1.1. General principles
For the conduct of its business, Qover has adopted the principle of managing in an honest, equitable and professional manner any conflicts of interest which may arise between Qover and its clients, a client and another party who act for Qover or among its clients. In accordance with the applicable law, Qover takes all necessary measures to identify and properly manage conflicts of interest which give rise to a significant risk of damage likely to harm the interests of its clients whether current, potential and former clients (hereinafter the "Client").
Conflicts of interest may arise between:
For the purposes of this policy on conflicts of interests, the term concerned person refers to:
1.2. Internal measures for the identification and management of conflicts of interests
In order to identify these conflicts of interest, Qover focuses on facts and also does its best to determine, in particular, if a concerned person, or any other person:
When a conflict of interest is identified, it must be managed rapidly, equitably and adequately.
Examples of basic measures laid out in the rules adopted by Qover are:
In the course of the management of a conflict of interest, it may be appropriate to have recourse to additional measures when the basic measures are not sufficient to adequately manage the potential conflict. These measures may include in particular the setting up “Chinese walls" on an ad hoc basis, specific to the transactions or other additional measures for the separation of information.
Qover employees must ensure that they adopt fully independent attitudes in their dealings with clients and insurance intermediaries. This is why measures aimed at preventing any influence and guaranteeing an independent attitude have been introduced: separation of departments, prevention of improper intervention in some activities or services, policy on gifts and invitations.
When it can reasonably be expected that any measures taken to manage a conflict of interest will not be sufficient to protect the clients’ interests, the clients concerned shall be informed of the general nature and/or of the sources of the conflict of interest. Information must be communicated prior to the provision of the product or to the implementation of the service with which the risk of conflict of interest is associated.
The procedure for notification of unmanageable conflicts of interest must remain the exception and is subject to approval by the Compliance Officer. The aforementioned step is not to substitute for the development of conflict of interest management measures as laid out and required above.
An additional support to the identification and management of conflicts of interest is provided through procedures and guidelines which have been set up in connection with other specific obligations.
Qover enters into cooperation agreements with business introducers. Such agreement governs the rights and obligations of the parties, including the remuneration payable by Qover to the introducer.
It is important to note that Qover’s relationships with insurers work differently from traditional players. A traditional insurer builds and manages its products (and the premium integrates such internal costs on top of the risk carrying) and then remunerates brokers who merely distribute its products.
As an InsurTech, it is important to highlight that Qover is not an additional intermediary in the traditional insurance value chain. Qover builds and manages insurance products as described below (and the role of the insurer is limited to risk carrying) and make it more cost-efficient. So in QOVER approach, the insurance premium is usually spread as follow:
Qover does not increase the cost of the insurance value chain but manages instead what the insurer traditionally do in a more efficient way ultimately aiming at a better user experience.
Should you wish to have more information on these policies, the Client can contact the Compliance Officer by e- mail on the following address: firstname.lastname@example.org or by mail: Qover - Compliance Department – rue des Palais 44 – 1030 Brussels - Belgium.