A CoI occurs when personal interests – family, friendships, financial, or social factors – could potentially compromise his or her judgment, decisions, or actions. With other words: if a certain action or recommendation is not provided objectively without any bias, but is (or at least may potentially be) driven by other interests such as acquiring an advantage or gain that would not be gained otherwise.

Baloise believes in treating our customers and business partner in a fair and transparent manner which includes to develop, implement and maintain effective organisational and administrative measures to identify, prevent and appropriately manage potential CoI that may arise namely in the distribution of insurance products and to prevent such conflicts from adversely affecting the legitimate interests of policyholders and business partners.

In the production and execution of contracts, Baloise conducts itself according to a set of rules to ensure fairness, honesty, professionalism, correctness and the best interest our customers, namely the policyholders.

CoI may arise between the insurance companies of the Baloise Group, other companies belonging to our group, our management, our employees, intermediaries and partners, or other persons related to us, as well as towards or between our customers.

In accordance with the provisions of the regulations on CoI, we:

• transparently reveal the costs to be borne by the policyholder and strive to achieve the best result for the policyholder in relation to his insurance requirements and needs;
• design our insurance solutions and its terms by also taking the needs and best interest of our Policyholders into consideration namely with regards to the time, size and nature of the policy any and transactions;    
• do not engage in activities or conduct that may benefit some customers to the detriment of others;
• do not adopt practices and provisions on compensation to the distribution network that may encourage conduct contrary to the duty to be impartial and act unbiased towards the contracting party;
• identify cases where contractual terms and conditions agreed with third parties conflict with the interests of the policyholder and ensures that the assets of segregated funds, in-terest-bearing funds and the representative assets of value-linked contracts or individual contracts are not burdened by charges that could otherwise be avoided or excluded from the receipt of benefits due to them.
• we do not offer or ask for retrocessions. If retrocessions are offered, Baloise will not keep these but will credit these to the respective insurance portfolio without any deduction.

There are multifold instances where a CoI-situation may occur.
In particular, CoI may arise in the following circumstances or activities:

• in advising on insurance investment products, resulting from our interest in selling our products;
• in relation to remuneration paid or received, e.g. (recurring) sales commissions, (non-) monetary benefits in connection with sales services of insurance products, in-investment services or ancillary services for our customers and any other economic benefits of any kind offered or received;
• where a remuneration above market standards in money or (non-) monetary compensation (other goods or advantages such as free trainings) is promised to incentivize the distribution of our insurance policies, or buying or keeping certain assets in the insurance portfolio;
• in relation to the different cost structures of the funds on which the company's insurance investment products are based;
• in relation to remuneration paid to the Company's collaborators, intermediaries and partners;
• us promising an additional remuneration based on the achievement of certain objectives/targets to our employees, intermediaries or business partners;
• involvement of other business entities which are part of the Baloise Group;
• following the acquisition of information that, in certain circumstances, may not be in the public domain;
• following the receipt of non-monetary compensation (e.g. training);
• as a result of personal relationships maintained by the Company's employees or managers, or by persons related to them, or of the participation of these persons in supervisory commissions or advisory boards.

First and foremost, the responsibility for the identification, prevention and regulation of CoI lies with the business units. Within Baloise, its Compliance Officer is responsible for monitoring the identification, prevention and management of CoI. In case of a CoI, the Compliance Officer must be involved and will decide within his discretion how to handle this CoI.

Possible measures to handle a CoI are for instance:

• make transparent/inform the customer/counterpart about the CoI;
• mitigate the CoI (i.e. choose another intermediary, change the person acting for or on behalf of us to someone without a CoI);
• stop the deal.

In addition, we have established organizational regulations and systems, controls, guidelines, procedures and policies to prevent CoI.

Should you believe that someone in the course of the subscription or administration of your policy has or has had a CoI, or if you have further questions with regards to this topic please contact our Compliance Officer: compliance@baloise-life.com