Other

The measure to provide written reports on situations where conflicts of interest arise, is to ensure that senior management are aware of any issues and can take measures to address them. It is not necessary for a sole trader or a small insurance intermediary with no separate senior management function to produce an annual written report on conflicts of interest. However, it is important that sole traders or small insurance intermediaries maintain a record of situations in which a conflicts of interest arises or may arise in accordance with Article 7, and can demonstrate how the conflicts of interest was assessed and managed to eliminate or mitigate any risk of damage to the interests of a customer.