Code of professional ethics for insurance agents

1. General Provisions

1.1. The Code of Professional Ethics for Insurance Agents (the "Code") sets out the rules of professional conduct for insurance agents who are members of the Association of Insurance Agents and Brokers (the "Association") when providing agency services on the insurance market of the Republic of Kazakhstan.

1.2. The Code applies to insurance agents who are individuals, including sole proprietors, and legal entities, as well as to employees and representatives of legal entities who deal directly with clients (the "agents").

1.3. The Code supplements, but does not replace, the requirements of the Law of the Republic of Kazakhstan "On Insurance Activity", the Civil Code of the Republic of Kazakhstan, the Law of the Republic of Kazakhstan "On Consumer Protection" and other regulatory legal acts. In the event of any discrepancy, the provisions of legislation prevail.

1.4. The purpose of the Code is to protect clients' interests, ensure that agents perform the instructions of insurance organizations in good faith, and maintain trust in insurance intermediation.

2. Core Principles

2.1. An agent is guided by the principles of honesty, competence, confidentiality, respect for clients and colleagues, and compliance with the law.

2.2. An agent does not provide false information, does not conceal material facts and does not make promises they cannot keep, including regarding the amount and timing of an insurance payout.

2.3. An agent does not forge or falsify documents, does not enter inaccurate information into them and does not induce the client to do so.

2.4. An agent does not take advantage of a client's inexperience, dependence or difficult circumstances. For those who find it harder to assess insurance terms — elderly people, persons with disabilities, clients concluding a contract for the first time — the agent explains the terms in more detail and makes sure the decision is an informed one.

3. Status of the Agent

3.1. An agent acts on behalf of, on the instructions of and in the interests of an insurance organization (insurance organizations) under an agency agreement.

3.2. At the start of any interaction, the agent clearly informs the client which insurance organization or organizations they represent and names the organization with which the insurance contract will be concluded.

3.3. An agent does not mislead the client about their status: they do not call themselves an insurance broker, an independent adviser or a representative of the client's interests, and do not create such an impression.

3.4. At the client's request, the agent confirms their authority with documents from the insurance organization.

3.5. An agent does not use their status as a member of the Association to give the client the impression of guarantees that the Association does not provide.

4. Authority and Obligations to the Insurance Organization

4.1. An agent acts only within the authority granted by the insurance organization and does not assume obligations on its behalf beyond that authority.

4.2. An agent correctly executes insurance contracts and related documents and provides the insurance organization with accurate information about the client and the risk being insured.

4.3. An agent transfers the insurance premiums received to the insurance organization in a timely manner and in full, and hands over documents within the time limits set by the agency agreement.

4.4. An agent ensures the safekeeping of documents received from the insurance organization and from clients and returns them upon termination of the agency agreement.

4.5. An agent cooperates with the Agency of the Republic of Kazakhstan for Regulation and Development of the Financial Market and provides the requested information in the manner established by law.

5. Remuneration

5.1. The agent's remuneration is paid by the insurance organization in the manner provided for in the agency agreement.

5.2. An agent does not charge the client additional fees for advice, execution of the insurance contract or other actions without a legal basis and does not include such fees in the insurance premium.

5.3. The amount of remuneration does not influence the agent's recommendations: from the products of the insurance organizations they represent, the agent offers the one that matches the client's needs and means.

6. Explaining Insurance Terms

6.1. Before the contract is concluded, the agent explains the material terms to the client: the scope of cover, the sum insured, the insurance premium and the procedure for paying it, and the term of the contract.

6.2. The agent separately and clearly explains:

• exclusions from cover;
• the amount of the deductible and how it applies;
• what to do when an insured event occurs and how to obtain the insurance payout.

6.3. An agent does not push unnecessary products, additional services or cover that is clearly unsuitable for the client, and does not prevent the client from reading the full insurance rules.

6.4. An agent advises only within their competence. If a question goes beyond it, the agent informs the client and recommends contacting the insurance organization or a relevant specialist.

7. Assisting the Client with an Insured Event

7.1. When an insured event occurs, the agent explains to the client what steps to take, within what time limits, and which documents to submit to the insurance organization.

7.2. The agent helps the client prepare the claim and documents, submits them to the insurance organization if this falls within their authority, and keeps the client informed of the progress of the review to the extent of the information available to them.

7.3. An agent makes no promises regarding the insurance organization's decision on payment and does not prevent the client from contacting the insurance organization directly.

8. Prohibition of Client "Switching"

8.1. An agent does not induce a client to terminate an existing insurance contract early and conclude a new contract with another insurance organization if this worsens the client's position.

8.2. If the client is considering replacing a contract on their own initiative, the agent explains the possible consequences: loss of part of the premium paid, a gap in insurance protection, and changes in terms and exclusions.

8.3. An agent representing several insurance organizations does not move clients between them for the sake of higher remuneration.

9. Fair Competition

9.1. An agent's advertising and information materials are accurate and do not mislead consumers about insurance terms, cost, payout guarantees, or the agent's status and authority.

9.2. An agent does not spread defamatory information about other agents, brokers or insurance organizations, and does not use unsubstantiated comparisons or unlawfully obtained information about competitors.

9.3. An agent treats colleagues courteously and respectfully. Professional disagreements are resolved through negotiation and, if no agreement is reached, with the involvement of the Association, including through mediation.

10. Confidentiality

10.1. An agent keeps confidential any information about the client, their property, health, financial position and the terms of the insurance contract that becomes known to them in connection with providing the service.

10.2. An agent uses such information only to conclude and perform the insurance contract, transfers it to the insurance organization they represent to the extent necessary, and discloses it to other persons only in cases provided for by law or with the client's consent.

10.3. An agent complies with the requirements of the Law of the Republic of Kazakhstan "On Personal Data and Their Protection" and does not use client information for their own benefit after the agency agreement ends.

11. Conflict of Interest

11.1. An agent avoids situations in which personal interest may influence their recommendations to the client or the performance of their obligations to the insurance organization.

11.2. If a conflict of interest arises, the agent informs the client and the insurance organization and takes measures to resolve it. If the conflict cannot be resolved, the agent declines to provide the service.

11.3. An agent does not accept gifts or other benefits from clients or third parties that may affect the integrity of their actions.

12. Professional Development and Accreditation

12.1. An agent knows the insurance legislation, the terms of the products of the insurance organizations they represent, and the procedures for executing contracts and settling insured events.

12.2. An agent regularly upgrades their qualifications, undergoes training and accreditation in the manner established by the Association, and keeps their certificates valid.

12.3. Legal entities acting as agents organize training for their employees and monitor their compliance with this Code.

13. Complaints and Liability

13.1. An agent accepts client complaints and responds to them on the merits and within a reasonable time. A complaint that falls within the competence of the insurance organization is forwarded by the agent to that organization, and the agent explains to the client how it will be reviewed.

13.2. An agent does not prevent the client from contacting the insurance organization, the Association, the authorized body or a court.

13.3. Complaints about breaches of the Code are considered by the Disciplinary Committee of the Association. To consider a specific complaint, it forms a Disciplinary Council in the manner established by the Rules for the Consideration of Complaints by the Disciplinary Council.

13.4. For a breach of the Code, an agent may be subject to a remark, a warning, suspension of accreditation or removal from the Association's register.

13.5. Measures applied by the Association do not release the agent from liability under the legislation of the Republic of Kazakhstan and the agency agreement.

14. Final Provisions

14.1. An agent confirms their commitment to comply with the Code by acceding to the Memorandum with Insurance Market Participants.

14.2. Amendments to the Code are made by decision of the Management Board of the Association and published on the website.

14.3. The Association provides interpretation of the Code at the agent's request.