Company Code of Conduct

LANDMARK INSURANCE BROKERS PRIVATE LIMITED

(CIN:U66030PN2002PTC017009; IRDAI License No:216; Code DB 089/03)

CODE OF CONDUCT

1. CLIENT PROTECTION
   1. Clients / Prospects
      The Employee shall make all efforts to protect the interest of our clients / prospects and shall render all possible assistance to our clients / prospects.
   2. High Standards of Service
      In the conduct of business, all Employees of the Company shall observe high standards of integrity, dignity, fairness, ethics and professionalism in all dealings with clients, market intermediaries, regulatory bodies, principal companies and other government authorities and all professional dealings shall be discharged in a prompt, effective and efficient manner.

      The Employee shall be responsible for his / her acts of omissions or commission.

   3. Exercise of Due Diligence and no Collusion
      All Employees shall at all times render high standards of service, exercise due skill and diligence, ensure proper care and exercise independent professional judgment and shall not at any time act in collusion with other intermediaries in a manner that is detrimental to the interest of our client(s)/prospects and our company.
   4. Confidentiality
      The Employee shall at all times use his / her best endeavors to keep the information about our clients/prospects confidential and shall not disclose the same to any third party/person, unless required by law or as required to fulfill legal obligations/discharge his/her day to day duties.
2. PROFESSIONAL SELLING PRACTICES
   1. Employee shall not use any unethical means to solicit, market or induce any client / prospect to buy financial / investment products, policy(ies).
   2. Employee shall not make any exaggerated statement regarding performance of any unit linked plans, policy etc. Further, the employee agrees and undertakes not to pass any adverse, derogatory comment / statement about any of the Principal Company / Insurance Company, other intermediary(ies), regulatory authority(ies), government bodies etc. Employee shall not assure or guarantee any return/s on investment, unless otherwise provided in the principal / insurance company(ies) offer document/s/brochures, marketing material’s etc., and in such case/s, the employee shall ensure that adequate documents / information is made available to the client / prospect and also maintained at his / her end for future reference.
   3. Employee shall ensure that at all times
      Clients / prospects are provided with true and adequate information, without any misleading or exaggerated claims about their capability to render certain services or their achievements in regard to services rendered to other clients; Clients / prospects are made aware of attendant risks in the investment/taking out a policy, before any investment decision is made by the client / prospect; copies of the insurance plan, memoranda and related literature is / are made available to clients / prospects, as and when requested; complaints from clients / policy holders are fairly and expeditiously dealt with not to accept CASH from the clients / prospects for investment or for any other purpose; and not to accept money in the employees own name or in the name of our company and / or our associate companies / affiliates / group companies, if any.
   4. Employees in all their communications to clients/prospects shall
      not create unrealistic expectations; not indusce clients / prospects by offering benefits which are extraneous to the plan / policy; not misrepresent either by stating information in a manner calculated to mislead or by omitting to state information which is material to making an informed decision.
3. DISBURSAL OF INFORMATION
   1. All employees shall ensure that adequate disclosures are made to the clients/prospects in a comprehensible and timely manner so as to enable them to make a balanced and informed decision.
4. CONFLICT OF INTEREST
   1. Employees shall avoid conflict of interest and make adequate disclosure of their interest and where any conflict of interest arises, shall take reasonable steps to resolve the same in an equitable manner. All employees shall make appropriate disclosure to the client / prospects and where ever applicable of its possible source or potential areas of conflict of duties and interest, while rendering services which would impair their ability to render fair, objective and unbiased services.
   2. Employees shall not, either in their own name or in the name of their family members, relatives indulge in any activity, business and/or take insurance agency, surveyor license etc., to the detriment of the business interest of company. The term “Relative” shall have the meaning as assigned to it under the Companies Act, 2013 and the Rules framed thereunder (as amended from time to time).
   3. Employees shall not accept any gift (in his / her own name or in the name of his / her family members) by whatever name called exceeding a value of Rs.500/- from any of the client / prospect, principal company, other intermediary. Any gift (by whatever name called) exceeding a value of Rs.500/- shall be immediately disclosed to the HR Department/Head.
5. GOVERNANCE AND COMPLIANCE
   1. Employees shall not engage in any fraudulent and manipulative activities, which is detrimental to the interest of the Company and / or the insurance industry.
   2. All employees shall take adequate and necessary steps to ensure that continuity in data and record keeping is maintained and that the data or records are not lost or destroyed. Employees shall also ensure that correct details of the client/prospect is recorded in the data base of the company and shall also ensure that the up-to-date back up is always available and provided to the Company at reasonable intervals or at any time as may be requested by the Company.
   3. Employees shall at all times take all necessary steps to keep the applicable regulatory certification/s including the IRDAI certification up-to-date and pro-actively take steps to update himself / herself with the latest information etc.
   4. Employees shall at all times act only in accordance with the instructions given (from time to time) by the Senior Management and shall co-operate with the Board / Seniors, or any authority designated by the Board/Seniors, as and when required and shall not make any untrue statement or suppress any material fact in any documents, reports, papers or information furnished, from time to time.
   5. Employees shall not neglect or fail or refuse to submit to the Board / Seniors / Company such books, documents, correspondence and papers or any part thereof as may be demanded/requested, from time to time.
   6. Employees shall maintain an appropriate level of knowledge and competency and abide by the provisions of any act, regulations, circulars and guidelines of the Central Government, Insurance Regulatory and Development Authority of India, IBAI or any other appropriate statutory or self regulatory or other body, as the case may be, and as may be applicable to the Company in respect of the business carried on by the Company.
   7. Employees shall ensure that the Senior Management team including the Finance & Accounts team, the Compliance & Legal team is / are promptly informed about any action, legal proceedings or any material breach or non-compliance by it, of any law, rules, regulations, and directions of IRDAI or of any other regulatory body. Further, Team Member shall ensure that the Senior Management team including the Finance & Accounts team, the Compliance & Legal team is / are promptly and in no event later than 24 hours is / are informed about any legal notice, communication etc., received from client, regulatory authorities, bodies etc., and other person or entity and forward the copy of any such notice etc.
   8. Unless you are authorized on behalf of the Company, you shall not (directly or indirectly) (i) represent the Company, in any publicly accessible media (real time or non-real time); (ii) you shall not contribute by way of article or otherwise in any publication, social media platforms etc. Before representing and / or contributing anything on any insurance plan / products, you shall seek the prior written approval of the Principal Officer of the Company.
   9. Employees must maintain knowledge of and comply with this Code of Conduct both in letter and in spirit.
6. REDRESSAL OF CLIENT GRIEVANCE
   1. Employee shall ensure that the clients are made aware of the designated e-mail id for lodging their concerns / complaints / grievances directly with client care team / client service team for speedy redressal.
   2. Any compliant received by the employee from the client / regulatory authorities / principal companies, shall be immediately sent at/to the designated e-mail id / HO for maintenance of complete records of all such concerns/grievances/complaints.
   3. Team Member shall make endeavors to redress such concerns / complaints / grievances promptly and in a time bound manner.
7. ANTI CORRUPTION / BRIBERY
   You shall not use the company funds or property for any illegal purposes, which is prohibited. Any breach of this clause, the Company shall at its sole discretion, terminate your employment including taking any legal action as per applicable laws.
8. HANDLING OF UNAUTHENTICATED MARKET RELATED NEWS OR RUMORS
   Employees and the Directors of the Company shall maintain the highest ethical standards and govern the conduct of the employees, with regard to circulation of unauthenticated market related news or rumors as it may be detrimental to the functioning and behavior of the insurance market/industry and the Company.
9. REGULATORY CERTIFICATION
   Every employee engaged in providing solicitation of insurance products / schemes shall obtain applicable certification (including taking steps to renew the same) as may be mandated by the regulatory authority(ies) from time to time. Employee shall ensure to inform the HR Department, immediately upon obtaining the said certification (including renewal thereof), without fail.
   Employees shall extend all necessary co-operation to the HR Department for any and / all requirement.
10. ENFORCEMENT
    The HR Department shall:
    disseminate this Code of Conduct to all employees of the Company;
    make observance of this Code a condition of employment;
    make violation of the provisions of the Code, a ground for disciplinary action;
    designate person(s) with primary responsibility for exercising compliance with authority to investigate possible violations and report to the Senior Management / Principal Officer of the Company.
    
    The Company may without prior notice amend / alter / modify this Code, as may be required due to regulatory reasons or otherwise, which shall then come immediate effect.
    
    I have read and understood the Code of Conduct and agree to abide by the Code and agree to keep myself updated and abide by any such revised / modified / amended Code.