
Although not falling within the meaning of an add-on policy for the purposes of this code, where an insurance policy forms an integral part of another product which, in itself, is not a policy of insurance and which cannot be untangled from the core product, the authorised insurance representative must explain the features, benefits and limitations of the policy.
8.1.13. Where disclosure under section 8.1 has been made orally, this should be made available to the customer
in a durable medium as soon as reasonably possible.

8.2. Pre-inception Standards
An authorised insurance representative should:
8.2.1. ensure the customer has received a copy of the licensee’s terms of business. Where this has not been
received, the authorised insurance representative should provide the customer with, or a means to access, a copy of the licensee’s terms of business;
8.2.2. provide the customer with prompt written confirmation of details of the insurance which is going to be
put in place on their behalf;
8.2.3. where confirmation of cover cannot be provided pre-inception, provide this as soon as reasonably possible,
and in any event, in sufficient time to exercise any option to cancel or withdraw from the contract;
8.2.4. explain whether there will be an opportunity for the customer to cancel or withdraw from the contract and
during what period he would be able to exercise that option;
8.2.5. where possible, provide a copy of the policy wording to the customer pre-inception, if not possible,
provide this as soon as reasonably possible post-inception, and in any event, in sufficient time to exercise any option to cancel or withdraw from the contract;
8.2.6. take reasonable steps to identify and explain the principal terms of any contract of insurance recommended
by him, and draw the customer’s attention to and explain significant and/or onerous conditions in the proposed contract of insurance and their effect, which may affect the customer’s decision or if not complied with might result in the avoidance of the policy or a repudiation or reduction of a claim; Guidance Note Significant and/or onerous conditions may, for example, include premium payment, claim notification conditions, warranties, conditions precedent, suspensory conditions, subjectivities, excesses, exclusions, clauses, or obligations to notify the insurer of changes to the risk during the policy period.
8.2.7. take reasonable steps to help the customer know and understand the duty to disclose all material facts,
and where appropriate, what is a reasonable search for information, and the duty to make a fair presentation of risk, making it clear to the customer that all answers or statements are the customer’s own responsibility before the customer completes a form or any other document gathering information, or being asked to give information; Guidance Note The authorised insurance representative should consider that a layman for insurance purposes might not understand which facts are material or are arguably material for any particular policy and should take reasonable steps to assist the customer in making an informed disclosure.
8.2.8. draw the customer’s attention to the premium payment terms and the effect of not meeting these;
8.2.9. disclose all additional charges related to the provision of intermediary services, including but not limited
to administration fees, cancellation and duplicate document charges;

8.2.10. where there is a delay between the presentation of risk to the insurer and the inception of the policy,
remind the customer before the policy goes on risk that non-disclosure of material facts or the inclusion of incorrect information may, for example, result in a claim being repudiated or not paid in full;
8.2.11. if completing the presentation of risk (in whatever form and for whatever class of business) on behalf of
the customer, ask the customer to check, amend if necessary and agree the details before the policy goes on risk;
8.2.12. inform the customer of the name of each insurer with whom a policy is placed. This information should
be given whenever possible prior to the inception of the policy. Any subsequent change to the name of the insurer should be advised to the customer as soon as reasonably possible; and
8.2.13. where disclosure under section 8.2 has been made orally, make it available to the customer in a durable
medium as soon as reasonably possible.
8.3. Post-inception Standards
During the term of an insurance contract, the authorised insurance representative should:
8.3.1. in the case of certificated proof of cover (e.g. motor, employer’s liability) send the certificate to the
customer promptly if that document has not been provided pre-inception;
8.3.2. forward full policy documentation to the customer as soon as reasonably possible where this has not been
included with confirmation of cover;
8.3.3. not withhold any documentation relating to the policy of insurance from the customer;
8.3.4. where there is a mid-term adjustment, deal with the matter promptly and take the opportunity to remind
the customer of the duty of disclosure, and where appropriate, fair presentation of risk and reasonable search; and
8.3.5. in the event of a mid-term adjustment, draw the customer’s attention to any additional premium payment
terms and the effect of not meeting these.
8.4. Renewals
At renewal, an authorised insurance representative should:
8.4.1. provide the customer with renewal terms in a reasonable timeframe for the customer to consider whether
they wish to proceed with the renewal offer;
8.4.2. confirm to the customer his existing cover, prior year premium, any significant changes in cover or terms
and draw the customer’s attention to, and explain, significant and/or onerous conditions in the proposed contract of insurance and their effect, which may affect the customer’s decision or, if not complied with, might result in the avoidance of the policy, a repudiation or reduction of a claim. Relevant guidance is available under 8.2.6;
8.4.3. take into account the knowledge of the customer when deciding what to explain. In the absence of any
judgement being made, the customer should be considered a layman for insurance purposes. Where the customer for a commercial policy has been identified as being other than a layman for insurance purposes, prior year premium should be disclosed at renewal, unless non-disclosure of prior year premium has been

agreed with the customer. Relevant guidance on identification of customer knowledge is available under
section 7.3.
8.4.4. take reasonable steps to help the customer know and understand the duty to disclose all material facts,
and where appropriate, what is a reasonable search for information and the duty to make a fair presentation of risk, making it clear to the customer that all answers or statements are the customer’s own responsibility; and Guidance Note This should take place before the customer is asked to complete a form or any other document gathering information, or the customer is asked to give any other information or check documentation for accuracy.
8.4.5. not advise a customer to replace or cancel an insurance contract unless it is in the best or stated interests
of the customer.
9. Long Term Pure Protection Products
9.1. Additional Requirements
An authorised insurance representative advising on or arranging long term pure protection products should:
9.1.1. comply with sections 3 to 8 inclusive;
9.1.2. take reasonable steps to ensure that he has sufficient knowledge and understanding of the legislation
(including taxation legislation) which would affect the customer and the products that the authorised insurance representative is recommending, or that the customer already owns. If he is unable to meet this standard he should inform the customer and, if possible, refer the customer to a person who can give appropriate advice;
9.1.3. not advise a customer to convert, allow to lapse, cancel or surrender any long term pure protection product
unless he can demonstrate the action to be in the best or stated interests of the customer. If such action is advised the advice should be fully documented. If such action is not advised, the reasons for the action should be sought from the customer, even if not received;
9.1.4. take reasonable steps to obtain and record information from the customer concerning the personal and
financial circumstances of that customer necessary to give advice suitable for the demands and needs of the customer and to make a fair presentation to insurers; and
9.1.5. where a customer has requested an authorised insurance representative to arrange a specific policy
without advice, confirm in writing, that the customer did not seek any advice from, and was not given any advice by the authorised insurance representative.
9.2. Code of Conduct for Financial Advisers
9.2.1. Where an authorised insurance representative’s licensee also provides advice on long term insurance
products and its authorised insurance representatives follow the requirements of the Code of Conduct for Financial Advisers, the requirements of the Code are considered to have been met.

10. Transitional Period Explanatory Note
    10.1. With reference to section 4.12, following the introduction of this code, upon first renewal for a customer
    whose renewal includes one or more add-on policies, the customer should positively choose to continue with each add-on policy. Once a customer has positively chosen an add-on policy, that customer’s renewal notice may offer the choice to either opt-in or to opt-out of the add-on policy on future renewal.
    10.2. With reference to sections 8.4.2 and 8.4.3, following the introduction of this code, a customer should be
    provided with confirmation of his prior year premium upon renewal. The Commission accepts that changes may need to made to the licensee’s computer software to allow for such changes to be displayed and would expect such changes to have been made as soon as reasonably possible and in any event by the first anniversary of the introduction of this code.
11. Revocation
    11.1. The Code of Conduct for Authorised Insurance Representatives effective from 1 January 2015 is revoked
    with effect from the date of commencement of the Code.