Conner Strong & Buckelew, is a licensed insurance producer in all fifty states. We engage in the business of insurance under the principal trade name of “Conner Strong Companies” where permitted by applicable state laws. Conner Strong Companies also operates under alternative trade names as approved by the appropriate jurisdiction. Alternative trade names include Conner Strong and in the state of California, Conner Strong Insurance Brokerage Services. We do not transact business, or knowingly disseminate marketing materials under any trade name that has not been previously approved by the appropriate state jurisdiction.
Policy on Political Contributions
Adopted by Board of Directors on May 15, 2008
Conner Strong & Buckelew is licensed to do business in all 50 states and is regulated by various departments of insurance and other authorities in those jurisdictions in which it conducts business.
Political contributions of all types are also subject to extensive governmental regulation and public disclosure requirements. Conner Strong & Buckelew is fully committed to complying with all applicable laws and regulations. To avoid any confusion and to assure that Conner Strong & Buckelew operates in a manner consistent with all applicable laws, Conner Strong has adopted this policy.
Under the laws of many jurisdictions, Conner Strong & Buckelew is legally prohibited from making political contributions as a business entity and may be otherwise disqualified by law from receiving the award of certain public contracts should certain political contributions be made.
Policy on Entertainment of Public and Union Officials
Adopted by Board of Directors on May 15, 2008
Under the laws of many jurisdictions, Public Officials and Union Officials are legally prohibited from soliciting or accepting gifts, meals or anything of value. When dealing with Public Officials and Union Officials, Conner Strong & Buckelew and its employees must avoid any activity that is illegal or unethical or gives the appearance of being such. Therefore, the giving of anything of value, including travel or entertainment, directly or indirectly, to Public Officials or Union Officials is prohibited.
For purposes of this policy, a “Public Official” is any individual holding any federal, state, multi-state, county, municipal office or school board, whether by election, appointment or by virtue of employment and a “Union Official” is any individual holding an elected or appointed leadership position in a labor organization, which includes any organization which exists for the purpose of dealing with employers concerning grievances, labor disputes, wages, rates of pay, hours of employment or conditions of work.
Conner Strong & Buckelew and its employees shall not provide, either with Conner Strong & Buckelew funds or personal funds, meals, entertainment (including tickets to sporting events), travel, gifts or anything of value to any Union Official or Public Official, except as follows:
Code of Business Conduct and Ethics
Adopted by Board of Directors on July 17, 2008
This Code of Business Conduct and Ethics (“Code”) applies to Conner Strong & Buckelew Companies, Inc. (“Company”). The Company has adopted this Code to help all Company employees behave in a way that promotes the integrity of the Company and maintains the trust and confidence of its clients. The Company expects all directors, employees, officers (“employees”) and business associates to use sound judgment to help the Company carry out the Company’s business with honesty and high ethical standards and in compliance with all applicable laws. Each employee and business associate is expected to demonstrate personal commitment to the standards set forth in this Code.
Any questions about this Code or the appropriate course of conduct in a particular situation should be directed to the Company’s General Counsel. Any evidence of improper conduct, violation of laws, rules, regulations or this Code should be reported immediately in accordance with the procedures set forth herein. The Company will not allow retaliation against an individual for such a report made in good faith.
I. Compliance with Laws, Rules and Regulations
All employees, officers and business associates must respect and obey all laws, rules and regulations applicable to the Company’s business, including state and local laws in all geographic areas in which the Company operates.
II. Commitment to Equal Opportunity and Treatment of Employees
The Company is an equal opportunity employer. The Company grants equal employment opportunities to all qualified individuals without regard to race, sex, sexual orientation, religion, age, national origin, creed, marital status, physical or mental disability, or veteran’s status. The Company does not tolerate discrimination and harassment, including sexual harassment, in the workplace or in other business related or company sponsored settings. The Company’s position on providing a comfortable work environment extends to the conduct of students, vendors, contractors, visitors, customers, and other persons who enter the Company’s property.
III. Political Contributions
Political contributions of all types are subject to extensive governmental regulation and public disclosure requirements. The Company is fully committed to complying with all applicable laws and regulations. To avoid any confusion and to assure that the Company operates in a manner consistent with all applicable laws, the Company adopted a policy on Political Contributions, which is posted on our website.
IV. Entertainment of Public and Union Officials
Providing meals, entertainment or gifts to Public and Union Officials are subject to extensive governmental regulation and public disclosure requirements. The Company is fully committed to complying with all applicable laws and regulations. To avoid any confusion and to assure that the Company operates in a manner consistent with all applicable laws, the Company adopted a policy on Entertainment of Public and Union Officials, which is posted on our website.
V. Conflicts of Interest
Conflicts of interest arise when an employee’s personal interests influence business decisions. Employees shall avoid situations where personal interests may conflict with the best interest of the Company or the client.
The Company believes that business decisions by its customers should be made solely on the basis of the Company’s quality, service, price and other competitive factors. Gifts and entertainment of nominal value are used to create good will with customers, vendors and service providers. If they go beyond that and make the customer, vendor or service provider feel obligated to offer any special consideration to the Company, they are unacceptable. Therefore, employees and business associates should exercise good judgment and moderation and should only offer gratuities to customers to the extent they are in accordance with local laws and reasonable business practices in the marketplace.
VI. Fiduciary Obligations to Clients
As an insurance broker, we act at all times in a fiduciary capacity to the client. In this regard, our placement decisions must be guided by our fiduciary obligations. This means that, in the course of representing our clients’ interests we must: (1) have the degree of skill and knowledge requisite to the calling; (2) exercise good faith and reasonable skill, care and diligence in the execution of our duties; and (3) possess reasonable knowledge of the types of policies, their different terms, and the coverage available.
Our guiding principle is to consider our client’s best interests in all placements above all else. We are our clients’ advocate and represent clients in our negotiations. We must work closely with clients on the design of their risk transfer program to address the complexity of decisions that have to be taken into account, such as the insurer’s financial strength, expertise in the line of coverage needed, its claims-paying history, clients’ service requirements, breadth of coverage, pricing, and other terms and conditions.
We must not engage in any unfair method of competition or unfair and deceptive acts or practices in the conduct of our insurance business. This would include, among other things “bid-rigging,” the submission of a fraudulent bid to the client, or the making of any materially false or untrue statement to a client for the purpose of inducing that client to place its business with a particular insurer. The most important objective in placing business with a particular insurer is the best interests of the client, price and other factors considered. In making a placement recommendation, consideration of the potential profit to the Company, including the potential for a bonus, incentive or contingent commission, when to the detriment of the client, is strictly prohibited.
Employees should maintain the confidentiality of confidential information entrusted to them by the Company or its customers and suppliers, except when disclosure is authorized or legally mandated. “Confidential information” includes all non-public information that might be of use to competitors, or harmful to the Company or its customers or suppliers, if disclosed. This obligation to protect confidential information does not cease when an employee leaves the Company.
VIII. Protection and Proper Use of the Company’s Assets
All employees have a duty to protect the Company’s assets and ensure the assets’ efficient use. Theft, carelessness and waste have a direct impact on the Company’s profitability and financial health. The Company’s assets should be used only for legitimate business purposes and employees and directors should take measures to ensure against their theft, damage or misuse. These assets include intellectual property such as patents, trademarks, trade secrets, business and marketing plans, salary information and any unpublished financial data and reports.
IX. Accuracy of Records and Reporting
The making of false or misleading records or documentation is strictly prohibited. The Company must operate in compliance with all applicable laws and regulations regarding the preservation of records. Records should be retained and destroyed only in accordance with the Company’s document retention practices and procedures.
COMPLIANCE STANDARDS AND PROCEDURES
The Company understands that no code or policy can address every scenario or answer every question. To ensure that all employees and business associates can obtain prompt answers to their questions and inquiries, the Company has designated the General Counsel as the designated individual for overseeing and monitoring compliance with this code. The General Counsel can be reached at 856-470-5999. Written communications intended to be confidential should be mailed to Conner Strong & Buckelew Companies, Inc., 40 Lake Center Executive Park, 401 Rt. 73 North, Suite 300, P.O. Box 989, Marlton, New Jersey 08053, Attn: General Counsel.
We encourage all employees and business associates to promptly report any violations of this Code or any other laws, rules or regulations to the Company’s General Counsel. The Company does not permit retaliation or discrimination of any kind against employees or business associates who reasonably believe there has been possible illegal or unethical conduct and who in good faith report the conduct to us. However, it is a violation of our policy for any employee to communicate a report claiming illegal or unethical conduct which the employee knows or reasonably should know to be false. Any reported violation will be kept confidential to the extent possible.
The report of an alleged violation of the Code must be factual, rather than speculative or conclusory, and should contain the following specific information to justify the commencement of an investigation:
(i) the alleged event, including the date and location of such event;
(ii) the name of each person involved; and
(iii) any additional relevant information, documentation or other evidence available to support the reported violation.
Reported violations will be promptly investigated. Employees are expected to cooperate fully with any investigation made by the Company or any of its representatives.
Employees who violate this Code may be subject to disciplinary action, up to and including termination of employment. The Company will also terminate any relationship with a business associate if such relationship is in violation of this Code. Knowledge of a violation and failure to promptly report or correct the violation may also subject an employee to disciplinary action.
Statement of Revenue Sources
Conner Strong & Buckelew (“Conner Strong & Buckelew”) is an insurance producer licensed by all 50 states. Insurance producers are authorized by their license to confer with insurance purchasers about the benefits, terms and conditions of insurance contracts; to offer advice concerning the substantive benefits of particular insurance contracts; to sell insurance; and to obtain insurance for purchasers. The role of the producer in any particular transaction typically involves one or more of these activities.
Conner Strong & Buckelew can be compensated in several ways for the services we provide to our clients. Compensation can vary depending on a number of factors, including the terms of the policy, the insurer that issues the policy and such other factors as the volume of business Conner Strong & Buckelew places with an insurer and/o or the profitability of insurance contracts Conner Strong & Buckelew provides to that insurer.
We primarily derive our compensation from insurance companies in the form of commissions on each insurance placement. These commissions are typically paid pursuant to our agreement with the applicable insurance company or insurance intermediary and in alignment with an established commission schedule. In situations where the commissions received are less than our standard compensation, we may receive an agreed-upon placement fee from the client in addition to the commission. In this case, the fee plus the commission received will not exceed our standard rate.
We also derive compensation directly from our clients. This compensation will only be received when it is memorialized in a separate written agreement with the client in which the fee amount is set out in detail and agreed upon.
In some cases, we may receive compensation from insurance companies based on the overall volume and profitability of business that we place with an insurance company. While these agreements may vary from insurance company to insurance company, as matter of corporate policy, Conner Strong & Buckelew expressly prohibits the consideration of compensation in selecting the most suitable insurance company for your needs.
We also earn interest income on premium payments held by us on behalf of clients from the date of our receipt through the date such payments are transferred to the insurance company to the extent permissible by law. When clients elect to pay their premiums using a traditional third party premium finance note, we may receive a portion of the finance charge payable to the premium finance company by the client. In addition, we may also receive promotional or referral fees from other third-party service providers as consideration for our promotion or referral of their goods and services.
Conner Strong & Buckelew and their employees may also receive incentives and rewards, such as trips, prizes and entertainment from insurance companies with which they place business.
Conner Strong & Buckelew believes that its clients have a right to fair and meaningful disclosure regarding our sources of revenue. Clients may request information about compensation expected to be received by Conner Strong & Buckelew based in whole or in part on the sale of insurance to the Client, and (if applicable) compensation Conner Strong would have been eligible to receive based on any alternative quotes presented to the client in connection with the placement of insurance.