Client Protection Principles: Model Law 4. Responsible Use of Agents: Relates to provider relationships with agents and making providers responsible for the behavior of agents.
1.2(1) Scope of Application; 3.2 Board and Senior Management Oversight; 8.1(4) Client Treatment Policies and Procedures
Financial Service Providers are responsible for the behavior of agents.
5. Preventing Staff Corruption: Relates to preventing staff from obtaining money or other favors from Clients in return for providing products, creating a corporate culture where employees feel safe to be whistle blowers, and systems for detecting and correcting corruption.
3.1(1)(c) Prohibited Acts
The prohibition on unfair, deceptive or abusive acts or practices includes staff corruption.
6. Informing Clients of Their Rights: Relates to the provision of information to Clients about their rights, including what is and is not acceptable behavior by the provider’s staff, and how to make complaints.
6.1 Product Disclosure Principles; 6.2 Product Disclosure Form; 10.1 Internal Complaint Handling Unit
7. Client Feedback: Relates to tools for assessing a provider’s success in fostering responsible treatment, including Client surveys, third party interviews, mystery shopping, and effective systems for addressing Client complaints.
8.1(4)(d)(ii) Client Treatment Policies and Procedures; 10.1 Internal Complaint Handling Unit; 10.2 Supervisory Authority Response to Client Complaints and Inquiries
A-2-5