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Trust between business partners is paramount for guaranteeing the sustainability of our business, the protection of our customers and the quality of our products and services.

This section outlines the general principles that have to underpin fruitful relations with our business partners. The establishment of a network based on long-lasting and mutually satisfactory relations with our partners is a strategic objective for GLAPI and builds competitive success. Thus, GLAPI requires its business partners to ensure compliance with all regulatory requirements and to align with its policies while performing business. The Generali Group and GLAPI as part of it are committed to performing business with partners by complying with the following principles and provisions:

1. GENERAL COMPLIANCE PROVISION

The parties represent and warrant that: 

1. they are, and shall remain throughout the term of this Agreement, in compliance will all applicable laws, rules and regulations.
2. they are, and shall remain throughout the term of this Agreement, acting in compliance with all obligations pertaining to insurance, social security, fiscal and tax obligations, labor, workplace safety, health and hygiene, environmental protection, subcontracting matter and in accordance with administrative and criminal law.
3. they are, and shall remain during the term of this Agreement, accredited by the relevant local accreditation authority and more, generally, shall keep all licenses (including specific licenses), accreditations, registrations, authorities and consents which shall be required under applicable laws and regulations; the BUSINESS PARTNER shall provide evidence of all licenses and accreditations upon request of the COMPANY, and shall provide immediate notification to the COMPANY of any suspension, revocation, modification or restriction of its license, accreditation, or right to conduct its business.

The BUSINESS PARTNER represents and warrants that, during the term of this Agreement and for its execution, it will keep the sufficient level of awareness and knowledge of relevant laws and regulations. The BUSINESS PARTNER will timely and accurately complete, sign, and submit all necessary documentation of compliance. Any breach by a PARTY of the provisions in this Clause shall be considered as a material breach of this Agreement and will enable the other PARTY to terminate this Agreement, without any prior notice or any compensation.

1.2. CODE OF CONDUCT

The BUSINESS PARTNER acknowledges receipt of the COMPANY’s Code of Conduct set out at: /code-of-conduct/ and undertakes to comply in good faith with the requirements therein and shall use all reasonable efforts to ensure compliance with the same by its employees, sub-contractors, agents and representatives engaged in the supply of the Deliverables and/or Services. A failure by BUSINESS PARTNER to comply with its obligations pursuant to this clause shall constitute a material breach of this Agreement entitling Company to withhold pertinent commissions where applicable and/or terminate this Agreement immediately upon written notice to the BUSINESS PARTNER.

1.3. ANTI-BRIBERY AND ANTI-CORRUPTION

The COMPANY commits to high standards related to the fight against corruption and expects any person (legal entity or physical person), in a partnership with GENERALI, to adhere to the same level of abovementioned standards, and to strictly respect all anti-corruption regulations in force. In this respect, the BUSINESS PARTNER ensures that it [and its Subsidiaries and Affiliates] have conducted their businesses in compliance with applicable anti-corruption laws and have instituted and maintain and will continue to maintain on an ongoing basis its own anti-bribery/corruption policies and procedures designed to promote and achieve compliance with such laws and to prevent bribery/corruption offences and will enforce them where applicable.

The PARTIES guarantee that each person (legal entity or physical person) acting on its behalf or for its account will:

• respect all regulations in force and related to the fight against corruption; 
• not be involved in the offering, promising, giving or taking of any financial or other improper advantage to any person in breach of any law against bribery or corruption; and
• provide any required assistance to the other PARTY which would be necessary to reply to any inquiry related to the fight against corruption made by a duly authorized authority.

Any breach by a PARTY of the provisions in this Clause shall be considered as a material breach of this Agreement and will enable the other PARTY to terminate this Agreement, without any prior notice or any compensation.

Each PARTY will promptly inform the other PARTY any information which has come to its knowledge for which the notifying PARTY knows or suspect that a breach of anti-bribery or anti-corruption regulation has or may occurred or of any matter which would be known by the notifying PARTY, and which would involve a liability, under this Clause.

1.4. SANCTIONS CLAUSE

“International Sanctions Regulations” means the set of national and international regulations dealing with embargoes, sanctioned individuals and entities, counter-terrorism financing and trade restrictions adopted by: (i) United Nations; (ii) European Union; (iii) United States of America, mainly through the Office of Foreign Assets Control of the US Department of the Treasury; (iv) the Philippines and (v) any additional relevant jurisdictions that govern this Agreement.

The PARTIES shall ensure compliance with International Sanctions Regulations and shall put appropriate systems and procedures in place to protect themselves against any breach of it. The COMPANY will not provide cover, nor pay, nor provide any benefit or service if this would expose the COMPANY to any sanction, prohibition, or restriction under International Sanctions Regulations. The BUSINESS PARTNER represents that neither it nor any individual, entity or organization holding any ownership interest or controlling interest in it, including any officer or director, is not a designated person, entity or organization or prohibited from rendering services pursuant to this Agreement under International Sanctions Regulation. The COMPANY will be entitled to immediately terminate the Agreement in case the BUSINESS PARTNER will become a specifically designated entity under International Sanctions Regulation.

2. ANTI MONEY LAUNDERING ACT AND GOOD CORPORATE GOVERNANCE COMPLIANCE

The PARTIES shall ensure compliance with anti-money laundering regulations and counter-terrorism financing regulations and shall put appropriate systems and procedures in place to protect themselves against money laundering and terrorism financing. In particular, the PARTIES agree to comply with the Anti-Money Laundering Act (AMLA) and Good Corporate Governance Compliance requirements provided for under the Anti Money Laundering Act of 2001, as amended, and the Terrorism Financing Prevention and Suppression Act of 2012, its Revised Implementing Rules and Regulations, and IC Circulars related therein to the extent that such laws and regulations may apply to them.

Each PARTY agrees to provide the other PARTY with documents and information required by anti-money laundering and counter-terrorism financing regulations on first request. Each PARTY guarantees that each person (legal entity or physical person) acting on behalf or for the account of it will provide any required assistance to the other PARTY which would be necessary to reply to any inquiry related to the fight against money laundering or terrorism financing made by a duly authorized authority (e.g., AML Council or IC).

Under a strict policy of confidentiality, the PARTIES undertake to communicate immediately any information which has come to its knowledge in the course of, or in connection with, the performance of this Agreement, for which it knows or suspects that a breach of anti-money laundering or counter-terrorism financing regulations has or may occurred.  

3. DATA PRIVACY ACT

The PARTIES agree to follow the requirements under Republic Act No. 10173 (Data Privacy Act of 2012) including its Implementing Rules and Regulations.

4. UNETHICAL PRACTICES

The PARTIES are prohibited from committing any unethical act such as misrepresentation, business twisting, connivance with any personnel in the solicitation of business, and the like or in general, which violates any provision of the Amended Insurance Code, or any of the existing rules and regulations of the IC.