利益冲突政策 

上映时间:2023年5月

Summary

本政策解释了我们如何识别, prevent and manage actual or potential conflicts of interest 哪一个 may arise between our clients and ourselves, or between one client and another in circumstances where we are providing our products and services. We will take all reasonable steps to prevent conflicts of interest from adversely affecting the interests of our clients.

冲突的意识

The identification, prevention and/or management of conflicts of interest is an ongoing process. 美世 believes we have a conflict-aware environment, core to 哪一个 are the following elements:

• 我们的行为准则 – Employees are required to comply with 美世’s Code of Conduct contained in the 马什McLennan Policy, 更大的利益, 作为雇佣条件. 更大的利益 has clear requirements and guidelines for dealing with ethical matters, 包括利益冲突.
• 客户保密义务s – Employees are made aware of their obligations to protect client confidentiality and to comply with insider trading and related laws and regulations.
• 礼品及娱乐政策 – Employees are required to comply with our gifts and entertainment policy, 哪一个 is designed to ensure that they are not unduly influenced by the receipt of gifts, 餐, 或娱乐.
• 个人投资报告 – Employees are also subject to policies governing their personal investing, 哪一个, 在一般情况下, 要求报告某些个人投资.

冲突类型

美世 has an obligation to act in the best interests of our clients and to comply with our statutory and regulatory requirements.

This policy covers the following areas of potential conflict:

• The personal interests of an employee of 美世 conflicts with a duty owed to a client or clients.
• The corporate interests of 美世 conflicts with the best interests of a 美世 client or clients.
• A duty 美世 owes to one client conflicts with a duty to another.

冲突的识别

When considering whether a conflict of interest does, 或者有存在的潜力, the following will be taken into account as appropriate:

• Is 美世 likely to make a financial gain, or avoid a financial loss, at a client’s expense?
• Does 美世 have an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, 哪一个 is separate and distinct from the client’s interest in that outcome?
• Does 美世 have a financial or other incentive to favour the interests of one client (or group of clients) over the interests of another client?
• 向客户端提供服务时, does 美世 receive or will it receive from a person other than the client an inducement in relation to a service provided to the client, 以金钱的形式, 商品或服务, 除了这项服务的标准费用?

利益冲突可能会发生，例如:

• From earning higher revenues or profits from certain types of client arrangements, 包括从提供更复杂的, 为客户提供成本更高的解决方案时更简单, 可能会有成本更低的解决方案.
• From relationships 美世 may have with providers of services or products to our clients, 包括费用安排或佣金.
• From relationships 美世 has with multiple parties related to the one corporate entity each of 哪一个 may have differing needs.
• 从收到的机密信息.
• From performance related remuneration paid to employees.
• From personal relationships our employees may have with our clients or service providers.
• From gifts 或娱乐 provided to clients or prospects, or received by our staff from key service providers.
• 来自非美世职位的员工.

管理潜在冲突

美世有自己的政策, procedures and codes in place to manage such conflicts including the Code of Conduct, “更大的善”, 个人账户交易政策, 礼品及娱乐政策 and Directorships and Outside Positions Policy.

除了各种政策和程序, the following controls are examples of those used for managing conflicts of interest:

• Information barriers to prevent/restrict the flow of information to certain employees in order to protect the interests of our clients. This could involve the physical separation of certain employees, the use of separate teams to act for certain clients and/or restrictions on employees access to client folders.
• 明确办公桌政策
• 同行评审

How we manage a specific conflict will depend on its nature and significance. 例如, we may be unable to undertake work for clients if we identify an actual rather than a potential conflict and there is a risk that our client’s interests may be damaged. Or we may disclose or seek the informed consent of the client(s) affected by a conflict before we provide products or services.

限制

This document is not intended to create third party rights or duties and does not form part of a contract between 美世 and our clients.