Kunden Broker’s success and reputation depend both on the quality of the products and services provided to our customers, as well as on the way we conduct business. Through the continuous increase of performance, the establishment of higher standards and a professional and ethical behaviour, we translate this desire into success.

In accordance with the stipulations given by the Financial Supervisory Authority (ASF) and in line with international law, companies are required to create a compliance function. Compliance is a set of rules, regulations and guidelines, which are a permanent task for institutions or companies and are implemented by a specialized department, under the supervision of a designated Compliance Officer. The compliance department has five responsibilities: identification, prevention, monitoring / detection, resolution, and consulting. The Compliance Officer identifies the risks a company faces and recommends appropriate corrective action; develops and implements controls to protect the company from these risks; monitors compliance and reports on the effectiveness of controls in managing the company’s risk exposure. The department also resolves compliance issues as they arise and provides recommendations on rules and control.

The Kunden Broker Compliance and Ethics Guide emphasizes a common vision of standards and practices for our business. The principles presented in this document guide each of us in our daily work. In accordance with the legislation in force, the Compliance and Ethics Guide summarizes a set of detailed rules, regulations, and procedures, which govern the way in which the company and its staff carry out their professional activity. This set of guidelines and policies provides assurance that all staff and shareholders have a common vision of ethical standards and operate in accordance with those standards. The guide sets the minimum standards that must be respected by all employees and collaborators.

Compliance policy

According to the structure of the compliance management system, compliance risks are identified and evaluated and methods for identifying and resolving non-compliant cases are established. Compliance risk represents the risk of affecting/ damaging the company’s integrity and reputation, by non-compliance with laws, regulations, internal procedures and ethical standards, in the course of the daily professional activity and the behaviour of each individual, applicable to staff working for the company Kunden Broker.

Internal anti-corruption and anti-fraud policy

Violation by employees, collaborators or partners of existing legislation, internal procedures, regulations, circulars, and anti-fraud policies adopted by the company may lead to adverse financial penalties. Employee accountability is an integral part of our business model. Our behaviour and attitude dictate how we are perceived by customers and suppliers both at an individual and at company levels. Kunden Broker is committed to comply with national and international law in terms of combating corruption. The rules and principles mentioned in our legislative framework are valid for everyone: employees, partners, collaborators, suppliers, legal representatives, or people who work for the company. Therefore, Kunden Broker Companie de Brokeraj S.R.L. shows zero tolerance for any act of corruption.

Anti-money laundering procedure

Our company has drawn up an internal procedure to combat money laundering and terrorism financing that is in accordance with the provisions of Law no. 129/2019 on preventing and combating money laundering and terrorism financing, as well as amending and supplementing some normative acts and with Regulation no. 13/2019 on the establishment of measures to prevent and combat money laundering and terrorism financing through the financial sectors supervised by the Financial Supervision Authority. When assessing and managing the risk, the nature of Kunden Broker’s activities were considered, namely insurance distribution – activity materialized in the intermediation of insurance products from collaborating insurance companies – and marketing activity of the private pension fund – materialized in the intermediation of the fund’s private pensions. Considering that in the case of life insurances and in the acts of accession to the private pension fund, no receipts and/ or direct payments are made from/ to customers, these being made directly to/ from insurers, the company presents a reduced risk for money laundering and financing terrorism. Measures have also been taken to ensure that the risk management control systems and procedures, especially those related to the application of the correct level of customer awareness, are effective and proportional.

GDPR security policies and procedures

We have drawn up special policies and we have adopted GDPR security procedures in accordance with the provisions of EU Regulation no. 679/2016, regarding the protection of individuals in the context of the processing of personal data and the free movement of such data. The procedure describes the conditions and the manner of carrying out the activity regarding the security of personal data processing. The procedure applies both within the Company Kunden Broker Companie de Brokeraj S.R.L., hereinafter referred to as “Operator”, and by the natural and/ or legal persons empowered by the “Operator” to process personal data on its behalf.

Procedure for receiving and resolving petitions

Kunden Broker has drawn up the internal procedure establishing the rules and procedures for the registration, administration and storage of petitions, in accordance with the provisions of the Norm of the Financial Supervision Authority no. 18/2017 on the procedure about resolving petitions regarding the activity of insurance and reinsurance companies and insurance brokers. The purpose of the procedure is to regulate the registration and settlement of notifications, petitions and requests received from customers, according to the legal provisions in force, as well as the period of time in which they will be resolved within the company. The procedure contains the basic principles, rules, and terms regarding the responsible and prompt administration of petitions within the company, its provisions being applicable to Kunden Broker employees, brokerage assistants and collaborators. To properly resolve and within the legal term of the petitions addressed to it, Kunden Broker Companie de Brokeraj S.R.L. holds at both headquarters and territorial headquarters, written procedures for receiving and resolving petitions, approved by the executive management.

Information and communication resources security policy

This security policy defines a set of rules, requirements and instructions applicable at the company level, which are the basis of the security infrastructure and set the limits of an acceptable, legal and efficient behaviour in the use of Information and Communication Resources (ICR). Kunden Broker’s security policy aims to ensure the confidentiality, integrity, and availability of information. Confidentiality means protecting data against unauthorized access. Electronic files created, sent, received or stored using our own ICR system, managed or in the custody and control of Kunden Broker are confidential and can be accessed only by authorized company employees, only under the conditions provided by law and established in the company’ Internal Regulations. The user is personally responsible for ensuring the confidentiality of the data entrusted through the ICR access procedures. Integrity refers to the measures and procedures used to protect data against unauthorized alteration or destruction. Availability refers to ensuring the continuous operation of all ICR components. Different applications need different levels of availability depending on the impact or damage caused by the proper malfunction of the ICR.

Procedure for insurance products intermediation

Due to Kunden Broker’s continuous concern, as a Brokerage Company, with the protection of clients’ rights, the necessary steps in the process of conducting insurance distribution are elaborated, with the aim of avoiding operational and conduct risk. In carrying out the activity of distribution of insurance products and voluntary pensions, the company’s management will permanently monitor the distribution process, to avoid the risk of conduct in the relationship with customers. All those involved in the distribution process (brokerage assistants and individual marketing agents) will act in such a way as to ensure fair and equitable treatment of customers and to avoid incorrect, unfair, fraudulent, or abusive practices.

Rules of compliance and ethics

The brokerage assistants/ marketing agents conduct and ethics code

We carry out our activity considering our conduct and ethics code, emphasizing the management of all relationships with fairness, decency, and good intentions. The conduct and ethics code sets clear directions, regarding the way we act and presents details about the professional behaviour that each of us must have. By respecting it, we prove to everyone that we carry out our activity in accordance with the company’s values. Our goals are to achieve operational performance, which places us among the best in the industry, creating lasting value and providing complete and accurate financial information.

Internal Regulations

Social relations with employees are clearly regulated by the compliance and ethical code. Human resource is the most important capital of our company; capable, dedicated, and motivated employees playing a key role in the development and consolidation of the company. Therefore, the company’s management is concerned with the permanent development of employees and ensuring a favourable climate for business, including by promoting the Internal Regulations. Based on the statement regarding the handling of employees’ complaints, they are encouraged to promptly report any practices or actions that they consider to be incompatible with the policies set out in the company’s Compliance and Ethics Guide.

Procedure for the training and development of staff and brokerage assistants

The training and development process of Kunden Broker’s staff as a Brokerage Company is a planned and systematic process that aims to close the gap between the existing and desired level of performance. At the company level, there is a structured training plan for employees/ brokerage assistants/ marketing agents, which will help maintain the requirements of our clients and partners.

The staff training is performed by:

• Integration programs for newly hired staff;
• Training and development programs for the existing staff;
• Training and development programs for promoted or reassigned staff (internal recruitment);
• Training programs for brokerage assistants/ marketing agents.

We want to consistently provide efficient services and tailored solutions to our customers, while meeting the highest standard of professional training.

The mission of the Kunden Broker team, summarized in the slogan “we care for your future”, is to guide those who choose to become our clients or partners to have more confidence in their future. Thus, we build together with them plans for a secure present and a stable future, from a financial point of view. The brand strategy created by Kunden Broker, on which the company’s entire activity is based, is founded on the idea of always respecting the company’s three values: Professionalism, Orientation towards solutions, and Consistency. We have a long-term commitment to conduct our business in accordance with the applicable laws and regulations and in accordance with the highest ethical principles. This commitment helps maintain our reputation in terms of the honesty, quality and integrity that we demonstrate.