Agency Code of Discipline Document Control Code

Subject Agency Code of Discipline Page No. Page 1 of 13

Issuer Compliance Document

Control Stamp
Effective Date August 2016

Revision No. 2.0

AGENCY CODE OF
DISCIPLINE
August 2016

APPROVALS SIGNATURE
Prepared by: James Yap
Reviewed by: Atty. Raya Gargarita
Approved by: Atty. J. Sotero Roman
Noted by: Dennis Villanueva
AGENCY CODE OF DISCIPLINE
Table of Contents

A. Introduction ............................................................................................................................... 3
B. Policy .......................................................................................................................................... 3
C. Guiding Principles – Doing the Right Things Right ..................................................................... 4
D. Classification of Offenses ........................................................................................................... 5
1. THE FOLLOWING ARE CLASSIFIED AS CLASS A OFFENSES .................................................... 5
2. THE FOLLOWING ARE CLASSIFIED AS CLASS B OFFENSES .................................................... 7
3. THE FOLLOWING ARE CLASSIFIED AS CLASS C OFFENSES .................................................... 9
E. Incident Report Template ........................................................................................................ 10
F. Process Flow for Disciplinary Action ........................................................................................ 11
G. System of Sanctions ................................................................................................................. 12
H. Appeals..................................................................................................................................... 13

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A. Introduction
This Agency Code of Discipline (ACOD), in conjunction with the Market Conduct Guidelines
(MCG), sets out the standards of behaviour and best practices that FWD Life Insurance
Corporation (FWD) expects of its Agents to demonstrate and observe when conducting their
day-to-day business activities.

It outlines the measures of conduct and provides a comprehensive list of offenses and a
corresponding system of sanctions to instil a strong sense of professional discipline among the
FWD Agents and Agency Leaders especially in how they conduct their business relations with
their clients, their fellow agents, FWD and its employees and officers.

All licensed Financial Wealth Planners, Financial Wealth Officers, Financial Wealth Managers,
Financial Wealth Directors and Financial Wealth Executive Directors of FWD or such other
sales producers authorized by FWD’s Agency Channel to act as such however they may be
called, shall be covered by this ACOD.

This ACOD is intended to supplement, and not to replace the MCG and should be read
together with the MCG.

This ACOD vis-à-vis the MCG shall be periodically reviewed and updated as may be required
by law or as evaluated by current experience. All approved changes shall be communicated to
the Agents accordingly, however, it shall be responsibility of Agents to study the ACOD and
MCG regularly and keep themselves updated on any of its revisions, amendments or additions.

B. Policy
All Agents and Agency Leaders are expected to embody the FWD Guiding Principle of Doing
the RIGHT things RIGHT. Thus, it is incumbent upon everyone to maintain the highest
standards of personal integrity in carrying out their duties and to make a commitment to
always comply with the laws and regulations governing their activities.

Agents must always demonstrate good judgment and apply the highest ethical standards in
their business relationships and to act within the letter and spirit of the laws and regulations
that govern FWD’s business including the policies, rules, and guidelines it has set.

It is likewise incumbent upon the Agents to recognize compliance failures and to promptly
report such to management or to their immediate supervisors and to Compliance.

Lastly, every Agent must put to heart that his duty is not only focused in the practice of his
profession but also in how he conducts his business relations with his clients and FWD.

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C. Guiding Principles – Doing the Right Things Right
These Guiding Principles set out the behavioural standards expected of every Agent, Agency
Leader and any sales producer, however, they may be called, as part of their appointment and
engagement with FWD.

1. Honesty and Integrity

All business dealings of Agents shall be based on trust, conducted with integrity, due
care and diligence and should always consider what is fair and ethical in any given
circumstance.

All Agents must likewise approach incentive structures, contests, or promotions with
the right behaviours. The main objective of these incentives, i.e., to reward good
performance, should never be lost. Thus, Agents must not commit any dishonest acts
in order to secure unfair and unlawful advantage in order to gain such incentives.

2. Be Informed and Act Responsibly

Caring about the client is the core culture of FWD. Thus, Agents should always give
paramount consideration to the best interests of the clients and should always act
within the parameters of his authority.

Agents are likewise responsible for the management of their businesses and its
associated risks and should adopt the sound risk management policies as set by FWD.

3. Open and Clear Communication

Agents shall treat all their clients fairly and should communicate with them in an open
and clear manner. Agents should not withhold information from clients or exaggerate
benefits or inversely, play down risks associated with FWD’s products and services.

4. Professionalism and Respect

Agency Leaders and their Agents should promote a workplace in which diverse
thinking and the free expression of personal values is genuinely appreciated and
respected. Agency Leaders should likewise encourage innovative thought, proactivity
and urgency in solving issues and getting results however, not at the expense of doing
the right thing by the clients and by each other.

5. Socially and Environmentally Responsible

Agents and Agency Leaders shall avoid or responsibly manage their business activities
which may have a negative impact on people or the environment, play their parts in
addressing socio-environmental challenges, and seek positive social change by
supporting good causes and investing in communities.

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D. Classification of Offenses
Offenses are classified into three (3) different classes which shall be the basis of the
Distribution Compliance Officer (DCO) and/or Compliance and Ethics Committee (CEC) for
prescribing the necessary disciplinary action as the case maybe. Any misconduct or offense
which cannot be clearly classified or defined shall be forwarded to Compliance for proper
evaluation and interpretation.

1. THE FOLLOWING ARE CLASSIFIED AS CLASS A OFFENSES

CLASS A
1 Breach of Agent’s Agreement
Engaging or encouraging others to engage in sub-agency or subcontracting of
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his duties and obligations
3 Adjudged bankrupt or insolvent
Failure to comply with laws and regulations, e.g., AMLA, FATCA, Data Privacy
4 Act, Counter-Terrorist Financing, etc., including violation of any of the policies
and/or guidelines of the Company or any amendments thereto
Entering the service of/ recruiting for another life insurance company and/or
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its affiliates, in whatever capacity without the knowledge of the Company
6 Committing or facilitating money laundering or terrorist financing activities

7 Tipping off clients that a report to the AMLC was made against them
8 Failure to report known AML-CTF suspicious activities
Committing, attempting to commit or assisting the commission of a financial
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fraud
Accepting check or cash payments by virtue of the Agency without the
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approval of the Company
11 Unauthorized collection of premium
12 Diversion and/or Misappropriation of premium payments
13 Accepting bribes and/or kickbacks
Signing or submitting insurance application forms for processing or such other
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documents without personally seeing the client

15 Asking or permitting a client to sign in blank forms or documents

Signing on behalf of the client whether the same is with consent of the client
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or not

Signing as a witness to any forms and documents without having seen the
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client sign the said document

18 Unauthorized submission of a client's policy application or any change thereto

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 Forgery, including forgery of the client's signature or any of the signature of
19 the officers of the Company, falsification or alteration of Company documents
and forms or client documents
20 Knowingly using or permitting the use of forged or fraudulent documents
Knowingly providing false statement or misrepresentation on any document
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or official form of the Company
Knowingly withholding relevant information about the client that may affect
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underwriting of a new application or reinstatement of a policy
Participating directly or indirectly, or in collusion with others, in the filing of a
23 fraudulent application for insurance, or reinstatement of policy, or claim
against the Company
Committing or attempting to commit, by himself or in collusion of others, act
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or acts to defraud the Company or its affiliates
Disclosing confidential information, other than to where it is intended,
whether gathered from the client in the course of solicitation or proprietary
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information, records, trade secrets of the Company disclosed or made
available to him without the written consent of the Client and/or the Company
26 Gathering personal information of a client in a dishonest manner

Committing an act or omission that brings discredit or disrepute to the

27 Company, its officers, stockholders, employees, fellow Agents, as well as its
products and/or operations
Committing an act constituting breach of trust or confidence reposed upon
28 him by the Company, such as but not limited to theft, unsettled personal
obligations, etc.

Giving false testimony, including knowingly presenting falsified documents or

29 information on any investigation being undertaken or conducted by the
Company

Commission of a crime involving moral turpitude or any other offense which

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shall affect the trust reposed upon him by the Company

Rendering false statements or misrepresentations in his application for

licensing, or for manipulating his sales, such as but not limited to; cross-selling
amongst agency force, their spouses, and family members, to be entitled to
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an appointment, commission, bonus, incentive, or any other privilege or
benefit from the Company; splitting large sum assured amounts into multiple
small sum assured amounts to increase case counts
32 Failure to conduct field underwriting to client
33 Gross or habitual neglect of its Agent’s duties and obligations
Inducement or offering any incentive, discounts, rebates in order to close a
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sale

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 Threatening, intimidating, coercing or harassing a Client, officer or employee
of the Company, a fellow Agent and/or his family with bodily harm or any
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other illegal acts for any reason specially if it concerns the work or business of
the other and/or directly affecting his work

36 Inciting mass action against the Company or its officers

Intentionally destroying or damaging client or Company documents (hard or

37 soft copies), property or any other property belonging to the Company, its
employees, and other persons for which the Company may be held liable

Placing the Company under any legal obligation which is not within the
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authority granted in the Agent’s Agreement or elsewhere in writing
Retaliation with harassment or physical violence due to a whistleblower
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report made
40 Submission/reporting of a false or malicious/misleading whistleblower report
41 Other acts similar or analogous to the foregoing
42 Failure to report any of the foregoing offenses

2. THE FOLLOWING ARE CLASSIFIED AS CLASS B OFFENSES

The DCO and/or CEC may reclassify a Class B Offense to a Class A Offense, if the
infraction committed was proven to have been done intentionally or fraudulently.

Class B
Participating directly or indirectly in the piracy of sales associates, or
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poaching of businesses of another, whether within the Company or another
Recruiting in violation of IC CL 2013-32 or any other applicable law or
2
regulation
Using abusive, disrespectful, insulting, profane, or obscene language or act
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in addressing a client, another agent, employee or office of the Company
4 Undergoing bankruptcy or insolvency proceedings
Failure to attend Compliance training sessions and refresher courses or
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other trainings required by the Company
Resorting to unethical practices in soliciting business and/or manipulation
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of sales, e.g., twisting, churning, pooling or selling to relatives
Financing or advancing payments of premiums or using personal or
7 another's cash, check, bank account, and/or credit card in paying a client's
premium

Failure to promptly complete, accomplish, submit, return and/or transmit

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all required documents related to his business brought into the Company

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 Failure or unreasonably delaying the submission of requirements,
information and/or document known to him which are needed in
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underwriting new applications, amendments, reinstatements, or
termination/s of old policy/ies
Reporting to the office, attending official Company functions and/or
10 conducting business while under the influence of liquor, prohibited or
regulated drugs and/or other intoxicating and addictive substances
Willful or intentional circulation and/or use of unauthorized materials in
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soliciting applications for insurance coverage
Placing of any advertisements in any publication, or publishing any circular
or letter, or posting to websites, including social media sites, any material
12 involving the Company or any other person or entity which the Company
has existing business relationship or tie-ups, without any authorization from
the Company
Unauthorized use of the name of the Company while pursuing personal,
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political or for-profit activities
Identifying one's position or authority in any communication other than the
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authority given by the Company
Recommending a person for appointment or licensing to any position who
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will serve as "dummy" to his business or branch
Maligning or circulating false, vicious, or malicious statements against the
16 Company, its officers, stockholders, employees and fellow Agents, as well as
its products or operations
Inducing any employee or Agent to leave its services or to commit an
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infraction of Company rules and regulations
Instigating a fight and/or participating in a fight while inside Company
18 premises or while presenting/selling for the Company whether within or
outside Company premises
Failure to disclose outside business activities that require prior approval of
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the Company
20 Unauthorized / erroneous filing of expense/reimbursements
21 Other acts similar or analogous to the foregoing
22 Failure to report violations in relation to any of the above

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3. THE FOLLOWING ARE CLASSIFIED AS CLASS C OFFENSES
The DCO and/or CEC may reclassify a Class C Offense to a Class A/B Offense, if the
infraction committed was proven to have been done intentionally or fraudulently.

CLASS C
Failure to ensure that the client has a sound understanding of the benefits
1 and features, as well as the charges, limitations, etc., of the product being
offered
Failure to ensure that the client has a sound understanding that, by signing
2 the completed application form, the client attests to the veracity and
completeness of the information provided
Failure to conduct proper needs analysis resulting to offering or
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recommending inappropriate products to the client
4 Unauthorized use of the Company's premises and facilities
Unintentional circulation and/or use of unauthorized materials in soliciting
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applications for insurance coverage
Gross uncooperativeness with his Agency Leader/s on matters related to
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productivity and management
7 Offering services beyond company services - Multi-level marketing, etc.
Failure or refusal to acknowledge and/or recognize official
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communications from the Company
Refusal to cooperate in any investigation being undertaken or conducted
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by the Company
Engaging in activities or relationships that may cause embarrassment to or
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impair the Company's best interest
11 Failure to personally and/or immediately deliver the policy to the client
12 Failure to promptly return all undelivered policies
Failure to inform the insured and/or the policyowner, at the time of policy
13 delivery of any significant changes between the policy applied for and the
policy issued by the Company
14 Failure to forward all client complaints in a timely matter
Failure to report lost company-issued equipment/devices in a timely
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manner
Failure to disclose gifts and/or entertainment received or given that is
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more than the threshold
Unauthorized invitation of Non-FWD personnel in FWD sponsored events
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and gatherings
18 Other acts similar or analogous to the foregoing
19 Failure to report violations in relation to any of the above
20 Failure to provide prompt and effective after sale transaction to the client
21 Failure to comply with the company and agency policies and guidelines

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E. Incident Report Template

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F. Process Flow for Disciplinary Action

APPROVALS SIGNATURE
Prepared by: James Yap
Reviewed by: Atty. Raya Gargarita
Approved by: Atty. J. Sotero Roman
Noted by: Dennis Villanueva
G. System of Sanctions
The system of sanctions below prescribes the disciplinary actions to be imposed upon the
erring Agent. Nonetheless, the DCO and/or CEC shall not be precluded from imposing a lower
or higher penalty, depending on the gravity and frequency of the misconduct or offense.

OFFENSE FREQUENCY SANCTION/S

CLASS
A 1st  Immediate Termination of Agency Contract
 and Financial Penalty, if any, including clawbacks,
disqualification to contests and rewards, etc.

B 1st  Suspension of Agency Contract;

 Disqualification to any incentives, contests, rewards
and/or drive;
 and Financial Penalty, if any, including clawbacks, etc.
2nd  Termination of Agency Contract;
or succeeding  Disqualification to any incentives, contests, rewards
offense and/or drive;
 and Financial Penalty, if any, including clawbacks, etc.

C 1st  Written Reprimand

2nd  Suspension of Agency Contract; and/or
 Disqualification to any incentive and/or drive.
3rd  Disqualification to any incentive and/or drive;
or succeeding  Suspension of Agency Contract; and/or
offense  Termination of Agency Contract
 and Financial Penalty, if any, including clawbacks, etc.

SANCTIONS THAT MAY BE IMPOSED

DURING THE PENDENCY OF INVESTIGATIONS
The CEC may likewise impose  Immediate Suspension of Agent’s Selling Privileges
the following penalties while  Suspension of Agent’s Selling Privileges
the case is pending  Suspension of Other privileges, including disqualification
investigation: to contests and rewards, etc.
ADDITIONAL SANCTIONS
The CEC may likewise impose  Inclusion in the Negative List;
the below penalties on top of  Removal or lowering of the Agent’s non-medical limit or
the Sanctions already executed: authority;
 Requiring additional training;
 Requiring retraining in areas where the Agent had failed
in; or
 Requiring the Agent to bear the cost of any service or
claim recovery to the complainant, policyholder or
policyowner.
FURTHER LEGAL ACTIONS
The above sanctions/penalties shall be without prejudice to FWD’s right to take any
appropriate legal action including the filing of any administrative, civil and/or criminal
charges.

APPROVALS SIGNATURE
Prepared by: James Yap
Reviewed by: Atty. Raya Gargarita
Approved by: Atty. J. Sotero Roman
Noted by: Dennis Villanueva
H. Appeals
Once a decision has been reached by the DCO and/or CEC, the Agent will be notified in writing
of the resolution, copy furnished his immediate Agency Leader.

The Agent will have a period of three (3) working days from notification to appeal the said
decision. Agent will be entitled to appeal the Decision only once.

If Agent wishes to appeal the Decision, Agent shall file his Appeal Letter to Compliance, copy
furnished to his immediate Agency Leader, stating therein his grounds for appeal and the
resolution prayed for, e.g., lowering the penalty, etc. Compliance will then review the Appeal
and make its recommendation to the CEC panel for their consideration.

After the CEC has ruled on the Agent’s appeal, no further appeals or motions for
reconsideration will be entertained. The Decision on the Appeal will be deemed final and
executory and shall be effected within three (3) working days from Agent’s receipt of the
Notification of Decision of the Appeal.

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