1
Q
What is the Ethics Decision Tree?
A
A framework that provides guidence to RICS members when they are faced with ethical dilemmas. Questions asked include:
Is it Legal?
Is it in line with the Rules of Conduct?
Have you consulted with appropriate people to make an informed decision?
RICS regulated Confidential Hotline offers assistance to members.
2
Q
Rules of Conduct
A
- Honesty and integrity – Members and firms must be honest and act with integrity and comply with professional obligations, including obligations to RICS.
- Competence – members and firms must maintain their professional competence and ensure that services are provided by competent individuals who have the necessary expertise
- Good quality and diligent service – Members and firms must provide good-quality and diligent service.
- Respect – Members and firms must treat others with respect and encourage diversity and inclusion.
- Act in public best interest and take responsibility – Members and firms must act in publics interest, take responsibility for their actions and act to prevent harm and public confidence in their profession.
3
Q
Mandatory Obligations of firms and members.
A
- RICS members must:
1. Comply with CPD requirements
2. Cooperate with RICS
3. Promptly provide information reasonably requested by the Standards and Regulation Board - RICS-regulated firms must:
1. Publish a CHP
2. Ensure previous and current work is covered by PII.
3. If having a sole principal, make appropriate arrangements for their professional work to continue in the event of incapacity, death, absence from or inability to work.
4. Coorperate with RICS
5. Promptly provide information reasonably requested by the Standards and Regulation Board
6. Display on business literature a designation to denote that they are regulated by the RICS.
7. Report to RICS any matter that they are required to report under the Rules for the Registration of Firms.
4
Q
Fee negotiations
A
- Firms should avoid price fixing, aggressive fee cutting or collusion with competitors.
- Fees should be market bases and agreed on ad-hoc basis
- Healthy competition is encouraged but aggressive fee cutting not allowed
- You can enter into further fee negotiations after you have submitted your initial fee proposal.
- In deciding upon a fee, you should consider the amount of time and resources required and that you have appropriate expertise.
- You can vary level of service depending on fee quote but be aware you still have to provide a high standard of service
- Should not undercut another firm
- Be transparent so they understand that you may be in receipt of, or offering, a referral fee and state in ToE if applicable.
- Granting and accepting referral fees should be considered in the context of bribery.
5
Q
Terms of Engagement
A
- Must state in writing client’s agreement to the proposed fee basis, payment of expenses, and the firms CHP.
- 3 key steps:
1. Check professionally competent
2. No conflict of interest or personal interests
3. Confirm terms of engagement in writing and get written approval from the client before you start work.
6
Q
What is a Conflict of Interest
A
When a member of firm’s independence is impartially threatened due to the existence of a conflict between two clients
7
Q
Conflict avoidance v conflict management
A
o Conflict avoidance is when you do not accept the instruction
o Conflict management is when the instruction is accepted, and steps are agreed to and put in place to manage the conflict, such as information/ethical barrier, with the written agreement of all parties.
8
Q
What is the RICS publication of Conflict of Interest?
A
- RICS Global Professional Standard: Conflict of Interest, 2017
o Mandatory
o Members cannot advise a client if there is a risk or risk of a conflict of interest unless all those affected provide informed consent.
o Informed consent may only be sought where the RICS member of regulated firm is satisfied that proceeding despite a conflict of interest is in the interests of all those who may be affected and it is not prohibited by law (RICS, 2017)
9
Q
3 types of conflict of interest
A
o Party conflict – work on the same or related instruction for two different parties
o Own interest conflict – personal interest
o Confidential information conflict – work relating between two parties that is confidential.
10
Q
Explain informed consent
A
o Can only be given in writing by the party if the person explaining the position to them is entirely transparent about any material factors and are sure that the party affected understands what they are doing.
o Surveyors should only seek informed consent if satisfied that all relevant parties are best served by doing so.
11
Q
How to handle a conflict of interest
A
- Transparency and openness
1. Conflict avoidance
o Consider whether the conflict is irresolvable because your impartiality is compromised and should be avoided or whether it can be properly managed.
o Decide whether to accept of decline
2. Written advice to both parties
o If you accept, set out in writing covering three points:
1. Disclose the nature of the conflict, the circumstances surrounding it and any other relevant facts and set out your proposals for dealing with the conflict
2. Be as clear as possible – ensure both parties make their own decision and inform them to seek independent advice is needed
3. Request written confirmation from both clients of their informed consent.
3. Conflict management
o Once received written confirmation, set up barriers in accordance with agreements with clients
12
Q
Explain the use of information/ethical barriers
A
- Barriers must be robust enough to offer no chance of information passing between the two parties.
- Must take reasonable steps to operate an effective barrier.
- Surveyors acting on each side must be different and physically separated.
- All information regarding the instruction should be securely stored.
- Keep a clear audit trail of the conflict check process and all written and oral communication.
13
Q
What is a personal interest/own interest conflict?
A
- Arises when acting for a family member, a close business associate or someone with whom you have a financial or personal interest or benefit (aka ‘a connected person’)
- You must not let a personal interest interfere with your professional judgement. Full transparency required.
- Declare facts promptly and in writing before you accept the instruction.
- Section 21 of Estate Agents Act 1979 declaration required for agency work.
14
Q
Confidentiality
A
- RICS Bye laws – ‘client confidentiality must be maintained for all client affairs’ and this includes historic information and information provided prior to instruction.
- Client approval must be sought if a 3rd party wants access to your files unless you are subject to statutory duty overriding the client’s confidentiality, such as police or HMRC investigation.
- Old files should be held for a minimum of 6 years.
- If a surveyor finds out confidential information, then this cannot be used for their own purposes. The client should be advised of the error and a note should be recorded to the firm’s compliance officer.
15
Q
What are the 4 CPD requirements
A
- Members must do 20 hours CPD in a calendar year
- Of the 20 hours, 10 hours must be formal.
- Members must maintain a relevant understanding of the RICS Rules of Conduct during a rolling 3-year period
- CPD must be recorded using CPD Management System available online by 31st January each year.
16
Q
Talk to me about negligence
A
- Duty of care exists to clients and third parties, using a ‘reasonable care and skill’. When breached, and there is a loss, a claim for damages arises.
- Limitation Act 1980, Current limitation periods for negligence are:
o Contract – 6 years from the date of the negligent act, breach of contract or omission. (Also section 14a provides an alternative period of 3 years from the date of acknowledgement of the damage subject to 15 years long stop from the negligent act or omission.
o Tort – 6 years from the date the claimant suffered the loss. - Avoidance of negligence – Claims may be avoided or reduced by undertaking actions to include:
o Clearly understand the client’s objectives and confirm the precise instructions in the ToE
o Ensure competence
o Undertake work in accordance with RICS advice
o Make detailed file notes and take photographs
o Keep up to date with market knowledge and undertake CPD
o Cap professional liability excess on your PII policy in ToE.
17
Q
Professional Indemnity Insurance
A
- Mandatory
- To protect clients, surveyors and third parties against negligence where there is a duty of care breached and a claim for damages arises.
- All members must ensure they have an adequate and appropriate level of insurance in place for each instruction having potential liabilities.
- All policies must be unwritten by an RICS approved insurer.
18
Q
What are the current PII requirements for a firm’s minimum limit of indemnity.
A
Firm’s turnover in the preceding year Minimum limit of indemnity
£100,000 or less = £250,000
£100,001 to £200,000 = £500,000
£200,001 and above = £1,000,000
19
Q
What are the current PII requirements when considering a firm’s maximum uninsured excess
A
Turnover up to £10m - The greater of 2.5% of the sum insured or £10,000
Over £10m - No set limit
20
Q
RICS Professional Standard: Client Money Handling, 2019
A
- 6 main areas set out in RICS Professional Standard: Client Money Handling, 2019:
1. Holding client money
2. Providing information to clients
3. Receipts of client money
4. Payments from client accounts
5. Accounting records and controls
6. Compliance
21
Q
What are the procedures for handling client’s money
A
o Client accounts must be kept separate and clearly identifiable
o Word ‘client’ is on the bank account and cheque book
o Client must be made available on demand
o Payment of interest agreed with a client and accounts must be kept in credit
o Regular bank reconciliation checking that payments received are transferred to the bank account and expenditure records are checked at least monthly.
o Accurate records are kept with a running balance available
o Annual audit and reporting obligations by certified accountant employed by the RICS are met
o Money can only be withdrawn from a client account if properly required.
o If cash receipts are made to settle transactions, make sure your records show all cash transactions.
o Signatories must be agreed with authorised staff and two signatories should be required.
o A discrete account is for a single named client account only
o All firms handling client money need to display their procedures documents on their website.
22
Q
Starting a new practice under RICS compliance
A
o Inform RICS by completing a Firm Details Form
o Appoint a Responsible Principal
o Register with RICS for regulation of the firm
o Arrange PII and send details to RICS
o Set up procedures for client money handling
o Register for the RICS Valuer Registration Scheme (VRS) if undertaking Red Book valuation work
o Obtain RICS approval for CHP.
o Set up a complaints log
o Appoint a Complaints Handling Officer (or select a surveyor in another practice if sole practitioner)
o Use a logo kit from the RICS for all practice material to comply with the designation ‘Regulated by RICS’
o Plan for succession/future running of business if a sole practitioner.
o Ensure CPD logged online and set up staff training plan
o Ensure completion of an online RICS Annual Return
23
Q
Starting a new firm statutory compliance includes
A
o Requirement to disclose business name
o Disability discrimination compliance (Equality Act 2010)
o Financial services compliance (Financial Services and Markets Act 2000, Financial Services Act 2012)
o Bribery Act 2010 compliance
o Appoint a Money Laundering Reporting Office (Money Laundering Regulations, 2017, as amended)
o Health and Safety compliance (Health and Safety Act 1974, as amended)
24
Q
What is the key legislation regarding bribery?
A
- Bribery Act 2010
o Hospitality, promotion or other ‘low value’ business expenditure which seeks to genuinely promote and improve the image of a firm is acceptable and a key part of doing business.
o Bribery Act aims to reduce bribery in business
o Bribe can be the giving, offering, promising, or receiving of an advantage such as a payment, gift or a service for an action which is illegal or a breach of trust.
24
Closing a practice
* Inform the RICS of your retirement/closure and deregister
* Ensure clients are informed at the earliest opportunity and hand over arrangements made to a new firm
* Return any monies held for clients to their own accounts
* Inform insurers and procure PII run-off cover for a minimum of 6 years from the expiry of the policy in force at the time of cessation
* Retain a copy of client files and records for a minimum of 6 years.
25
What are the 6 principles of the Bribery Act 2010?
1. Proportionality
2. Top level commitment
3. Risk assessment
4. Due diligence
5. Communication
6. Monitoring and review
26
What are the 4 offences of the Bribery Act and what are the penalties.
1. Bribing
2. Receiving a bribe
3. Bribing a foreign public official
4. Failing to prevent bribery
Penalties: 10 years in prison and/or unlimited fine for individuals. Companies face an unlimited fine.
27
What is money laundering and what is the key legislation?
When proceeds of criminal activities are disguised or converted and then realised as legitimate assets
Terrorism Financing and Transfer of Funds (Information on the Payer) Regulations, 2017 (as amended in 2023)
28
What are the key provisions of Terrorism Financing and Transfer of Funds (Information on the Payer) Regulations, 2017 (as amended in 2023)
1. A requirement to have a written money laundering and terrorist financing risk assessment
2. Implement systems, policies and controls and procedures to address money laundering and terrorist financing risks and meet the requirements under the regulations.
3. Adopt appropriate internal controls
4. Provide staff training
5. Comply with new customer, enhanced, and simplified due diligence requirements
6. Comply with the requirements relating to politically exposed persons (PEPs)
7. Ensure appropriate record keeping, policies and procedures
8. AML checks must be undertaken to confirm the identity of the proposed purchasers of a property and check the purchaser’s source of funds by the vendor’s agent before contracts are exchanged.
9. To include additional high-risk when assessing the need for enhanced due diligence, and seek additional information and monitoring in certain cases, eg where there are transactions between parties based in high-risk third countries.
29
What are Estate Agents' legal obligations relating to money laundering?
* Requires letting agents to register with HMRC within 12 months of May 20 if they let individual properties for more than the equivalent of £10,000/month
* Individuals and businesses need to be approved and remain registered by HMRC in order to trade.
* CDD checks on vendors, purchasers, landlord and tenants will have to be undertaken on new sales and any letting or reletting as above.
* EDD checks needed to be undertaken if red flag occurs.
* Firms must have policies to identify and scrutinise transactions which are:
o Complex or unusually large
o Contain unusual patterns or transactions
o Are without apparent economic or legal purpose
* Firms must have group-wide procedures to share relevant information, and to train anyone capable of identifying or preventing money laundering or terrorist financing risks.
30
Describe some due diligence checks for AML (Customer Due diligence, enhanced due diligence, other key requirements)
1. Customer Due Diligence
o Identify the client and verify their identity based on a reliable independent source (eg passport, driving licence)
o Make reasonable endeavours to identify the beneficial owners of the client (and to verify the identity of the person responsible for managing it if not able to do so in the Persons of Significant Control Register at Companies House)
o For a company, its name, company number and address of the registered office is required.
o Names of the directors required unless the company is listed on a regulated market (such as the London Stock Exchange)
o Obtain information on the purpose and intended nature of the business relationship and proposed funding arrangements.
2. Enhanced Due Diligence (EDD)
o EDD procedures require additional evidence and monitoring.
o Additional procedures required if involving a person established in a ‘high risk third country’ or a ‘politically exposed person’ (PEP) or a PEP family member/business associate.
o PEP = someone who has been entrusted with a prominent public function.
o PEP generally at a higher risk for potential involvement in bribery and corruption by virtue of their position and the influence they may hold
o More detailed examination of the background and purpose of the transaction and increased monitoring.
3. Other key requirements of the regulations include:
o Limit of €10,000 for the acceptance of cash
o On-going business relationship with client should be monitored
o Detailed record keeping of the procedures undertaken is required
o A senior member of staff/board member must be appointed to take responsibility for all compliance
o A nominated person (the Money Laundering Reporting Officer) must be appointed to report any suspicions with a Suspicious Activities Report (SAR) to the National Crime Agency who decide what appropriate steps and actions are required.
o A firm maintain records for a minimum of 5 years and to report to Companies House and discrepancies between the information the firm holds on their customers compared with information held in the Companies House Register.
31
What are the penalties in relation with money laundering?
* Maximum 14 years prison sentence and/or unlimited fine for assisting with money laundering
* Maximum 5 years prison sentence and/or unlimited fine for tipping off a person by informing them that they are under suspicion for money laundering or for failing to report suspicion.
32
Red flags of money laundering.
* Inability or unwillingness of parties to provide identity documents
* Changes to parties involved in transactions
* Unusual transaction features, such as unexpected urgency required by parties, potential loss making or an unusual transaction for a client.
* Payment of fees, purchase or rental monies in unusual currencies.
33
Other relevant legislation relating to Anti-money Laundering Act
Sanctions and anti-money laundering act, 2018
* Wider sanctions in light of geopolitical activities such as the Ukraine conflict
* HM Treasury’s Office of Financial Sanctions Implementation (OFSI) provides regular updated guidance in relation to financial sanctions against countries, companies and individuals.
* RICS Anti-money laundering sanctions update, 2022, which provides a reminder about sanctions and estate agents’ role in enforcing these issues including:
o Consider the risks to a business as part of your AML procedure, noting that the sanctions lists include UK citizens and people who live in the UK.
o Understand risk factors and people who live in the UK
o Understanding risk factors and red flags
o Using software as part of due diligence if a firm is likely to engage with higher risk clients or assets
o Checking individual clients of a higher risk against the HM Treasury’s ‘consolidated lists’
o Checking existing clients regularly where they present a higher risk, eg by subscribing to HM Treasury’s Sanctions Notices
o What to do if your client is a possible match on the sanctions list, including contacting the Office of Financial Sanctions Implementation (OFSI) for assistance.
Proceeds of Crime Act 2002
* Provides powers for enforcement authorities in the UK to recover in criminal and civil proceedings money and other assets deemed to be proceeds of crime
* Creates a set of criminal offences intended to combat money laundering (AML offences)
* 3 mains areas of offence:
1. Concealing criminal property: if a person conceals, disguises, converts or transfers criminal property
2. Arrangements: if a person enters into or becomes concerned in an arrangement which they know or suspect facilities the acquisition, retention, use or control or criminal property by or on behalf of another person.
3. Acquisition use and possession: if a person acquires, uses or has possession of criminal property.
Economic Crime (Transparency & Enforcement) Act 2022
* Measure for a beneficial ownership register of overseas entities owning property in the UK
* Strengthens the investigation powers regarding unexplained wealth orders (UWOs)
* Allows easier prosecution of those involved in sanctions-busting inability or unwillingness of parties to provide identity documents.
34
What is the RICS professional standard for bribery, corruption, money laundering and terrorist financings?
RICS Professional Standard: Countering bribery, corruption, money laundering and terrorist financing, 2019
* Sets out the mandatory, globally applicable requirements for RICS members and firms
* Divided into 3 parts (with a glossary at the end):
1. Bribery and corruption (B&C) – Mandatory requirements. RICS regulated firms must:
o Not offer or accept anything that could constitute a bribe
o Have procedures in place to comply with the law
o Report suspicion to the relevant authority
o Act with due diligence to perform periodic written evaluations or the risks the firm faces.
o Retrain records to show how the firm has met the requirements of the professional statement.
Money laundering and terrorist financing (ML & TF). RICS regulated firms must:
o Not facilitate or be complicit in ML and TF
o Have systems in place to comply with the laws
o Report suspicion
o Evaluate and review the risks presented to the firm
o Use 3rd party reliance for checks only where there is a level of confidence for the quality of the information provided
o Take appropriate measures to understand the client and purpose of the instruction
o Verify the client by undertaking basic ID checks
o Retain records to show how the firm has met the requirements of the Professional Statement.
2. Guidance - Practical guidance is provided:
o Have a written policy in place for, and senior management to take control of, the procedures
o Publish a code of behaviour for staff and provide staff training
o Encourage transparency
o Set up a gifts register
o Keep up to date with the legislation
3. Supplementary guidance.
o Establishing a ‘risks-based approach’: Consider the three ‘Ws’ when assessing risks to your business: who you act for, what are you doing, why are you being asked to do something.
o Dealing with PEPs requires enhanced checks as they are hold positions of influence and are higher risk.
o Need to identify the beneficial owner of a company, partnership or trust – such as by requesting a recent Certificate or Incorporation or Annual Return for a company.
35
What is the RICS Professional Standard in Relation to bribery, corruption, money laundering, 2019
Countering Bribery, Corruption, Money Laundering, and terrorist financing, 2019.
Sets out the mandatory, globally applicable requirements for RICS members and registered firms.
3 parts:
Mandatory requirements
Guidance setting out supporting good practice above
Supplementary guidance notes set out in parts 1 & 2.
36
In the RICS Professional Standard: Countering Bribery, corruption, money laundering and terrorist financing, 2019. What is included in Part 1?
Part 1 - Mandatory requirements.
Bribery and Corruption - Firms must:
- Not offer or accept anything that could constitute a bribe
- Have procedures in place to comply with the law
- Report suspicions to the relevant authority
- Act with due diligence to perform periodic written evaluations of the risks the firm faces
- Retain records to show how the firm has met requirements.
Money Laundering and Terrorist Financing (ML & TF) - RICS regulated firms must:
- Not facilitate or be complicit in ML and TF
- Have systems in place to comply with the laws
- Report suspicion
- Evaluate and review the risks presented to the firm
- Use third party reliance for checks only where there is a level of confidence for the quality of information provided by the third party.
- Take
37
What is dual agency?
Where an agent has a contractual agency relationship with the buyer and seller at the same time.
From 1st January 2018 if must not be done under any circumstances.
38
What is a multiple introduction?
Where an agent has competing contractual relationships simultaneously with several buyers for commercial real estate opportunities.
Agent can. When a client appoints an agent, ToE must be agreed highlighting if on an exclusive or non-exclusive basis.
Exclusive = others prospective buyers must be informed the agent is no longer able to advise them.
Non-exclusive basis = agent must obtain informed consent from the clients subject to necessary barriers in place.
39
What is incremental advice?
When an agent is approached by another party, for a valuation for instance, relating to a purchase or disposal that is incremental to existing instruction.
Eg - When an agent is acting for a seller in a disposal and is approached by the buyer, or lender, to provide a valuation.
RICS members can only provide incremental advice if informed consent is given and information barrier is put in place.
40
Types of conflict of interest
Party conflict of interest
Personal conflict of interest
Confidential information conflict of interest
41
What should be included in ToE?
Competence
Independence
Fee Basis
Payment of expenses
Firms CHP
Should be confirmed in writing and get written approval from the client before starting on an instruction.
42
When can a disciplinary procedure be triggered?
Someone complaining to RICS
Allegation by a client or 3rd party
Information received or established by RICS.
43
What are the 3 levels of disciplinary action?
1. Action by Head of Regulation
2. Disciplinary Panel
3. Appeal Panel
44
Explain what happens when action is taken by Head of Regulation?
Initial investigation stage
- by Head of Regulation
- Head can initiate one of 4 actions:
1. Serve a Fixed penalty notice - Procedures used for breaches of the Rules relating to supply of information to RICS by firms and members.
2. Make a regulatory compliance order - Low level breaches which can be easily corrected. Written document which states terms member of firm must take or desist from. Could be for not undertaking CPD.
3. Refer the matter to a single member of the Regulatory Tribunal for consideration
4. Refer the matter directly to a Disciplinary Panel
45
Action by a disciplinary panel
Used for more serious breaches
Head of Regulation can consider that a hearing is required under the discipline rulers.
Membership can include non RICS members
Penalties include:
1-Issue a regulator compliance order
2 - reprimand
3 - fine
4 - impose an unlimited amount of fine per breach but it must be proportionate to the offence.
5 -impose conditions upon future continued RICS registration
6 - Expulsion
7 - Require results of hearing to be in RICS modus magazine, on RICS website and in local newspaper where the firm is based.
46
What are the penalties available to the Regulatory Tribunal Disciplinary Panel?
1 Issue a Regulatory Compliance Order
2 Reprimand
3 Fine
4 Impose an unlimited fine per breach but it must be proportionate to the offence
5 Impose conditions upon future continued RICS registration
6 Expulsion
7 Require publication of the results in RICS modus magazine, on the RICS website and in local newspaper
47
What is the appeal panel and what can they do?
Includes non-RICS members.
Can consider an appeal against review of a decision relating to a disciplinary procedure.
Will review decision made having regard to evidence previously presented and any new representations.
Can Appeal Panel and can allow the appeal and vary the penalty previously imposed.
48
What act outlines the limitation periods for negligence?
Limitation Act 1980
Contract - 6 years from the date of the negligent act, breach of contract or omission.
Also s14a provides alternative limitation period of 3 years from the date of knowledge of of the damage subject to the 15 years long stop from the negligent act or omisson.
Tort - 6 years from the date the claimant suffered the loss.
49
What is meant by the idea that PII policies work on a 'claims made' basis
Policies should be retroactive and policies cover claims that are made during the period of insurance regardless of when the negligence occurred.
50
What document contains information on liabilities for valuations?
RICS Practice Information: Risk, Liability and Insurance, 2021:
RICS recommends the use of liability caps to manage risks associated with professional work.
Advice can only be relied upon by the client name in the ToE.
CBRE Maximum agreed liability to client shall not exceed the lower of 25% of the value of a single property or 25% of aggregated value or £20,000,000.
51
Describe the key provisions of the Sanctions and Anti-Money Laundering Act, 2018
Wider sanctions have been issued in light of geopolitical activities.
HM Treasury's Office of Finanical Sanctions Implementation (OFSI) provides regularly updated guidance regarding sanctions against countries, companies and individuals.
RICS provides guidance in RICS Anti-money laundering sanction update, 2022. Provides a reminder about sanctions and estate agents role:
Consider risks to businesses as part of AML procedure, noting sanctions list include UK citizens.
Understanding risk factors and red flags
Check individual clients of a higher risk against HM Treasury's 'consolidated list'
Check existing clients regularly where they present a higher risk.
52
What is a bribe?
The act of promising, giving, receiving, or agreeing to receive money or some other item of value with the aim of receiving preferential treatment.
53
What is a premium and why is it different to a bribe?
Premium is a capital payment made by one part to another.
Different to a bribe as it is part of the transaction, it is in the open air, transparent. Can also be alongside equipment such a kitchen equipment.
54
What RICS document sets out requirements for PII? And aside from thresholds, what are some of the requirements.
UK professional indemnity insurance requirements 2022
- An 'each and every' claim basis or aggregate plus unlimited round the clock basis
- PII must be fully retroactive (Retroactive - can take affect from a date in the past).
- PII policies work on a 'claims made' basis. This means the policy covers claims that are first made against the insured during the period of insurance no matter when the negligent act occurred.
- Underwritten by an RICS listed insurer.
- Covers all past and present employees.
