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CISRO Principles of Conduct for Insurance Intermediaries
The CISRO Principles of Conduct for Insurance Intermediaries (the Principles) reflect common regulatory standards for
insurance intermediaries in Canada. The Principles outline professional behaviour and conduct expectations for the fair
treatment of Customers.
Intermediaries should conduct their business following the Principles that are relevant to them, while ensuring compliance with all
applicable laws, regulations, rules, or regulatory codes within all jurisdictions where they carry on business. Any more stringent
requirements, rules or standards of conduct take priority over the Principles.
The Principles are intended to supplement, complement and build upon the intermediary elements in the Guidance on Conduct
of Insurance Business and Fair Treatment of Customers (FTC), issued by CISRO and the Canadian Council of Insurance
Regulators (CCIR). The Principles also align with Insurance Core Principles (ICP) of the International Association of Insurance
The Principles reinforce the fair treatment of Customers throughout the life cycle of the insurance product as a core component
of the intermediary business culture. This includes conducting business in an honest and transparent manner. Expectations for
the conduct of insurance business may differ depending on the nature of the relationship to the Customer, the type of insurance
provided, and the distribution method. Intermediaries with oversight responsibilities must take appropriate measures to ensure
that their employees and representatives meet high standards of ethics and integrity.
Definition of Intermediary: Intermediary is given broad meaning, and will differ based on the applicable definitions within
different jurisdictions across Canada. It encompasses adjusters, agents, brokers and representatives, as well as business
entities that distribute insurance products and services, including managing general agencies and third party administrators. It
also applies to all distribution methods, including over the internet.3
Definition of Customer: Customer refers to policyholder (which may include a certificate holder) or prospective policyholder
with whom an insurer or intermediary interacts, and includes, where relevant, other beneficiaries and claimants with a legitimate
interest in the policy. Customer may also refer to a consumer, which includes all actual and potential customers for insurance
1 International Association of Insurance Supervisors. Insurance Core Principles, ICP 18 and ICP 19, updated
November 2019. https://www.iaisweb.org/page/supervisory-material/icp-on-line-tool
2 The Insurer is responsible for fair treatment of Customers throughout the life cycle of the insurance product, as it is the Insurer
that is the ultimate risk carrier. The Insurer’s ultimate responsibility does not absolve Intermediaries of their own responsibilities
for which they are accountable.
3 This definition aligns with the CCIR/CISRO FTC guidance. These Principles apply to all Intermediaries that are authorized to do
business within any jurisdiction, whether licensed, registered or exempted from licensing or registration.
Canadian Insurance Services Regulatory Organizations (CISRO)
Principles of Conduct for Insurance Intermediaries
1. Compliance / Outcomes: Intermediaries must comply with all applicable laws, regulations, rules and
regulatory codes to which they are subject.
2. Customers’ Interests: Intermediaries are expected to place Customers’ interests ahead of their own. This
includes when an Intermediary is developing, marketing, recommending, distributing and servicing products.
3. Conflicts of Interest: Intermediaries are expected to identify, disclose and manage any actual or potential
conflict of interest that is associated with a transaction or recommendation. They are expected to avoid entering
into or pursuing agreements for which conflicts of interest cannot be managed, or if they interfere with the fair
treatment of Customers.
4. Advice: When providing advice to or for a Customer, Intermediaries are expected to seek appropriate
information from the Customer in order to understand and identify their unique needs. Intermediaries are
expected to provide objective, accurate and thorough advice that enables the Customer to make an informed
decision. Advice is expected to be suitable for the needs of the Customer based on the Customer’s disclosed
5. Disclosure: Intermediaries are expected to provide Customers with objective, appropriate, relevant, timely and
accurate information and explanations so that they can make informed decisions. Intermediaries are expected to:
• Properly disclose the information to all necessary parties, including the insurer; and
• Disclose information and explanations in a manner that is clear and understandable for Customers,
regardless of the distribution model or medium used.
6. Product and Service Promotion: Intermediaries are expected to ensure that products and services are
promoted in a clear and fair manner. Regardless of the distribution model or medium used, Intermediaries are
expected to ensure that promotions are not misleading, and are easy to understand. Product promotions are
expected to disclose all necessary and appropriate information.
7. Claims, Complaints Handling, and Dispute Resolution: Intermediaries are expected to handle or
cooperate in the handling of claims, complaints and disputes in a timely and fair manner.
The Principles outline professional behaviour and conduct expectations for the fair treatment of Customers:
8. Protection of Personal and Confidential Information: Intermediaries are expected to take necessary
and appropriate measures to protect and manage personal and confidential information. They must comply with
all applicable privacy legislation.
Customers should be confident that Intermediaries:
• Only collect and retain information that is necessary and appropriate for the fulfillment of the service or
product provided; and
• Use and disclose the information only for purposes and for the duration for which the Customer has given
consent or as required by law.
9. Competence: Intermediaries are expected to maintain an appropriate level of professional knowledge, and
should stay current through continuing education to ensure the fair treatment of Customers. Where applicable,
continuing education requirements must be fulfilled. Intermediaries are expected to not misrepresent their level
of competence or conduct business beyond their level of professional knowledge and experience, and duties
must match training/education.
Oversight: Intermediaries with contractual or regulatory oversight obligations are also responsible for the
conduct of any employee or third party involved in the marketing, distribution or servicing of an insurance product.
Intermediaries are expected to have tools at their disposal such as policies and procedures, training and control
mechanisms to ensure the fair treatment of Customers is achieved in relation to their oversight obligations
Please find below some links which you may find useful.
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