Code of Business Practice
(Europe)
VFS Europe Sàrl (‘VFS Europe’), part of the VFS Group, is regulated by the Commissariat aux Assurances (CAA) in Luxembourg as an Independent Insurance Brokerage. The CAA licence number is 2007CM007.
As such VFS Europe is authorised to sell insurance products which are either approved in Luxembourg or which are marketed by Insurance Companies in other EU member states which have given notice under Freedom of Services that they intend to market their products in Luxembourg.
Your personal VFS Europe intermediary is also authorised and licensed by the CAA.
VF Europe, Sucursal en Espana is the Spanish branch of VFS Europe Sarl and is regulated by the Spanish General Directorate for Insurance and Pension Funds (DGS) under Licence No. J-2209.
As independent insurance intermediaries, VFS Europe will act on your behalf to identify the most suitable product or products from a wide range of companies. VFS Europe and its intermediaries obtain full personal details from each client in order that the most appropriate solution is recommended in each case, from the product provider most suited to the client's requirements. More specifically, VFS Europe offers products in the following areas: life assurance, savings, pensions, capital placement and protection. Such products may be guaranteed or unit-linked, and, as a result of the purchasing power of the VFS Group, VFS Europe is often able to offer products at special terms as well as unique branded products incorporating competitive pricing or other advantages.
VFS Europe and its intermediaries are rewarded by commissions paid by the companies providing the products concerned. These take the form of initial commissions and can sometimes include ongoing or trail commission.
This means that the client does not pay for the associated advice, unless specific professional services are involved when the client will be advised in advance that a fee might be payable.
Advice – your intermediary will seek comprehensive information about your personal circumstances in order that he can provide ‘Best Advice’. If you withhold information, it may not be possible to ensure that advice given will be suitable. If you do not wish to provide full details of your circumstances, it may still be possible to proceed on an ‘Execution Only’ basis which means that VFS Europe is simply acting on your instruction to effect a particular policy without providing advice on its suitability.
Service – the VFS Group considers ongoing service of vital importance and clients will normally be contacted by their personal intermediary on a regular basis, dependent upon the needs of the client. There is no charge for this service. If advice is required at any other time, the client should contact his personal intermediary, or, in his absence, the General Manager of VFS Europe at the address shown below.
Investment management – under no circumstances will your intermediary agree to provide discretionary investment management services. Where appropriate, you may appoint a manager if you wish.
Authority to act – you may at any time revoke your authority for VFS Europe to act on your behalf, but this must be done in writing both to VFS Europe and to the Insurance Company which has provided the product. Please note that this might affect certain policies where VFS Europe has exclusive rights to market such products. You will be advised of the implications in such a situation.
Documentation – VFS Europe undertakes to provide you with full details of the products recommended, including illustrations, policy provisions (if requested) and all information required to be provided by the CAA.
Client money - VFS Europe does not under any circumstances handle client money. All monies should be sent to the product provider, either by cheque, bank transfer, standing order, direct debit, credit card transfer or similar. Cheques made payable to VFS Europe (unless for specific fees) will be returned. Cash and traveller’s cheques will not be accepted at any time. All proceeds from surrender, encashment or withdrawal will be paid to the client or his specifically nominated agent. Such monies should not be paid to VFS Europe or its intermediaries at any time.
Policy documents – the insurance company will issue the policy documents directly to your VFS Europe intermediary who will undertake to check the documentation before delivering it to you. You should also check the documentation upon receipt and notify us of any changes required or anything you do not understand. We do not offer a custody service, but we will hold copies of policy documents on file for future reference.
Professional Indemnity Insurance (PII) – the CAA and the DGS require insurance intermediaries to have PII cover. VFS Europe intermediaries have such cover to satisfy that requirement.
Data Protection – VFS Europe will only use information held about a client for the purposes of providing advice to that client and ancillary issues, such as ensuring documentation is correct. It will not be used by other members of the VFS Group (apart from normal administration purposes) or passed to third parties without written permission from the client. The client has a right of access to his data and may request rectification of data if incorrect.
Communication - any comments or complaints regarding the service provided or a product purchased from VFS Europe should be made to The Compliance Officer, VFS Europe Sàrl, 4 Route d'Arlon, L-8399, Windhof, Grand-Duché de Luxembourg. For business written in Spain, comments and complaints should be addressed to The Compliance Officer, VFS Europe Sàrl (Spain), Calle San Antonio, Trinquete No. 3, 03726 Benitachell, Alicante, Spain. Such comments and complaints will normally be acknowledged within 10 working days.
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