Transparency Rules (Code of Ethics)
InteRBroS is committed to maintaining very high and strict standards of corporate management
and fully recognizes the benefits of the application of the principles set out specifically to conduct
our Business in a professional, efficient manner and with high moral and ethical values.
InteRBroS has applied these principles, duly taking into account the current size and the nature of
the company. The management framework will be continuously evolving, always keeping ahead the
development of the company and providing the necessary assurances to those who have an interest
in its success.
InteRBroS has a program of specific objectives to:
~ Management and Risks
~ Sales/Products, Claims and Customer service
~ Security: Reinsurers Ratings and Operations ~ Compliance and Audit
Management and Risk
A periodic review is carried out in a comprehensive manner on the main aspects of business
management; call it management and finance, human resources, sales, products, claims and customer
services.
Sales/Products, Claims and Customer Service
The sales budget, the updated monthly results obtained as well as the accumulated of the year are
analyzed every month. The sales strategy, development and implementation of new products is
checked and adjusted and in a detailed manner, the management and status of relevant paid and
outstanding claims is analyzed to determine if the service is suitable and/or to take the corrective
measures of the case. In addition, other services to the clients are analyzed such as risks inspections,
presentations, workshops to clients, etc.
Security: Reinsurers Ratings and Operations
At the moment of the quotation/ placement of the reinsurance of a risk, the financial conditions
analysis of the reports provided by AMBEST or Standard and Poor's of each of the participating
reinsurers are reviewed. Also their current polices and operations to make sure that are in accordance
with our corporate compliances.
InteRBroS security policy limits the usage of reinsurers whose classification falls below A-.
Based on the above mentioned classification, in case that THE CLIENTS OF InteRBroS decide
to use a reinsurer with a classification lower than the stated one, an specific written approval/ request
will be asked from the clients, on the mentioned reinsurer.
InteRBroS does not evaluate or guarantees the solvency of any reinsurer.
InteRBroS does not accept/ assume any responsibility for any amount not paid in reference to
claims or return of premiums owed to its CLIENTS by a participating reinsurer who declares himself
insolvent or who is behind or who refuses or not the payment of a valid claim settlement and/or in
the return of premiums.
Transparency and Confidentiality of the Information
On every business that InteRBroS quotes and places on behalf of its clients, InteRBroS will
send finished copy of the reinsurance slips signed and stamped/ sealed by the reinsurers.
Inasmuch as the relation between the clients and InteRBroS is of commercial character and it is
based on the good faith, professional ethics, confidentiality and principles that go in hand with the
international standards of proper handling of the insurance activity, the clients of InteRBroS have
all the right to request InteRBroS at any moment, copy of the placement, of the files of
accounting and claims records of any risk that we have placed in their name.
All the information provided by each of the CLIENTS of InteRBroS, is handled by
InteRBroS, under the most absolute confidentiality, discretion and greater respect towards the
intellectual property and institution of their CUSTOMERS.
InteRBroS Remuneration
InteRBroS is normally remunerated by commission or by reinsurance brokerage earned by the
placement of reinsurances, or by a negotiated and agreed rate with its clients and/ or with the
reinsurers. Since this remuneration is 100% earned at the moment in which the client confirms that
the terms and the reinsurance order placed by InteRBroS is accepted, InteRBroS would have
the right to retain this one (or to receive this one if it would not be paid), even if the reinsurance risks
placed by were annulled later. InteRBroS will not impose the payment of fees or
additional expenses on our clients without previous notice or discussion.
InteRBroS will be able to receive administrative and/or consultation fees or commissions from
the reinsurers, with whom it has placed the reinsurance risks of its clients.
InteRBroS does not receive any remuneration from the reinsurers in relation to the volume of
business/risks that we have placed (sometimes so-called ‘Market service Agreement’ and ‘Placing
Services Agreements’)
Annual Reports of External Audit/Compliance and Internal Audit
Matters relating to the operation of the business, on the proper handling of funds, ensuring
compliance and implementation of procedures, controls and established good practices necessary for
the prevention of money laundering and financing of Crime, are examined in detail every month.
Evidence that it has a Compliance Officer
Types of underwriting and claims services. And Experience and/or expertise in certain lines of
insurance and the ability to manage the underwriting and claims.
InteRBroS counts with professional and technical personnel, highly specialized and experienced,
having each served clients with a diversified business portfolio in terms of business lines in most
countries in the region for over 30 years.
InteRBroS also counts with an extensive network of companies and specialized independent and
experienced consultants, to which we turn to support us in technical, marketing, actuarial,
management and risk assessment, engineering and industrial safety and other areas related to the
insurance industry.
InteRBroS team specializes in the design, development, marketing and placement of
comprehensive programs and products in all types of insurance and reinsurance business both
facultative and treaty, proportional and non-proportional. InteRBroS is especially strong in the
Facultative business of property damage, Transport/ STP, Liability of large industrial risks/
economic conglomerates, as well as Treaty and Facultative Health, Critical Illness, Life / Group
Personal Accidents, including Mass and Related Products, for debtors and monthly collection
portfolios, associations, chambers of commerce and other distribution channels.
Detail of Service and responsibilities of InteRBroS towards its CLIENTS
As an international reinsurance intermediary, InteRBroS explaining the principal characteristics
of the products and services that it is offering to its clients, including costs, details of coverage,
exclusions, conditions and other obligations.
InteRBroS also provides to its clients complete information regarding any quoted risk, before this
one has been placed. InteRBroS places the reinsurance of its clients only when its clients
authorize it in writing, and lets them know, if it could not have completed the placement of the
reinsurance order granted.
Proof of coverage and politics of documentation
InteRBroS sends immediately to its clients, evidence of coverage in the form of a certificate of
reinsurance, of a copy of the Reinsurance Slip or InteRBroS will produce a contract of
reinsurance or a Cover Note. The clients must carefully examine all the reinsurance documents to
make sure they meet their requirements. However, if the documents do not meet with their
requirements, or if the clients feel that the documents are incorrect or if they are not satisfied with
participating reinsurers, InteRBroS will have to be notified as soon as possible. Otherwise,
InteRBroS will assume that the documents are in order. InteRBroS maintains the documents
of the business placed to benefit their clients in electronic format and on paper in accordance with
market practice.
Client Money
Being reinsurance brokers, InteRBroS receives the money of its clients to pay reinsurance
premiums, and money of the reinsurers to pay claims and/or returns of premiums for its CLIENTS,
being considered for all relevant purposes as “client money”, which is all managed through a
separate and independent operative bank account of InteRBroS called fiduciary account.
The funds in this fiduciary account will always be available both for the CLIENTS of InteRBroS and
for the reinsurers.
It is verified that the origin of the funds/ premiums received from the insurers, reinsurance brokers
and of any other entity locally authorized in accordance with law for the handling of premiums,
corresponds to the reinsurance premiums, net of the standard local discounts and taxes and in
accordance with applicable law in every country, of the risk that our company has placed on the
international reinsurance market on behalf of the insurer.
These funds of premiums and/or payment of claims that are always deposited in the fiduciary
accounts of InteRBroS are applied against financial accounts of premiums due and/or claims
pending to be paid based on the supporting documentation for premiums due and/or payment of
claims to/from reinsurers and/or to/from the insurers.
InteRBroS may only receive funds/ premiums or claims payments of insurance companies,
reinsurance brokers or any other company, provided that these are licensed/ authorized by the
relevant local authority under the rules and laws of the country they operate to manage reinsurance
premiums on insurance policies issued by insurers licensed according to law.
InteRBroS does not accept the offset of account between premiums and/or claims receivable
and/or premium/ claims payable neither of different reinsurance placements, nor of a same
reinsurance placement unless all the reinsurers and its CLIENTS have given their agreement in
writing and been in agreement with the balances that result from the offset of accounts.
Process of Financial Crime
If a financial crime occurred InteRBroS will do a process of investigation in the following
manner:
1- InteRBroS will make sure of taking an action if a financial crime is discovered.
2- The management of InteRBroS will establish an investigation.
3- The management of InteRBroS will establish a mechanism to document and report the
progress of the investigation.
4- The processes of the investigation can imply:
It will be maintained confidentially
Recovery of assets
Protection of evidence
Deal with the employees that they are under suspicion
5- The management of InteRBroS will check all the operative procedures
6- InteRBroS will make sure that the effective control is in place to preserve all the forms of
evidence.
7- The executives of InteRBroS will assess in an early stage the actions to adopt with the persons
under suspicion and if the suspension/ dismissal are necessary.
8- The executives of InteRBroS will establish adequate measures to protect the business during
the whole process of investigation.
9- The executives of InteRBroS will check the corrective measures and actions of improvement
to guarantee proper monitoring carried out.
Bribery and Corruption Politics and Procedures and Anti-Fraud Fight
InteRBroS will not tolerate acts of fraud or dishonesty. Any fraud, dishonesty, or other illegal
acts can be treated like serious and Associates may be subject disciplinary actions and possible legal
action.
Fraud or dishonesty acts can include the manipulation of records, the theft and the embezzlement of
funds or goods, undue use of information, records and equipment and bribes and inappropriate
payments. If any Associate knows or has suspicion that a fraudulent or dishonest activity is or can be
carried out, they must continue the procedure established in the previous paragraph.
This is essential since the possibilities of success of the investigation and resolution of a fraud, or the
elimination of the suspicions, might turn out to be seriously affected for taking the wrong actions.
Against Money Laundering
InteRBroS will not be knowingly the part of any deal or series of deals, which could change the
identity of the source of obtained money of illegal activities so that it seems as if it was coming from
a legitimate source.
Data Security
Data, systems security of InteRBroS which allow the e-mail and the exchange of information,
have turned into a central element in the form in which we all direct the business, the employees are
fully conscious of their responsibilities by virtue of the politics of InteRBroS, the code of
personal conduct to make sure that the accesses of information and the systems that process these are
fully protected. No employee must allow third parties to gain access to the system of InteRBroS
without the appropriate consent of his supervisor; employees are reminded that no software must be
loaded in the system of InteRBroS without the previous authorization of the supervisor of
InteRBroS.
Claims
The CLIENTS of InteRBroS, without delay, must notify to InteRBroS all the details of any
incident that could lead to a claim and provide all the information that they have available so that
INTERBROS can assist and comply with the terms of the reinsurance contract.
InteRBroS coordinates with its CLIENTS, with previously appointed adjusters and with
reinsurers, so there is an immediate attention and handling of the claim, supporting and helping clear
up any doubt, dispute on the placed reinsurance conditions.
If it is the case, InteRBroS will immediately inform its CLIENTS of the acceptance or denial of
any claim, jointly with the whole explanation of the reasons given by the adjustor and/or by the
reinsurers.
InteRBroS provides its CLIENTS a suitable, efficient and professional service in the handling of
their claims.
Communication of Material Facts
It is the duty of the CLIENTS of InteRBroS at the time of sending information about a new
offered business, to communicate all the relevant material facts to the Reinsurers through
InteRBroS. The CLIENTS should also keep InteRBroS informed of any event during the term of
the contract and/or at the time of the renewal, because they may also have to be communicated. A
relevant material fact is a fact that may influence the judgment of a Reinsurer in his evaluation of a
risk, including terms and pricing. If the CLIENTS have any doubt as to whether a fact is a relevant
material, InteRBroS recommends to be revealed. The failure to disclose relevant facts may entitle
Reinsurers to invalidate the contract from the beginning.
Warranties
The warranties are important provisions contained within the Reinsurance Agreement and must
always be fulfilled accurately. The breach of a warranty will cause the Reinsurers to be
automatically out of risk from the date of that violation, and in some cases may mean that reinsurers
do not come at risk at all. This is the position regardless if there is any connection between the
breached warranty and any loss that leads to such breach becoming evident. A warranty may exist in
the contract using different terminology without referring to the word warranty. It can be
conceptualized that InteRBroS’ CLIENTS (or their clients) have guaranteed the accuracy of the
information supplied in a questionnaire (e.g. under a Base Contract Clause), so that any
inaccuracies constitute a violation of warranty.
It is very important that the CLIENTS read the complete text of the contract carefully and if the
CLIENTS are not sure or cannot comply, they will have to get in touch with InteRBroS
immediately.
Conditions Precedent
The CLIENTS of InteRBroS must take note of any precedent condition that appears in the
Reinsurance Contract. If precedent to the validity of this Reinsurance Contract or at the inception of
the Reinsurance Contract a condition is not fulfilled, the Reinsurers will not enter risk. If a condition
precedent to the liability of the Reinsurers in accordance with the Contract of Reinsurance is not
complied with, the Reinsurers will not be responsible for the loss in doubt. A condition precedent
can exist in the contract using another terminology and without referring to the words “condition
precedent”.
It is very important that CLIENTS read carefully the full text of the contract and if the CLIENTS are
unsure or cannot comply, they should contact InteRBroS immediately.
Subjectivities
If the coverage that is provided is granted by the Insurers subject to certain requirements, failure to
comply may result in no coverage placement. The CLIENTS have to communicate with
InteRBroS immediately if they are unsure as to the meaning or significance of subjectivity, or
cannot comply with it.
Documentation Review and Participating Reinsurers List
According to the instructions and information provided by the CLIENT, InteRBroS will effect on
their behalf a Reinsurance Contract with Reinsurers under terms and conditions as detailed the
reinsurance slip and the Cover Note to be issued by InteRBroS. The CLIENTS shall examine
these documents carefully and if coverage, terms, conditions do not meet their demands or if they are
dissatisfied with the participating Reinsurers, we must be immediately informed. Otherwise,
InteRBroS will assume that the documentation is in order.
Compliance with Reinsurance Premium Payment Warranties
The CLIENTS of InteRBroS must comply with the payment of reinsurance premiums according
to the pay period imposed by reinsurers. Non-fulfillment of same, shall entitle reinsurers to cancel
the reinsurance contract or invalidate the payment of a covered loss as per the payment warranty
conditions imposed on each contract, as appropriate.
The CLIENTS may not unilaterally, perform offset of accounts between premium amounts and/or
claims receivable and/or premium amounts/ claims payable of different reinsurance placements,
neither of funds of the same reinsurance placement, unless all the reinsures and CLIENTS, have
given their agreement in writing and been in agreement with the balances that result from the
crossing of account.