- Broker and intermediary charter
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Across the Irish Life & Permanent Group, the independent broker or intermediary is valued as a source of quality business. Central to our relationship with brokers and intermediaries, is an understanding of the relationship between them and their clients, a recognition of the need to protect the integrity of that relationship and a commitment to respect the confidentiality on which it is based.
Accordingly we make the following undertakings, by way of statements of practice, which govern the management of our relationship.
1. Integrity of client information
Irish Life & Permanent will not use any client information arising from an introduction of a client by a broker or intermediary to the group to cross sell other financial products or services that would normally be available to the independent broker or intermediary. Such products include life assurance, pensions, savings, investment, general insurance, mortgages, leasing or personal lending.
Information obtained through the sale or introduction of a group product to, or by, a broker or intermediary will not be passed to or used by any other part of the group. Such client introductions to the group will be, to the best of our ability, recorded as such in any subsequent client records across the group.
Money transmission products or services such as credit cards, and bank short-term accounts, may be offered to such clients from time to time.
2. Use of the Money transmission system
Irish Life & Permanent undertakes not to use any information arising from the operation of the money transmission system for the purposes of targeting clients introduced by brokers or intermediaries for the sale of products included above.
3. Remuneration
Irish Life & Permanent undertakes to fairly remunerate brokers and intermediaries by way of fees or commissions for the sale of group products arranged by them.
4. Advertising
Irish Life & Permanent undertakes to include an equal reference to dealing through a broker or intermediary in all relevant advertising and promotional materials.
5. Arbitration
In the event of a complaint arising that a group product has been sold to a client of a broker or intermediary in contravention of the principles set out in this charter, the complaint will be referred to the Irish Life & Permanent Compliance Officer for mediation. The purpose of such arbitration will be to establish if the relevant business has been transacted as a result of the original broker introduction. In such cases, the payment of commission and the client ownership will be determined.
- Group purchasing policy
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1. General policy
Products and services must be capable of meeting all specifications relating to:
- quality
- delivery
- technical support
- price
- training
- financial reliability
- service
Every purchase will be made in a manner which is expected to obtain the most beneficial outcome both strategically and commercially.
Irish suppliers and manufacturers will be given equal opportunity as group providers where the product meets required standard and the pricing is commercially acceptable to the group.
Cognisance will be taken at all times of environmental issues in the selection of goods or services for use within the group.
2. Selecting suppliers
The selection of suppliers is based on sound business principles which recognise, amongst other factors, their relevant experience and reputation, their financial stability and, most importantly, their ability to perform the contract in a manner which is both timely and acceptable to the group.
The selection of suppliers is also based on the quality of the products and services offered by them.
The group does not seek to unduly restrict its sources of supply, however, where economic, strategic or technology benefits may accrue, group procurement may utilise single sourcing to maximise the benefits to the group.
Every effort is made to ensure that suppliers are treated fairly and equally:
- In bid situations, the same information is supplied to all potential candidates.
- All negotiations are conducted as promptly as possible.
- Only those with the financial and infrastructural capacity to supply the group are asked to respond.
- The result of the selection will be notified to all candidates at the same time and those unsuccessful are offered a debriefing opportunity if desired.
Responses to requests for proposal and requests for quote remain confidential both before and after the business is placed. Equally, suppliers are obliged to ensure that any privileged information regarding the group's operations is kept strictly confidential and divulged only on a need-to-know basis. Suppliers and their employees, agents and sub-contractors, are, in all cases, required to sign contracts which include a specific confidentiality clause.
Suppliers will, at all times, be paid in accordance with the terms agreed. An exception to this rule would be where the supplier fails to deliver in accordance with the agreed terms.
3. Procurement methods
Group procurement is primarily responsible for deciding and agreeing the method of purchase. If a Term Purchase Agreement (TPA) or a Volume Purchase Agreement (VPA) is in place, then this would normally be the first choice.
Alternatively, a competitive selection process may be adopted by means of either (i) a Request for Information (RFI) or a Request for Proposal (RFP) or both, or (ii) a Request for Quotation (RFQ).
Group procurement will issue RFI’s, RFP’s and RFQ’s based on the detailed specification received from the business area involved. In doing so, cognisance will be taken of the potential group needs in respect of the particular goods or services sought.
4. Contracts
Terms and conditions of contracts for all purchases of goods and services must meet our standards and requirements. Draft contract formats containing Group Terms and Conditions will form the basis of contractual discussions.
- Gift policy
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The receipt of invitations or the offer of any gifts, payments, services, hospitality or benefit-in-kind could affect, or could be considered to affect, the ability to exercise independent judgement or give rise to a conflict with the duty owed to customers.
No sponsorship or gifts may be solicited or accepted by staff for any event or occasion involving staff where such could be deemed to influence or compromise any business decision in relation to the sponsor or donor. Invitations, including overnight accommodation or long distance travel must always be refused unless the proposed trip is predominantly of a business nature.
Where there is any doubt as to the propriety of accepting an invitation or offer a staff member must refer the matter to their relevant manager. In general referral will not be necessary where the value of the gifts or benefits is not significant, i.e. below the value limits set for the group from time to time.
The Manager may approve or refuse the acceptance by the member of staff of the offer or invitation. Where clarification is required on any legal or regulatory aspects the Manager will consult with the Compliance Officer who will only give approval if satisfied that the letter and spirit of the law or regulation is not breached and independence is not compromised.
All approvals must be recorded and are subject to review by the Compliance Officer.