IAG (“the Company”) upholds the highest professional standards in confidentiality and compliance when managing client and third-party information and business best practices. We also ensure that the Insurers with which we place business are compliant through every step of the policy placement and management process. IAG colleagues must comply with the Competition Act and antitrust law in Canada. Violation of these laws could severely damage the Company’s reputation and result in severe penalties.
The Competition Act and antitrust laws are complex. Colleagues who are unsure of appropriate practices are required to consult with IAG’s management. This policy applies to all colleagues of IAG. IAG is committed to competing vigorously and fairly for business by providing superior products and services, not be engaging in improper or anti-competitive practices. The Company and its colleagues must comply with applicable Competition Act and antitrust laws and must compete fairly and ethically for business.
Defining Competition
IAG is expected by the governing bodies in the areas where it conducts business to compete vigorously for client business through fair practices. The Competition Act and antitrust laws are different names for laws designed to protect competition and regulate how companies compete with each other and deal with clients and suppliers.
Anti-competitive behaviour prohibited by such laws includes:
COLLEAGUE RESPONSIBILITIES
IAG colleagues are required to comply with applicable the Competition Act and antitrust laws and compete fairly and ethically for business. The following guidelines will ensure fair business conduct and appropriate competition in IAG’s business conduct.
Avoiding Collusion
Colleagues are not permitted to:
IAG and its colleagues can be held liable for an antitrust violation for disclosing competitively sensitive information. Competitively sensitive information can include:
Avoiding Bid-Rigging
When conducting or managing a bidding process on behalf of clients IAG colleagues are not permitted to:
Avoiding Tying, Exclusive Dealing or Predatory Pricing
IAG colleagues are not permitted to:
Participation in Trade Associations
An IAG colleague who participates in a trade, industry or professional group, should not use this group as a forum for reaching unlawful agreements or improperly exchanging competitively sensitive information. When joining any external association applicable to IAG’s line of business, IAG colleagues should:
If required, IAG colleagues should remove themselves from the meeting or conversation and request that their departure time be recorded in the organization’s meeting minutes. Colleagues are required to immediately report the events of the meeting to IAG’s legal advisors.
Maintaining Accurate Records and Reporting
Any interactions IAG colleagues have with competitors or suppliers and any records created relating to the interaction, such as e-mail messages, must be accurately recorded. If an IAG colleague becomes aware of antitrust or competition-related inquiries from a government agency, they are required to contact IAG’s management immediately. Further, if an IAG colleague becomes aware or suspects any violation of this policy by another colleague, they are required to contact IAG’s management immediately.
MANAGEMENT RESPONSIBILITIES
IAG’s management is responsible for assessing the Company’s risk related to the Competition Act and antitrust laws and to develop appropriate mitigation procedures relative to the Company’s level of risk, which may include communications, controls, training, certifications, monitoring and/or documentation requirements. IAG’s management is also responsible for determining, on a risk-based basis, which categories of vendors and third party service providers present a risk of violating the Competition Act and antitrust laws and the controls that should be put in place relative to that risk. In addition, they are responsible for determining the circumstances in which it is appropriate to obtain the agreement of third parties to comply with this policy. All IAG colleagues are responsible for reporting any violations of this policy to IAG’s President.
THIRD-PARTY RESPONSIBILITIES
When IAG retains third parties to provide services to the Company or its clients, the IAG colleague supervising the third-party relationship is required, when appropriate, to ensure that the third party is in agreement to comply with this policy and any procedures issued pursuant to this policy.
Training and Auditing
All IAG colleagues are required to undergo the training required on this policy. Internal auditing to monitor employee compliance with this policy will be annually and periodically performed, as required. Findings of these audits will be reported to IAG’s President. Failure to comply with this policy may result in disciplinary action in accordance with local laws and/or internal Company procedures, up to and including, termination of employment or contract for services.
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