Compliance

Anti-Bribery policy

As a mutual insurer for companies within the transport sector ITIC and its Managers, Thomas Miller/ ITIM Co Ltd, set great store by equity between Members and probity when dealing on their behalf. In support of our commitment to maintaining the highest possible standards of business practice we hold a 'zero-tolerance' stance towards bribery. Bribery is illegal and as such has no place in our organisation.

Our Policy

In accordance with the Bribery Act 2010, ITIC prohibits absolutely the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement, regardless of size:

• to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company;
• by any individual employee, agent or other person or body acting on behalf of ITIC;
• in order to gain any commercial, contractual or regulatory advantage for ITIC in a way which is
  illegal or unethical;
• or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.

Interpreting the policy

It is not the intention of the policy to prevent the following activities, particularly in relation to our international role as an insurer and claims handler.

• Normal and appropriate hospitality.
• The giving and receiving of ceremonial gifts.

Such hospitality or gifts must be in moderation and not place any expectation on the recipient to reciprocate either in like or by performing, or failing to perform, any other task in return.

If there is any doubt as to whether an action might constitute bribery the matter should be referred to a director of the management team of ITIC, Thomas Miller/ITIM Co Ltd , for a decision.

Preventing and reporting bribery

All management staff working on behalf of the ITIC have a responsibility to prevent, detect and report bribery. We provide appropriate guidance to our staff in fulfilling this duty.

Should you hold any suspicion of bribery or attempted bribery committed by or against an employee, agent or other party acting on behalf of ITIC, it must be reported immediately to a director of the management team.

Complaints procedures

We are dedicated to providing you with a high quality service and we want to ensure that we maintain this at all times. If you feel we have not met your expectations please first write to your insurance broker or intermediary, if any.

If you are a member who places his insurance direct to ITIC or are an insurance broker or intermediary and wish to complain about any matter relating to policy wordings or documentation, speed of response etc, please contact the following:

The Underwriting Director
International Transport Intermediaries Club Ltd.
90 Fenchurch Street
London, EC3M 4ST
United Kingdom

Tel: + 44 (0) 20 7338 0150

Email: ITIC@thomasmiller.com

If, after contacting your insurance broker, you remain dissatisfied about any aspect of a claim, please contact:

The Claims Director
International Transport Intermediaries Club Ltd.
90 Fenchurch Street
London, EC3M 4ST
United Kingdom

Tel: + 44 (0) 20 7338 0150

Email: ITIC@thomasmiller.com

In the event that you wish to pursue matters further, we refer you to Rule 28 – Disputes and Differences.

Whether you are a member based in the United Kingdom or elsewhere (as although you may not be based in the United Kingdom, ITIC is) you may be able to refer this matter to the Financial Ombudsman Service. Their contact details are as follows:

The Financial Ombudsman Service
Exchange Tower
London E14 9SR

Help line: 0800 023 4 567 Switchboard: 020 7964 1000 For calls outside of the UK: +44 20 7964 1000

Website: www.financial-ombudsman.org.uk

Email:  complaint.info@financial-ombudsman.org.uk

Following this complaint procedure does not affect your rights to take legal action.

ITIM Co. Ltd. ist der offizielle Repräsentant von International Transport Intermediaries Club Ltd., der durch die Aufsichtsbehörde genehmigt und durch die Finanzaufsicht und die Aufsichtsbehörde geregelt ist. International Transport Intermediaries Club Ltd (Handelsregister Nr. 2725312) und ITIM Co. Ltd. (Handelsregister Nr. 2670020) sind in England registriert.

Die eingetragene Anschrift lautet: 90 Fenchurch Street, London, EC3M 4ST

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