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

As a mutual insurer we aim at the highest standards of service - and fairness - towards members and brokers. If you have a complaint, or any other comment, about the maintenance of these standards by ITIC, or by anyone acting on behalf of ITIC, we ask that you let us know immediately. This will allow us both to resolve the issue which you raise and to take action to improve our service to other members and brokers in the future.

ITIC is regulated in the UK by the UK Financial Conduct Authority (FCA). We will deal with complaints from eligible complainants according to the requirements of the FCA. These include timescales for acknowledgement and response and an obligation to advise the complainant on further action if he or she remains dissatisfied. The notified person for resolving these complaints is the Chief Operating Officer of ITIC and complaints may be addressed direct to him at alistair.mactavish@thomasmiller.com or through your usual ITIC contact.

We will deal with complaints other than from eligible complainants for the purposes of the FCA as far as practicable as if they were from eligible complainants.

ITIC Europe is regulated in the Cyprus by the Superintendent of Insurance of the Cyprus Ministry of Finance. Complaints in respect of ITIC Europe should be addressed to the CEO of ITIC Europe at charlotte.kirk@thomasmiller.com

Financial Ombudsman Service

If you are dissatisfied with the final response we send you, you may refer your complaint to the Financial Ombudsman Service. You may also refer your complaint to the Financial Ombudsman Service if we have not sent you a final response within eight weeks. The Financial Ombudsman Service will write to us requesting a summary of the matter, and will liaise directly with us in resolving your complaint. If the Financial Ombudsman Service makes a determination that they will take up your case, the matter will be decided by them following a thorough investigation.

Further details of the Financial Ombudsman Scheme are available from the Financial Ombudsman Service.

Contact details

Financial Ombudsman Service
The Financial Ombudsman Service
Exchange Tower
London E14 9SR

0800 023 4 567

Website: www.financial-ombudsman.org.uk

If you are a policyholder of ITIC Europe, you may be able to refer this matter to the Financial Ombudsman Service of the Republic of Cyprus. Their contact details are as follows:
 
The Financial Ombudsman Of The Republic Of Cyprus
15 Kypranoros, 1061 Nicosia
or P.O. Box. 26722, 1647 Nicosia
Email: Complaints@financialombudsman.gov.cy
 
Following this complaint procedure does not affect your rights to take legal action.

For those members based in either the United States of America or Australia underwritten by the TT Club, you may be able to refer any disputes to either local, territory, state, federal or national insurance regulators, details of which are available on request.

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

Solvency II Reporting

The Solvency and Financial Condition Report (“SFCR”) provides the general public with an overview of the company’s solvency and financial condition covering business performance, its system of governance, the adequacy of its risk profile and a description of its capital management.
 

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