International Life Plan
What is the International Life Plan?
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A level, regular premium Once issued, premiums do not change, no matter your age.
The Life Cover Solution for Personal, Family and Business Wealth by Lombard International Assurance
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The International Life Plan (ILP) is a pure protection product that offers High Net Worth individuals, families and businesses the ability to protect key parts of their financial legacy and seeks to provide greater efficiency in their estate planning.
Combining compelling features and having access to strong market capacity, our International Life Plan solution can provide much needed peace of mind when it comes to estate and liquidity planning. It offers:
Issuance from Luxembourg With flexibility to include ownership by structures and international lives assured.
Financial Security High amounts of coverage capacity reinsured by RGA International, which is rated AA- by S&P Global Ratings. RGA International is one of the world's largest global life & health reinsurer by revenue.
Who is this solution for?
The International Life Plan may be especially valuable for individuals, families or businesses who are:
UK and Finnish residents
Non-Resident individuals owning UK property
International clients
Corporate clients and family businesses
The International Life Plan can be used to cover UK and Finnish Inheritance Tax (IHT) liabilities that clients may face on their worldwide estates.
With the ILP, clients do not need to remit funds or assets to the UK to pay premiums, due to our Luxembourg status.
Utilising our expertise and connections enables us to serve an international client base, including non-UK residents facing the prospect of UK tax exposure. Policies can be held in trust or corporate structures.
The International Life Plan is also designed to cater for business risks, including key person, shareholder and/or partner protection.
Lombard International Assurance S.A. 4, rue Lou Hemmer L-1748 Luxembourg Grand Duchy of Luxembourg Tel: (+352) 34 61 91-1
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Why the International Life Plan?
For higher value death benefit solutions, Finnish residents, UK residents, UK resident non-domiciliaries (RNDs), international clients and their families have only a limited range of providers who can meet their policy requirements. Even where some pure risk cover may be available, pricing is considered to be unattractive and the levels of coverage capacity are not sufficient to meet client needs.
For Business Owners with young families, liquidity on death can be a profound issue where wealth is tied up in a Company, yet there is the need to meet IHT liabilities within a short period of time. The International Life Plan can help prepare for this exposure as well as meeting other Corporate protection needs.
Benefits of the International Life Plan
One of the largest global life and health reinsurance companies 100% focus on Life & Health risk (AA- S&P Global Ratings’ financial strength)
Offers a broad range of cover options to a geographically diverse client base
Number of lives assured: Flexibility to meet clients’ structuring needs
Certainty over the amount available at death
No correlation of death benefit with market fluctuation/volatility
Duration: Flexibility to match policy term to the anticipated period of exposure
Multicurrency options available: choose benefits in GBP, EUR, USD, CHF. Eliminates foreign exchange exposure and allows clients to obtain a death benefit in the currency of the risk
Large coverage capacity designed with the needs of HNWIs in mind
Clients can subscribe with peace of mind that, once underwritten, their premiums will not change as a function of age or the length of time the ILP has run
Cover available across key age ranges
Examples of what the International Life Plan can be used for
UK RESIDENT
FINNISH RESIDENT
Trustees of a large settlement for a Qatari family with significant UK IHT liability; Settlor has no other connection to the UK and is aged 60; Other policies (Unit-Linked Life Insurance) owned by the corporate trustees have been subject to revisions on premiums; UK Property is valued at £25m with IHT liability of £10m.
Example Client
Solution
Client, having a UK insurable interest, subscribes to an International Life Plan policy; The policy is sold in the UK and subject to English law; Whole of Life is selected for a cover of £10m; The level annual premium is £323,300; Family and trustees meet in London and sign Application Form.
Benefits
International life assured accepted for coverage; Fixed premium eases trustees’ key concerns.
Liquidity available in the event of the client's death within the policy term(s). Policy taken out to cover IHT on corporate asset value meaning there is no requirement for the family to sell the company to meet IHT needs.
Asset value: €100m; Policy coverage: 2 × €10m; Term: one policy for a 10 year term and one for a 15 year term to coincide with children reaching age 18; Relevant IHT: 19% of asset value Total Premium: €14.500 p.a.
Finnish resident entrepreneur; Owns company valued at €100m; 2 children aged 8 and 3; 32 years old; Non-smoker.
Quick Facts
Custodian banks
Investment Managers
International team of
Partnership underpins everything we do
(Assets under Administration) As at 31 December 2022
AuA
Proven track record
All details given as benefits are subject to the terms and exclusions described in the General Terms and Conditions of the International Life Plan, the accuracy of information provided as part of the application process and the terms of any eventual offer of Cover.
Who we are
Lombard International Assurance S.A. has been partnering with the advisers of high and ultra-high net worth individuals and institutions for over 30 years, providing tailored and efficient solutions to complex needs and family structures. We provide a highly specialised, authoritative perspective in an increasingly uncertain world. We are specialists in insurance-based wealth solutions, with a team of more than 60 technical experts in wealth planning, tax law and non-traditional assets around the world. This deep-rooted expertise offers clients a proven capability that works across borders, regions and geographies, giving them the choice and flexibility to meet their unique needs.
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Legal disclaimer
The content of this website is intended solely to provide general guidance to the reader of these pages on the services offered by Lombard International Assurance. The information contained within these pages is not intended as an offer to sell or solicitation for the purchase or sale of any life assurance product. Neither is the information intended to constitute any form of legal, fiscal or investment advice or recommendation and it should therefore be used only in conjunction with appropriate professional advice obtained from a suitable qualified professional source. Lombard International Assurance does not warrant, represent or guarantee that the information contained within these pages is complete, accurate or up-to-date. Lombard International Assurance expressly disclaims all liability to any person in respect of anything, or the consequences of anything, done or omitted to be done wholly or partly in reliance upon the whole or any part of the contents of the Lombard International Assurance website. On this website you may be offered automatic links to other websites. Following such links to off-site web pages is entirely at the risk of the user. Lombard International Assurance does not endorse or accept any responsibility for off-site web page content, nor the products or services offered through them. Access to off-site web pages is entirely at the risk of the person accessing such information. Lombard International Assurance does not represent or warrant that that access to off-site web pages will be uninterrupted, that there will be no delays, failures, errors or omissions or loss of transmitted information, that no viruses or other contaminating or destructive properties will be transmitted or that no damage will occur to your computer system. The information, material and content provided in these pages may be changed at any time without notice. The Lombard International Assurance website is not intended for any person in any jurisdiction where, by reason of that person’s nationality, residence or otherwise, the publication or availability of the Lombard International Assurance website is prohibited. When registering, you declare accepting that your personal data obtained by Lombard International Assurance can be used for marketing and prospecting needs. You can ask for this information to be communicated to you and to be corrected, if necessary, by applying in writing to Lombard International Assurance. The laws on intellectual property are applicable to the content of this website. It is strictly prohibited to copy, transfer, distribute, modify or register all or part of the content, illustration, layout, look and feel, logos and trademark of this website, in whatever form. All rights are reserved. The information supplied on these pages is subject to the laws of the Grand Duchy of Luxembourg. This financial promotion has been approved for distribution in the UK by LIA Wealth Advisers Limited, 58 Grosvenor Street, London W1K 3JB, United Kingdom, a company registered under number 11732755, which is authorised and regulated by the Financial Conduct Authority under number No. 829788. FP/2023/7/6
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At Lombard International Assurance, we take personal data protection seriously and we are dedicated to protecting the confidentiality and privacy of information entrusted to us. This Privacy Notice provides information on the processing of personal data by Lombard International Assurance with its offices at 4, rue Lou Hemmer, L-1748 Luxembourg, Grand Duchy of Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B37604. At Lombard International Assurance, we collect such Personal data mainly by requesting it directly from the persons whose personal data we process. In some limited circumstances, personal data may come from others sources, mainly in the case of anti-money laundering research. Personal data includes any information by which you may be directly or indirectly identified which may be held on paper, electronically or otherwise. This Privacy Notice sets out:
- To whom this Privacy Notice applies
- The purposes for which we may process your personal data
- How long we will keep your personal data
- Who has access to your personal data
- How can you exercise your rights
- How you can contact us
- How we protect your personal data
Privacy NOTICE
This Privacy Notice is applicable to the processing of all personal data of our customers and other persons interested in our products, our suppliers, service providers and professional partners (e.g. intermediaries, banks and investment managers), and prospects.
To whom does this privacy notice apply?
Your personal data can be retained for different periods of time, depending on the purposes of the processing and category of personal data, however it will always be retained in compliance with the applicable laws and/or regulations.
How long will we keep your personal data?
- The processing is necessary in view of entering into or for the performance of a contract (e.g. insurance policy, service agreement); - The processing is necessary for compliance with a legal obligation (e.g. disclosure to government institutions or supervisory authorities, AML/CTF checks); - The processing is necessary for the purpose of the legitimate interests of the company (e.g. call recording to limit corporate liability when clarifying instructions over the phone). - The processing is necessary to respond to your query(ies) submitted via our website contact form, email or any other means.
We may ask for your written consent before processing your personal data for a purpose other than those listed above. If you have given your consent for the processing of your personal data, you have the right to withdraw this consent at any time, without affecting the lawfulness of the processing based on consent before withdrawal. We will not use your personal data for direct marketing purposes without your explicit prior consent. If, at any time, you decide not to receive any commercial or promotional information from us, you may, without having to provide any justification, opt-out of any direct marketing campaigns and oppose to the future processing of your personal data for such purposes by sending an email to the attention of our Marketing and Communication departments at communications-eu@lombardinternational.com.
Lombard International Assurance may collect and process your personal data (including but not limited to the following categories of data: identification data, contact details, medical and health data, professional data, financial and tax information, health information, AML (Anti-Money Laundering) and CTF (Counter-Terrorist Financing) related data, voice recordings, computer device data such as IP address and logon details) for the following purposes:
For which purposes do we process your personal data?
1.1 Access to your personal data by our employees Your personal data is available on a need to know basis within Lombard International Assurance, and can only be accessed by the employees of the relevant internal departments to the extent necessary to fulfil their respective tasks and responsibilities. Our employees process your personal data in accordance with our policies and procedures to ensure an adequate level of security. 1.2 Access to your personal data by third parties Depending on the purpose for the processing of your personal data, third parties may have access to your personal data when this is necessary for the provisioning of their products or services to Lombard International Assurance. These third parties may be other group companies, banks, insurance companies, head-hunters/recruitment agencies, IT suppliers, service suppliers, financial, tax or legal advisors, auditors, IT forensic experts, partners or a regulatory or government body. If your personal data is transferred to a recipient in a country that does not provide an adequate level of protection of personal data, Lombard International Assurance will transfer your personal data in compliance with the applicable laws (including Luxembourg professional secrecy law), as well as on the basis of appropriate and suitable safeguards such as EU Standard Contractual Clauses with these third parties. 1.3 Sub-processing of your Personal Data Lombard International Assurance may use external providers (data processors) to process your personal data on its behalf. Lombard International Assurance S.A. shall only use processors providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that processing will meet the requirements of the General Data Protection Regulation and ensure the protection of your privacy. As data controller, Lombard International Assurance will ensure that processors act under its authority and only process personal data insofar as strictly necessary for the performance of the services contracted.
Who has access to your personal data?
Protecting your privacy is very important to us. Lombard International Assurance has taken adequate safeguards to ensure the confidentiality and security of your personal data by implementing appropriate technical, physical and organisational measures to protect personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access, and against all other forms of unlawful processing (including, but not limited to unnecessary collection) or further processing. Lombard International Assurance is ISO/IEC 27001 certified.
How do we secure your personal data?
You have certain rights regarding your personal data. You may exercise your right to request access to or rectification of and, as the case may be, erasure of any Personal Data relating to you, or to object to processing, or restriction of processing, as well as your right to data portability, in compliance with applicable data protection law, by sending a signed request form with a copy of your ID card, passport or other proof of identity to the attention of our Data Protection Officer (whose details are mentioned below).
How can you exercise your rights?
If you have any questions related to your personal data or you have concerns regarding the way in which your personal data is processed by Lombard International Assurance, please contact our Data Protection Officer at dataprivacy@lombardinternational.com or by post at the address of the company. You can find more information about the privacy legislation on the website of the Luxembourgish Data Protection Authority (CNPD) at www.cnpd.public.lu. We are committed to working with you to obtain a fair resolution of any concern about privacy. If, however, you believe that we do not comply with the applicable privacy rules, you have the right to lodge a complaint with the Luxembourg supervisory authority, the Commission Nationale de la Protection des Données, using the form available on the website: https://cnpd.public.lu/en/particuliers/faire-valoir/formulaire-plainte.html; or any other competent EEA data protection authority.
Who can you contact?
Disclosure of information about policies on the integration of sustainability risks in investment decision-making process and investment advice (Article 3)
The Environmental, Social and Governance Policy (the “ESG Policy”) of Lombard International Assurance S.A. (the “Company”) defines the Company's sustainability principles and targets. Lombard International Assurance S.A. is committed to contribute towards implementing the UN 2030 Agenda for Sustainable Development and in particular, comply with the EU implementation measures on Sustainable Development. For this purpose, the Company has rolled-out and implemented a number of initiatives which e.g. protect our environment, reduce inequalities or support health of employees over the last years. A strong governance structure is protecting the interests of the Company's clients, employees and stakeholders and helps the Company to implement its sustainability strategy. As Lombard International Assurance S.A. is not managing assets the Company's ESG Policy does not define how sustainability risks are integrated in the investment decision-making process. Where Lombard International Assurance S.A. is acting as Insurance Distributor it does not consider sustainability risks in its advice and for this reason the Company's ESG policy does not define how sustainability risks are integrated in insurance or investment advice.
Disclosure on due-diligence policies with respect to principal adverse impacts of investment decisions on sustainability factors OR where adverse impacts are not considered, explanation why this is not the case (Article 4)
Lombard International Assurance S.A. provides a range of unit-linked insurance products. The investment parameters for those solutions and the principles of their underlying asset allocation are determined by the Insurer in accordance with its own investment policy, Luxembourg law and, often, insurance law and taxation in policyholders’ countries of residence. However, investment decisions are ultimately taken either by independent investment managers appointed by Lombard International Assurance S.A. or (in certain) countries by, or with the confirmation of, policyholders themselves, who may in turn receive investment advice. As such, it is the independent investment manager, investment adviser or, if this is the case, policyholder who is best placed to integrate sustainability risk into investment decision making and assess the principal adverse impacts of investment decisions on sustainability factors and risks on investment returns. For the same reasons, neither Lombard International Assurance S.A. as a financial market participant nor the unit-linked insurance products issued by Lombard International Assurance S.A. consider the adverse impacts of investment decisions on sustainability factors. Likewise, Lombard International Assurance S.A., when acting as Insurance Distributor, does not consider the adverse impacts of investment decisions on sustainability factors in the insurance advice carried out.
Introduction Lombard International Assurance (the “Company”) established a Remuneration Policy in accordance with the applicable regulatory requirements. Reviewed on an annual basis or when deemed necessary it applies to all staff members. Its purpose is to define the principles and guidelines to establish and maintains equal, controlled and compliant remuneration practices that are designed to prevent (1) non-sustainable business decisions, (2) decisions in conflict with the Company and its clients’ interests, (3) risk-taking outside of risk appetite, (4) fines from the regulator(s), (5) financial loss and/or (6) demotivation of staff members. The Board of Directors, in order to exercise its responsibilities regarding remuneration, delegates the oversight of the execution of this policy to the Remuneration Committee (RemCo). The Company’s aim is to provide fair remuneration that contributes to attracting and retaining people while incentivising and rewarding them via variable remuneration for the successful delivery of the Company’s strategy and business priorities. The mechanisms of this remuneration should, in compliance with applicable regulatory requirements and best market practice (i) discourage risk taking beyond defined risk appetite (ii) prevent non-sustainable decision making and (iii) avoid situations of conflict of interest.
The Company identifies, on an annual basis, all employees whose work is deemed to have a major influence on the overall risk profile of the Company. A suitable compensation structure is designed and subject to deferral rules.
The RemCo may decide, at any time within 3 years of the date of a Bonus allocation that the Employee who has been allocated that Bonus shall be subject to claw back of the related Bonus allocation, if such claw back is justified in relation to one or several of the following circumstances:
Lombard International Assurance (the “Company”) established an Inducement Policy (the “Policy”) in accordance with the applicable regulatory requirements. Inducements mean any fee, commission, or any non-monetary benefit provided by or to an intermediary or insurance undertaking in connection with the distribution of an insurance-based investment product or an ancillary service, to or by any third party except the customer or a person on behalf of the customer. Inducements do not include fees paid by the customer or internal payments to employees of insurance distributors. The Policy defines that inducements and inducement schemes paid or received must not lead to a detrimental impact on the quality of the service provided to customers and prevent the insurance intermediary or insurance undertaking from complying with their obligation to act honestly, fairly and professionally and in accordance with the best interests of its customers. The Policy defines clear criteria in order to assess whether an inducement can have a detrimental impact on the services provided to the client. On a regular basis all identified inducements are reviewed and assessed. Any inducement which is likely to have a detrimental impact on the services provided to the client are escalated to the company’s Compliance Department in order to implement mitigating actions. Lombard International Assurance S.A. does not make investment decisions in respect of the assets underlying its life insurance policies, nor does it consider sustainability risks in its insurance advice as assets will exclusively be selected by independent investment managers appointed by Lombard International Assurance S.A. or (in certain) countries by, or with the confirmation of, policyholders themselves, who may in turn receive investment advice. As a consequence, this Inducement Policy does not take into account the integration of sustainability risks in the investment or insurance advice.
Ensure that remuneration is appropriate and linked to the role of the individual. Rewards the overall delivery of the business strategy, achievement of financial results and long term growth and sustainability. Aims at paying fair base pay, based on market practice, and at recognising and rewarding collective and individual performance via variable remuneration. Encourages sound corporate governance and a strict compliance with internal rules and procedures. Does not reward excessive risk-taking outside of confirmed risk appetite. Considers the principle of proportionality in defining the remuneration principles in such a way as to take into account the internal organisation and the nature, the scale and the complexity of the risks inherent to the business
The Company’s remuneration framework is designed to:
Remuneration policy statement (Article 5)
A sustainable remuneration framework
Specific provision for Material Risk Takers
Claw back mechanism
Remuneration Policy
Inducement Policy
ESG: SFDR disclosures
any act of fraud or other intentional infringement of penal law caused by the Employee or of which the Employee had knowledge of but failed to prevent and/or flag to the board of the Company as appropriate; any circumstances caused through wilful misconduct and/or gross negligence by the Employee, or of which the Employee had knowledge of but failed to prevent and/or flag to the board of the Company as appropriate, that has (or would have if made public) a significant impact on the reputation of the Company; or a material misstatement of the Company’s financial results, caused by or of which the Employee had knowledge, and which had been considered in the Bonus determination.
SRDII disclosure notice
Disclosure in accordance with Directive (EU) 2017/828, the “Shareholder Rights Directive II” (SRD II) Lombard International Assurance S.A. provides a range of insurance-based unit-linked wealth planning solutions. In this context, and in contrast to general insurance funds under which the assets of all policyholders of the insurance company are managed together according to principles determined by the insurer, assets underlying a unit-linked life insurance contract are managed at the discretion of an appointed investment manager pursuant to the investment strategy selected by each policyholder. As a consequence of this type of arrangement whereby the investment manager is vested with such discretion, Lombard International Assurance S.A. is not involved in asset management decisions and therefore it does not monitor the corporate governance or capital structure of listed investee companies. However, Lombard International Assurance S.A. may decide to use its voting right, if it is deemed to be relevant considering the size of possession or the topic of the vote. Lombard International Assurance S.A. may use its voting right directly or via an authorisation. Lombard International Assurance S.A. appoints investment managers following a rigorous selection and due diligence process, after which it enters into an Investment Management Agreement with each investment manager it appoints. The Investment Management Agreement describes the framework for the management of assets underlying a life insurance contract. Investment managers follow the investment mandate provided for each policy account. The investment mandate defines in which asset classes and within which allocation ranges the investment manager may invest at his own discretion and without further guidance by Lombard International Assurance S.A.. A dedicated investment mandate is provided to the investment manager for each account on the basis of the investment strategy selected by the policyholder. Investment managers do therefore neither align the management of the assets linked to life insurance contracts issued by Lombard International Assurance S.A. to the financial structure or governance of Lombard International Assurance S.A. nor is the remuneration of the investment manager linked to these factors. The Investment Management Agreement between Lombard International Assurance S.A. and the investment manager is in force until further notice. Lombard International Assurance S.A. monitors the compliance of assets managed by the appointed investment managers.
Whistleblowing Policy Notice
The Lombard International Assurance S.A. Whistleblowing Policy has been reviewed in April 2020 in order to align with the obligations imposed by the EU Whistleblowing Directive 2019/1937 and the EU Directive 2018/843 (the “5th AML Directive). Both have caused some impact in terms of reporting channels and sanctions. The main points of the implementation are listed below: 1.Revamp of the reporting channels including eligible persons and types of information to be reported Who is eligible to report a concern? A breach is generally defined as any kind of information or activity within the Company and its affiliates that is deemed illegal, unethical, or not in compliance with any internal rules (policies, procedures, corporate governance rules) and/or external rules and laws and regulations applicable to the business of the Company and its affiliates. Based on Article 4 of the EU Directive 2019/1937, the concept of reporting person is extended for the purpose of this policy and therefore should apply to all who acquire information on breaches in a work-related context, which includes the persons listed: • All Staff Members; • Persons having self-employed status; • Shareholders and persons belonging to the administrative, management or supervisory body of an undertaking, including non-executive members, as well as volunteers and paid or unpaid trainees; • Any persons working under the supervision and direction of contractors, subcontractors and suppliers.* What can be reported? Information concerning the following matters may be reported (non-exhaustive list): • Corporate governance breaches ; • Fraud and misconduct in respect of accounting, internal accounting controls ; • Auditing matters; • Protection of privacy and personal data, and security of network and information systems; • Bribery and financial crime including fraud, theft, abuse of data and compliance; • Financial services, products and markets, and prevention of money laundering and terrorist financing; • Breaches relating to the functioning of the European internal market, as referred to in Article 26(2) TFEU (Treaty on the Functioning of the European Union), including breaches of Union competition and State aid rules, as well as breaches relating to the internal market in relation to acts which breach the rules of corporate tax or to arrangements the purpose of which is to obtain a tax advantage that defeats the object or purpose of the applicable corporate tax law; • Breaches of internal rules and laws/regulations applicable. 2. Internal reporting channel and external reporting channel via the Commissariat aux Assurances (CAA), and the setting of conditions of sanctions to be imposed Reporting through internal channel (Moral Maps) In order to make our internal channel complying with the above measures, it will remain available for staff members through the intranet, and it is extended to all eligible persons via our webpage link. Under these terms, all eligible persons in a work-related context with LIA will have access to our internal channel and be able to report a concern anonymously. The whistleblower can always submit the escalation directly to the Chief Compliance Officer and Head of Regulatory Compliance by writing a letter to Lombard International Assurance S.A. 4 Rue Lou Hemmer, 1748 Findel Niederanven. Reporting through external channel In addition, the EU Directive 2018/843 (the “5th AML Directive”) in accordance with the EU Whistleblowing Directive 2019/1937 establishes that whistleblowing alerts may be reported independently to the Commissariat aux Assurances (CAA) for any breaches to the applicable Luxembourg laws and regulations. As for the CAA website, instructions on how to report via hotline or proper form are described in details. on the link https://www.caa.lu/fr/whistleblowing. In conclusion, it is recommended for all eligible reporting person to first use our internal alert procedure via Moral Maps before contacting the CAA for external report. 3. Sanctions for non-compliance with the legal protection of the reporting person The 5th AML Directive states that whether the reporting person is exposed to threats, retaliatory or hostile action, and in particular from adverse or discriminatory employment actions, sanctions can be imposed in the form of a fine ranged between €250 and €250,000 by supervisory authorities (CAA or other competent authorities) to the Company, its Board members, its effective directors and any other person within the company responsible for the non-compliance action.
*In line with the provisions of Article 5(4), subparagraph 3, and Article 8-3(3) of Luxembourg Law of 12 November 2004 on the fight against money laundering and the financing of terrorism.
Complaints management Policy
1. INTRODUCTION 1.1 Purpose/background of the Policy On 14 June 2012, the European Insurance and Occupational Pensions Authority (EIOPA) issued “Guidelines on Complaints-Handling by Insurance Undertaking” which require that a “Complaints management policy” is put in place by insurance undertakings. On 21 December 2012, the Luxembourg insurance regulator, the Commissariat aux Assurances (CAA), has informed EIOPA it would fully apply these guidelines and has thus issued the Circular Letter 14/1. According to this Circular Letter, the EIOPA guidelines are to be considered as minimum standards for complaints handling. On 26 February 2019, the CAA issued a regulation n° 19/03 relating to out of court complaint resolution (the 2019 Regulation) This complaints management policy (the Policy) sets out how Complaints are managed by the Company. This Policy is designed to address the risk of inadequately responding to Complaints. The impact of non-compliance may result in: • Regulatory sanction; • Litigation; • Reputational impact; • Financial loss. For the purposes of this Policy, the words and expressions set out below shall have the following meanings: “Complainant” means a person who is presumed to be eligible to have a Complaint considered by an insurance undertaking and has already lodged a Complaint e.g. a policyholder, insured person, beneficiary and, in some jurisdictions, injured third party. “Company” means Lombard International Assurance S.A. including its branches. “Complaint” means a written dissatisfaction addressed to the Company on a dysfunction of the latter which is not resolved by the agreement of both Complainant and the Company no later than the first working day following the receipt of the Complaint. Specifically, a dysfunction relates either to: • The Company’s overall organization; • The life insurance contract; or • The insurance service the Company has provided or failed to provide. Therefore, the following is not regarded as a Complaint: • The simple request for execution of the contract; • The request of the provision of the service; • The simple requests for information or clarification; • The grief resolved no later than the first working day following its receipt, provided that the Company's proposed solution has been accepted by the Complainant; and • The Complaint received by the Company concerning activities other than those regulated activities or activities related to another entity for which it has no competence. 1.2 Administration of the Policy As per the Lombard International Assurance Group Policy Framework, the Risk Oversight Committee (ROC) has the final authority to approve this Policy. The Chief Operating Officer is responsible of the Complaints-handling for the Company and has delegated the Complaint management process to the Partner & Client Services and to the Legal Departments. Consequently, the ROC delegates the responsibility to design, review and propose amendments to this Policy to the Partner & Client Services and to the Legal Departments. This corporate Policy will be reviewed annually or when major changes occur. The Partner & Client Services and the Legal Departments have communicated this Complaints management Policy appropriately and effectively and made it easily accessible to all relevant functions and departments. This Policy is published on the intranet of the Company and is accessible on demand to all clients. 2. POLICY STATEMENT 2.1 Basic principles The basic principles that are appropriate to the Company are the following: • Visibility and accessibility; • Fairness and objectivity / customer-focused approach; • A single point of contact for all Complaints; • Rigorous standards for response and resolution; • Accountability; • Continuous improvement. 2.2 Process for Complainant 2.2.1 A single point of contact for all Complaints – Partner & Client Services Department (PCS) A Complaint may be addressed to the Company in writing. In order to facilitate the interaction between the Complainant and the Company, any Complaint can be addressed to and will be managed by the relevant PCS desk and shall contain at least the following information: • Name, first name, address and details of the Complainant; • Quality of the Complainant (policyholder, life assured, beneficiary, partner, …); • Policy number (where applicable); • Clear and detailed description of the Complaint. Complaints can also be forwarded to the Company by the intermediary of the Complainant. By their nature, some Complaints are likely to be difficult to resolve and may require a technical legal approach. For these Complaints, PCS may ask the support of the Legal Department (Legal). 2.2.2 Complaints received at the Italian branch of the Company (the Italian Branch) The Company (i) has established a working function aimed at assuring that Complaints received at the Italian Branch are investigated fairly and in compliance with the applicable law and regulation (the Function); and (ii) has appointed a senior manager responsible with overall regulatory responsibility for the Function and relevant process (Complaints Officer). The Function will operate in compliance with the applicable provisions of the IVASS regulation n. 24 of May 2008 (Regulation 24), as amended by IVASS regulations n. 30 of March 2015 and n. 46 of May 2016. The Complaints Officer will provide any information on Complaints and Complaints handling to IVASS and will be in charge should any problem arise in the management of Complaints received at the Italian Branch. In case of Complaints directly submitted to IVASS, the latter may require for the Company to provide clarification directly to the complainant. In this scenario, the Complaints Officer shall send a copy of its reply to IVASS. The Italian Branch notifies IVASS, within 10 working days from the relevant appointment, about the Function, the name of the Complaints Officer and the relevant contacts. The Company guarantees the independence of judgment of the Function by adequately placing it within the organization and by envisaging appropriate procedures aimed to avoid conflicts of interest with the structures or subjects whose behaviour is the object of the Complaint. Moreover, the Italian Branch: (i) ensures the necessary internal flows of information and reporting lines for Complaints management, as appropriate; and (ii) controls the effective and efficient treatment of Complaints, also considering this Policy. 2.2.3 Complaints received at the Belgian branch of the Company (the Belgian Branch) Any Complaint received by the Belgian Branch will, by default, be handled by the Belgian Branch itself. However, in case of informational and/or technical constraints, the Belgian Branch can request PCS and/or Legal Luxembourg (depending on the nature of the Complaint) to respond to the Belgian Branch that in turn will respond to the Complainant. In addition, it is to be noted that information related to Complaints received at the Belgian Branch should be sent to PCS Luxembourg for logging purposes in the internal logging tool (the “Complaints’ Register”). 2.3 Internal process All Complaints must be acknowledged and answered within agreed corporate service standards and should take the Complainant’s history into account. To this effect, the Company shall adopt an internal procedure. Upon receipt of a Complaint, PCS takes the following actions: • PCS logs the Complaint within the Complaints’ Register. • PCS performs an initial review of the Complaint within 2 working days of receipt. • PCS acknowledges receipt of the Complaint to Complainant within 10 business days of receipt. • A detailed response shall be sent to the Complainant within 30 days from the date of the receipt of the Complaint. • When an answer cannot be provided within 30 days, the Company shall inform the Complainant about the causes of the delay and indicate when the Company’s investigation is likely to be completed. • All Complaints shall be reported to the Senior Management pursuant to internal reporting process. In case of a Complaint received by the Belgian Branch, the above actions (with the exception of the first one) are taken by the Belgian Branch. 2.4 Rights of the Complainant The Complainant has the following rights: • The right to be informed about the complaints management policy; • The right to a fair, swift and comprehensive treatment; • The right to receive updates regarding the progress, if any, in the handling of the Complaint; • The right to be advised in respect of the alternative dispute resolution methods; • The right to be informed regarding the management of conflict of interests. 2.5 Conflict of interests Internal procedures shall be adopted to ensure that conflicts of interests are managed properly and effectively alleviated. 2.6 Escalation 2.6.1 Escalation to senior management When the Complainant has not obtained an answer or a satisfactory answer at the level at which he/she submitted the complaint in the first instance, the Complainant may raise the Complaint up to the Chief Operation Officer - Laurent Muguet. 2.6.2 Escalation to authorities Without prejudice to any court action, in case the answer provided by the Company is not satisfactory to the Complainant, he/she can address the Complaint to the following authorities. Escalation may also be addressed to other authorities in the country of residence of the Complainant. Please refer to the applicable general terms and conditions of your contract for more information. a) Out of court procedure with the CAA The 2019 Regulation creates an out of court procedure allowing Complainant to escalate their Complaint to the CAA (the Procedure). Following to the 2019 Regulation, a request can be submitted to CAA only to the extent: 1. The formal Complaint has been filed in writing with the Company and have not been answered or satisfactorily answered within 90 days. 2. The request is admissible pursuant to article 4 of the 2019 Regulation. 3. The request to CAA is filed in Luxembourgish, German, French or English and does contain the information listed in article 5 (2) of the 2019 Regulation. The CAA may request the production of additional documents or information it deems necessary. It will acknowledge receipt of the request within 10 business days and transfer a copy of the request to the Company which shall take position within 30 days. The CAA shall issue a reasoned conclusion within 90 days once it has received all the information necessary to its analysis. The 90 days period may be extended in case of highly complex cases; in which event the CAA will inform the Complainant and the Company. The Complainant and the Company may be represented or assisted by a third party at any stage of the Procedure. The Procedure is in writing, free of charge and its conclusions are not binding upon the Complainant or the Company. More information on the Procedure can be found on the CAA website: https://www.caa.lu/uploads/documents/files/RCAA_19-03_REL_EN.pdf b) Other remedies • Médiateur en Assurances: c/o Association des Compagnies d’Assurances, 12 rue Erasme, L-1468 Luxembourg-Kirchberg, Grand-Duché de Luxembourg; and/or • Union Luxembourgeoise des Consommateurs (ULC) 55, rue des Bruyères, L-1274 Howald. 2.6.3 Italian policies For any Complaint related to an Italian policy, the Complainant can address the Complaint to the following authorities in case the answer provided by the Company is not satisfactory: • For issues related to the contract, to IVASS (Italian Insurance Authority – Istituto per la Vigilanza sulle Assicurazioni) – Servizio Tutela degli Utenti, Via del Quirinale 21 – 00187 Rome, +39 06 42133745 or fax +39 06 42133353, certified email (PEC) ivass@pec.ivass.it; • For issues related to informative transparency, to CONSOB (Commissione Nazionale per le Società e la Borsa), Via G.B. Martini 3 - 00198 Rome. For resolving cross-border disputes, the Complainant can submit a complaint to IVASS or activate the FIN-NET procedure (by accessing the website http://ec.europa.eu/internal_market/fin-net/members_en.htm). The Complainant may also use alternative dispute resolution methods (ADRs) as set out in the General Terms & Conditions of the policy and enlisted in the Company internet site regarding “Complaints management”, such as: “mediation procedure” (pursuant to Legislative Decree n. 28 March 4, 2010,) and “assisted negotiation procedure” (pursuant to Legislative Decree n. 132 September 12, 2014 turned into Law n. 162/2014). The Complainant is also entitled to contact the Commissariat aux Assurances 7, boulevard Joseph II, L-1840 Luxembourg. All the above is without prejudice to any court action. 2.6.4 Arbitrator for Financial Disputes (only for Policies issued by the Italian branch) In addition to the methods listed aboveand just in case of policies issued by the Italian branch, if the Complainant is not satisfied or has not received a response by the Company within 45 days, she can refer to the Arbitrator for Financial Disputes (ACF). ACF is a system of extrajudicial resolution of disputes between investors and intermediaries on the infringement made by intermediaries of diligence, honesty and transparency duties including cross-border disputes and Regulation (EU) No 524/2013 disputes. ACF does not manage complaints for requests of payment of sums > € 500,000. For further information on how to submit a complaint to ACF and the scope of its competence, please visit the website https://www.acf.consob.it/ or contact Consob or the Italian branch. The right to submit a complaint to ACF cannot be waived by the investor. 2.6.5 Belgian branch For any Complaint related to the Belgian Branch, the Complainant can address the Complaint to the following authorities in case the answer provided by the Belgian Branch is not satisfactory: - Service de l’Ombudsman Assurances, square de Meeûs 35, B-1000 Bruxelles (www.ombudsman.as; tél: +32(2) 547 58 71, fax: +32(2) 547 59 75); - Financial Services and Markets Authority (FSMA), Rue du Congrès 12-14, B-1000 Bruxelles, Belgique; - Commissariat aux Assurances 7, boulevard Joseph II, L-1840 Luxembourg; and this without prejudice to any court action. 2.6.6 Portuguese market If the Company’s internal complaints procedure is concluded and the issue has not been solved in a satisfactory manner for the Complainant, either for not agreeing with the outcome of the reply or as a result of the failure by the Company to reply within the applicable deadline, the Complainant may file its Complaint to the Company’s Ombudsman. The internal regulation applicable to the Company’s Ombudsman function can be found in the appendix I of this Complaints management policy. The Complainant may also file a Complaint to the following entities, without prejudice to recourse to the judicial courts: Autoridade de Supervisão de Seguros e Fundos de Pensões, at Avenida da República, 76, 1600-205 Lisboa; or Portuguese Securities and Exchange Market Commission (Comissão do Mercado de Valores Mobiliários), at Rua Laura Alves, n.º 4, 1050-138 Lisboa.
