Conflict of interests refers to a situation, even potential, of conflict that arises between the interests of an insurance company or the distributor of insurance products and those of its client, or between the interests of different clients.
In accordance with the regulatory provisions, the Company has formalized a specific Regulation regarding conflicts of interest in the design, management, and distribution of insurance products. This Regulation outlines principles, roles, and responsibilities related to conflicts of interest in the context of designing, managing, and distributing insurance contracts. It identifies operational areas where potential conflicts of interest may occur and establishes measures for their prevention and mitigation.
Conflicts within the scope of product design and management can relate to the internal process of creating a new product and its management. These conflicts manifest in the definition of a product that does not consider the reference market, the insurance needs of the identified target market, and the distributor.
Potential conflicts also arise in the management of insurance investment products, including those resulting from relationships with the Banco BPM Group or business relationships specific to the Company or Group companies. These situations include cases where the Company or its distributor has relationships of influence with external entities. Agreements in such cases must include specific contractual safeguards to prevent conflict of interest situations and mitigate associated risks.
The Regulation establishes general principles that the Company must adhere to, considering the principle of proportionality based on the size and complexity of its activities. The aim is to minimize situations that generate or could generate conflicts of interest.
While some conflict of interest situations may be inherent and cannot be eliminated entirely, organizational and administrative measures are adopted to prevent identified conflicts from negatively impacting client interests.
The measures implemented are guided by the following principles:
For each identified conflict of interest, specific organizational, behavioral, and governance measures are put in place to manage and mitigate the risks.