Associate Handbook 2018

Confidential Client Information *

While Associates are encouraged to talk to family and friends about the Company it is important that they observe the confidentiality of both the Company and its clients. Associates must not either directly, or indirectly, during their employment or after its termination without limit in time for their own purposes or for any purposes other than those of the Company (for reason and in any manner) use or divulge or communicate to any person, firm, Company or organisation except to those officials of the Company any secret or confidential information or information constituting a trade secret acquired or discovered by them in the course of their employment with the Company. Confidential information is any information, which is not freely available to the public and related to the private affairs or business of the Company or their suppliers, customers, management or shareholders:

 Confidential Client Information should only be utilised for broking, processing, renewal or internal statistical analysis purposes

 Confidential Company Information should not be given to others, or used for Associate’s own benefit

Upon the termination of employment with the Company, Associates must immediately return all documentation and information, be that documents or information recorded on paper (including any copies) or in computerised form, relating to any past, current, or prospective client or business of the Company to their Manager before their last day.

In addition, books, stationery and other property in Associates possession or control, which concerns or is owned by the Company, must also be returned.

All Associates have a post-employment contractual obligation, which requires them to continue to observe confidentiality.

Any breach of the above may result in disciplinary action and may amount to gross misconduct.

10.22 Compliance Policy

Lockton Companies LLP is authorised and regulated by the Financial Conduct Authority (FCA) in the UK, is a fully accredited Lloyd’s broker; and has passport rights to conduct business from a branch office in the Republic of Ireland and on a cross border basis with all other regulatory authorities in the European Economic Area (EEA). Lockton is obliged to comply with relevant statutory or regulatory obligations and requirements of various authorities that impact upon its UK, EEA and international business activities. In order to meet these requirements, Lockton maintains a variety of controls managed by the CR&C as part of its overall governance framework.  It is the policy of Lockton to conduct its business in such a way as to ensure that it complies with applicable insurance statutes, laws, regulations and corporate governance principles.  Lockton is committed to serving the interests of its customers by ensuring that its business is conducted with integrity and with due skill, care and diligence in order to ensure customer satisfaction and to treat customers fairly.