GUIDING PRINCIPLES The UIB Holdings (UK) Limited group consists of companies which are leading insurance/reinsurance brokers in their chosen fields of business, trading under the highly respected name of UIB. Our success rests on the contributions of the directors, officers and employees of UIB companies around the world, who develop and implement plans and actions to achieve the goals set by the group from time to time. In doing so, UIB directors, officers, and employees are required at all times to respect international and national laws and observe the highest standards of integrity in the conduct of the Group’s businesses. UIB Holdings (UK) Limited (UIBH) has adopted this statement of its Guiding Principles as an expression of the core values described above. All UIBH wholly-owned and majority-owned affiliates (referred to in the rest of this document individually, as well as collectively, as UIB) are encouraged to adopt it. Integrity Ethical Behaviour UIB will always act in an ethically correct way. Compliance with the Law UIB seeks always to comply with the law in all places where it is present or transacts business. UIB has a zero tolerance policy towards:– corrupt behaviour of any kind; bribery; economic and financial crime of all kinds; and fraud (including tax evasion) in any shape or form, and in particular no one connected with UIB may offer or accept bribes, or be involved in, or facilitate, tax evasion. Dealings with Regulators and Other Public Administration UIB make full, fair, accurate, timely, and understandable disclosure in reports and documents filed with regulators and all other public authorities throughout the world, as well as in all other public communications. Transparency of Information UIB views transparency as an essential element of UIB’s relationship with stakeholders, and accordingly UIB is strongly committed to the production and retention of accurate and complete information and records, both paper based and all other kinds of record (such as emails). Business Partners Client Care UIB’s first and foremost concern are its clients. Clients are the focus of everything that UIB does. The client’s interests always come first. Client Relations and Service Quality UIB responds to ever changing client needs and requirements with speed and care. Gifts and Entertainment UIB, while always acting ethically, base all commercial decisions exclusively on commercial criteria. UIB directors, officers, and employees providing or receiving third party gifts and entertainment when representing UIB are expected to exercise good judgement in each case, taking into account pertinent circumstances. All expenditure for gifts and entertainment provided by UIB must be promptly, fully, and fairly recorded in UIB’s books and records. Conflicts of Interest UIB’s directors, officers, and employees must avoid any actual or apparent conflict between their own personal interests and the interests of UIB. Companies in UIB have systems and controls in place to help avoid and deal with any conflict between the interests of UIB and those of clients, and also as between the interests of multiple UIB clients should they conflict. Anti-Money Laundering; Anti-Terrorist Financing; Sanctions UIB complies with applicable national and international laws, rules and regulations to prevent, detect and report money laundering and to ensure that UIB is not involved in financing terrorism. UIB has processes in place to apply all sanctions rules that apply to UIBL (including when they are linked to deterring terrorist financing). Antitrust (Competition) UIB and their directors, officers, and employees must comply at all times with the antitrust and competition laws of each country or group of countries which are applicable to UIB’s businesses. Data Protection UIB and their directors, officers, and employees must observe all laws and regulations for the protection of client and personal data applicable to UIB’s businesses around the group. Human Resources Equal Employment Opportunity UIB seeks to attract, develop and retain a diverse workforce by providing an inclusive and supportive working environment, and guarantees each UIB employee equal opportunities to develop without discrimination in all aspects of the employment relationship, including recruitment, hiring, work assignment, work-time allocation, working conditions, training, professional development, promotion, transfer, dismissal, wage and salary administration, and selection for training. UIB seeks at all times to treat employees fairly and consistently. Discrimination UIB has a policy of zero toleration of any kind of direct or indirect discrimination, including because of race or ethnic origin, gender, beliefs (including religion), politics, sexual orientation, age or disability. Harassment UIB prohibits all forms of harassment in any UIB workplace, including any form of harassment by or towards employees, clients, suppliers and visitors. Modern Slavery UIB has a zero tolerance towards modern slavery and human trafficking, and expects UIB employees, and those UIB deals with, to uphold UIB’s high values. UIB is fully committed to ensuring that there is no modern slavery or human trafficking in its supply chains, and that everyone’s fundamental rights are respected. Privacy Each UIB company respects the privacy of the individuals it deals with, in particular that of its employees (but also clients and others), and has procedures in place to comply with all applicable privacy, confidentiality and data protection laws relating to the protection of personal data. Whistleblowing Where an individual discovers information which he or she believes shows serious malpractice or wrongdoing within UIB, it is UIB’s policy that that information should be disclosed internally without fear of reprisal. Alcohol and Drug Use Except where pre-authorised by senior management either to entertain business partners or for staff functions, and then only in limited quantities, UIB does not permit alcohol to be consumed on UIB premises. The misuse of legitimate drugs, or with the exception above the use, possession, distribution or sale of alcoholic beverages, or illicit or un-prescribed controlled drugs on UIB business or premises, is strictly prohibited. Security UIB strives at all times: to provide all employees, and all others who visit UIB premises – including third parties who may work with UIB – with a secure work environment; and to secure its assets (including its IT systems) from improper interference or use. Holding Office UIB restricts directors, officers and employees from holding office in non-affiliated, for-profit organisations, and prohibits any director, officer or employee from accepting any such office which would, or might, involve a conflict of interest with, or interfere with, the discharge of the director’s, officer’s or employee’s duties to UIB. Office in a non-affiliated, for-profit organisation is therefore subject to review and approval by UIB management. Company and Third Party Assets UIB Assets UIB requires its directors, officers, and employees to protect UIB’s tangible and intangible assets and use them efficiently to advance UIB’s interests. Third Party Assets UIB’s directors, officers, and employees are required to respect the ownership rights, and intellectual property rights, of third parties. Bassem Kabban, Chairman and Group Chief Executive Officer November 2020 COMPANY INFO UIB Holdings (UK) Limited 69 Mansell Street London E1 8AN ENGLAND Email: enquiries@uib.co.uk Tel: +44 (0)20 7488 0551 Fax: +44 (0)20 7480 5182 Guiding Principles Section 172 Statement Modern Slavery Privacy Notice Terms & Conditions Sitemap Copyright © 2021 UIB Holdings (UK) Limited | All Rights Reserved