Associate Handbook 2018

 if Associates take up a personal investment in a business or Company that trades with Lockton

 where Associates feel obliged as a result of any personal relationship to carry on their activities as an Associate on behalf of Lockton in a manner, which may not be consistent with acting in the best interests of its clients If Associates believe that such a potential or actual conflict of interest may exist they must report it to Partner responsible for their Division and Head of International Risk & Compliance. The Partner along with the Head of International Risk & Compliance and the Company General Counsel will decide whether a conflict situation exists. Failure to disclose a personal conflict of interest is a serious disciplinary offence that may amount to gross misconduct. Following the Bribery Act 2010 coming into force July 2011, due consideration needs to be given in terms of giving and receiving gifts and hospitality. There can be significant risks around gifts, entertainment and expense in relation to bribery. Gifts and entertainment are often part of the country or business culture and it can be difficult for Associates to know what is appropriate in terms of providing and receiving gifts and entertainment. Gifts and entertainment can be used or be perceived to unduly influence third parties and to obtain an unfair advantage. Under no circumstances should a gift or entertainment be either provided or received if there is the possibility that it might unduly influence or be perceived to unduly influence the recipient’s performance or a business decision. As an Associate you are not normally permitted to accept any material gifts or cash from a client, supplier or any other party in respect of any work performed or as an inducement to undertake any duty. Lockton recognises that in the normal course of your duties, however, you may be offered token gifts such as branded or corporate items whilst attending golf days or other relationship building events or have been asked to present at a market or industry seminar or conference, which may be accepted providing the value of the gift does not exceed £100 per person. You should inform your Divisional Manager if you are offered a gift with a value in excess of this amount and ensure it is recorded on the Gifts and Entertainment Register. Gifts that are likely to be in excess of £100 per person should be returned to the sender advising them of our policy relating to gifts and request that this is respected. In addition, Lockton recognises that entertainment, hospitality or branded goods may be provided or received in building relationships with its clients, insurers or suppliers and that it is arranged in good faith and not with the intention of influencing the impartiality of the individual or firm. All Associates should familiarise themselves with the Conflicts of Interest and Transparency Policy (including Gifts and Entertainment) which can be found on LockDocs and clearly states the monetary levels and escalation and reporting procedures. Gifts and Entertainment