There will be times when you may be under pressure or unsure of what to do. When faced with difficult decisions, it may help to ask yourself the following:
Collaboration – Partners
Conflicts of Interest
Conflicts of Interest
Maintaining the trust of Clients and Trading Partners is imperative. We must put Clients’ and Trading Partners’ interests before all other business considerations.
What Is a Conflict of Interest?
A conflict of interest is anything that impedes, or might be perceived to impede your ability to act impartially because of a conflict between your self-interest and the interests of Ryan Specialty, or between Ryan Specialty’s interests and those of Clients and Trading Partners.
Avoiding conflicts of interest, whether apparent or actual, is of paramount importance. Conflicts of interest can arise, for example, between: clients and Ryan Specialty, between Employees and clients, or between Employees and Ryan Specialty. Conflicts can occur at any time and may impact your ability to make objective, professional decisions. You must avoid creating real or perceived conflicts of interest and disclose any conflicts or potential conflicts of interest to Ryan Specialty, its clients and vendors.
Understanding Conflicts of Interest
We must be positive and transparent in all of our interactions. Ryan Specialty encourages you to recognize that a conflict of interest may not always be easily identifiable and stresses the importance of speaking up if a concern arises.
Conflicts of interest also arise when an Employee (or a member of his or her family) receives improper personal benefit as a result of his or her position in the company.
Loans by the Company to, or guarantees by the Company of, obligations of any Employee are expressly prohibited.
Whether or not a conflict of interest exists or will exist can be unclear. Conflicts of interest should be avoided unless specifically authorized. Persons other than directors and executive officers who have questions about a potential conflict of interest or who become aware of an actual or potential conflict should discuss the matter with and seek a determination and prior authorization or approval from the Corporate Chief Compliance Officer.
Make Good Decisions
Kickbacks and Rebates
Ryan Specialty holds high expectations for its Employees at all levels, and prohibits any illegal kickbacks or rebates. Improper kickbacks and rebates are defined as offering any valuable consideration or inducement that is not specified within a contract or agreement. Employees that transact insurance should be aware of all applicable laws and regulations prohibiting kickbacks and rebates.
Gifts and Entertainment
Employees are forbidden from accepting any gifts or any remuneration from third parties, unless nominal and not prohibited by law. However, even when permitted, Ryan Specialty asks you to avoid accepting any gift which could be perceived as influencing your independent and objective judgment regarding business decisions. Likewise, Ryan Specialty restricts Employees from offering any gifts to clients, insureds or prospective insureds, unless expressly permitted, and requires all gifts to have a business purpose. Gifts can never be given with the intent to induce or bribe under any circumstance and gifts can never, under any circumstance, be given to any government official.
In the right circumstances, a modest gift may be a thoughtful “thank you,” or a meal may be an appropriate setting for a business discussion that strengthens a client relationship. When not used with care, however, gifts and entertainment may create the appearance of improper influence, violate client standards, and may even be violations of the law.
Political and Charitable Contributions
Donations to political candidates, political parties, or political action committees on behalf of Ryan Specialty are prohibited. As a private citizen you are welcome to participate in the political process, including making personal political contributions, but must always make clear that your personal views and contributions are not those of Ryan Specialty. Political activities must not create an actual or apparent conflict of interest with Ryan Specialty duties.
A request from a client to sponsor or donate to a charity, such as purchasing a table at a charity event, can be considered and should be commensurate with the status of the client requesting the sponsorship or donation.