Our Terms of Business Agreement

By asking us to quote for, arrange or handle your insurances, you are providing your
informed agreement to these Terms of Business. We draw your particular attention to the
following sections:
The Section headed ‘Your Responsibilities’
The Section headed ‘Privacy Notice & Data Protection’,
Drawing particular attention to the sub-section ‘Credit Checks’
The Section headed ‘Money’
It is important, for your own benefit and protection, that you read these terms
carefully.
They contain details of our statutory and regulatory responsibilities and your contractual
obligations on which we will rely. If you are unsure about any aspect of our Terms of
Business, your responsibilities or have any questions regarding our relationship with you,
please contact us for more information. It is your responsibility to obtain authority to act
for all joint policyholders and to keep them informed of matters relating to this agreement,
if you require additional copies of this agreement, please let us know.
We may change the terms of this agreement from time to time to reflect changes in our
services or where changes are required due to legal or regulatory developments. where we
make changes, we will tell you about them before any policy renewal.
The Regulator
The Financial Conduct Authority (FCA) is an independent watchdog that regulates financial
services. Our Financial Services Register number is 308373 and you can check our status
and permissions at https://register.fca.org.uk/ or by contacting the FCA on 0800 111 6768.
Law and Language
This Terms of Business Agreement is subject to English Law and the jurisdiction of the
English Courts. We will use the English language for all communications, the contractual
terms and conditions, and any information we are required to supply to you before and
during the duration of the contract.
Our activities
The FCA has authorised us to advise, arrange, deal in and assist with the placing and
administration of all types of General Insurance policies and pure protection policies. We
are also authorised to undertake the following Consumer Credit Activities: Credit broking
(where we act as a credit broker), Debt administration and Debt collecting.
Our service to you
We are an independent insurance intermediary who can act both as agent of insurer and
on behalf of you, the customer in sourcing and placing insurance. Our services include:
advising you on your insurance needs, arranging your insurance cover with insurers to
meet your requirements, helping you with any on-going changes you have to make. As
part of our service, we will assist you with any claims you need to make and advise you of
your responsibilities in relation to making a claim. We have in place management controls
to deal with any conflicts of interest that might arise. Unless we advise you otherwise, we
are acting on your behalf.
We also act on behalf of insurers when collecting premiums under risk transfer (see
“Money” section). We will ask questions to enable us to assess reasonably your insurance
requirements which may include checking information we already hold about you and your
existing arrangements with us and other parties.
We always aim to deliver good service and support when you need it and to treat you
fairly in all our dealings with you. This means that we will always conduct our business
with skill, care and integrity and we will not put ourselves in a position where our duty to
you is compromised. We will be transparent in all our dealings with you, always respect
your confidentiality and deal with any complaints that may arise impartially and
sympathetically.
We will confirm to you the level of service we are providing as part of our sales process.
In all cases our service will include arranging and administering your insurance, including
helping you with on-going changes. If we use the services of another intermediary to place
your insurance, we will advise you of the name of the intermediary we use and the name
of the insurer.
Your Responsibilities
You are responsible for answering any questions in relation to any proposal for insurance
cover honestly and to the best of your knowledge, providing complete and accurate
information which insurers will require. This also applies to your responses in relation to
any assumptions you may agree to in the process of applying for insurance cover. This is
particularly important before taking out a policy but also at renewal or of if you make a
mid-term amendment to your policy.
If you fail to disclose information or misrepresent any fact which may influence the
insurer’s decision to accept the risk or the terms offered, this could invalidate the policy
and mean that claims may not be paid.
You must check all details on any proposal form or Statement of Facts or Statement of
Insurance and pay particular attention to any declaration you may be asked to sign. It is
important that you read all insurance documents issued to you and ensure that you are
aware of the cover, limits and other terms that apply. Particular attention must be paid to
any warranties and conditions as failure to comply with them could invalidate your policy
or mean that claims may not be paid.
Our aim is to provide you with your policy documentation in a timely manner confirming
the basis of cover and giving details of the insurer(s). You should examine any insurance
documents we send you very carefully to ensure that they meet your requirements. If you
believe they are incorrect or inadequate for your needs, you must advise us immediately.
You must inform us immediately of any changes in circumstances which may affect the
services provided by us or the cover provided by your policy.
If you are unsure about any matter, please contact us for guidance.
Demands and Needs
You will be provided with a statement of your demands and needs as part of our sales
process and you can request a copy at any time during the lifecycle of your insurance
arrangement with us.
Our Product Selection (Fair and Personal Analysis)
We usually offer products from a range of insurers, representing a fair and personal
analysis of the market. For some products such as legal expenses and breakdown
insurance and non-standard risks we may only offer products from a single insurer. We will
advise where this is the case. In certain circumstances, we may use the services of
another intermediary to place your insurance, and we will advise you where this is the
case.
If you would like to see a list of the insurance companies that we deal with, please ask. To
make sure you get the best offers from insurers, and to protect you from fraud and verify
your identity, some of our insurers may use publicly available data from a variety of
sources, including credit reference agencies. This has no impact on your creditworthiness
although a record of the search may appear on your record, and the information is dealt
with in total confidentiality by them. If you have any objections to this being carried out,
please let us know.
Method of Communication
Whilst you do have a choice in the way we communicate with you, we will principally
provide you with information using postal means. During the process of dealing with us
you can request to receive information in a different way, meaning if you would like
information in an electronic format, we will be happy to provide it. We may also send
reminders in the format of SMS text messages.
Conflict Management
Whilst we act in the capacity of agents for our product providers (i.e., the insurance
companies we do business with) we are required to have in place appropriate governance
controls to help us meet our regulatory objectives, and have in place effective
organisational controls, including appropriate supervision to ensure we manage any and all
conflicts of interests which may arise or may be identified from time to time, including gifts
and benefits granted and accepted, which may damage the interests of our relationship
with either our distributors one or more customers.
Our Customers Best Interests
Our primary aim is to ensure, for any customer (or potential customer) that we act
honestly, fairly and professionally and in the customers best interest including giving
customers information they might need to understand the relevance of any information we
provide, as well as objectively giving that information when it is most useful to a customer
to enable informed decision making.
Financial Strength
We regularly assess the financial strength of the Insurance Companies and other
intermediaries that we deal with. The process usually involves general observation of the
financial ratings applied by independent rating agencies such as Standard & Poor’s and A
M Best published with other readily available information within industry guides,
newsletters, and press releases. Whilst we take care to deal with companies that maintain
reasonable solvency margins, we cannot guarantee their financial ability to pay claims.
Money
Under the terms of our agreements with the insurance companies with whom we place
business, we normally accept money as agents of the insurer. In most cases you have the
additional protection of insurance companies accepting that monies you pay to us are
treated as being received by them (Risk Transfer). This will include holding your money in
the following way:
A statutory trust bank account that only allows us to use the money held in trust on
behalf of a customer for paying that customers’ premium to an insurance company and to
pay premium refunds or claims we receive from that insurance company to the customer,
once the premium has been received from that insurance company. We cannot use that
customer’s money to pay another customers premium or refund. We do not pay any
interest on premiums held by us in the course of arranging and administering your
insurance, unless, in the case of consumer transactions we receive more than £20 per
transaction, and then we will ask for your permission to retain the interest. Unless you tell
us otherwise, you are consenting to us holding your money in this way. By holding your
money in this way, means that in the event that this firm becomes insolvent your money
remains protected.
By holding your money in this way, means that in the event that this firm
becomes insolvent your money remains protected.
In cases where risk transfer has not been granted to us, we will ask you to pay the insurer
directly. We will advise you where this is the case and help arrange this for you.
Additionally, in arranging your insurance, we may employ the services of other
intermediaries who are regulated by the Financial Conduct Authority, and your premium
may be passed to these intermediaries for payment to insurers.
Insurance Premium Tax (IPT)
Your premium detailed in the policy will include IPT at the prevailing rate. Should the rate
of IPT be amended by the Government, your premium will be amended by the insurer to
reflect the change.
Important Information Consumers: You must take reasonable care not to make a
misrepresentation to the insurer. This means that all the answers you give and statements
you make as part of your insurance application, including at renewal and when an
amendment to your policy is required, should be honest and accurate. If you deliberately
or carelessly misinform the insurers, this could mean that part or all of a claim may not be
paid.
Commercial customers: If the insurance is arranged wholly or mainly for purposes
related to your trade, business or profession, you have a duty to disclose all material facts
whether or not the insurer asks for specific information. This duty applies throughout the
life of your policy and when you renew your insurance. Material facts are any facts which
may influence the insurer’s decision to accept the policy and / or what terms are applied.
Failure to disclose a material fact may invalidate your insurance and could mean that your
claim will not be paid.
No claims discount
If you advise us that you are entitled to a no-claims discount on your insurance, you will
be given 30 days from the inception of the policy to provide us with evidence of this. If
you are unable to provide us with this evidence, we will ask you to pay an increased
premium. If we cancel your policy because you have failed to provide us with proof of no
claims and failed to pay the higher premium, the time on risk charge will be based on what
the premium would have been without any no-claims discount.
Cancellation
During cooling off period: You have the right to cancel up to 14 days after receiving your
policy documentation if the policy does not meet your requirements. If you cancel within
the cooling off period, you will be charged a pro-rata time on risk charge as well as your
insurer’s administration fee if applicable. We may also make an administration charge
equal to the commission we would have earned on your policy and/or a £25 cancellation
fee.
After cooling off period: If you wish to cancel your insurance after the cooling off period
you may be entitled to a return of premium for the unused part of the policy (in
accordance with your insurer’s cancellation scale) from your insurer. We will make an
administration charge equal to the commission we would’ve earned on your policy. In both
instances, if you make a claim on your policy no refund will be allowed and if any
payments are outstanding, they will still be payable. If you owe money on another policy,
we have the right to use any refund against that.
Commercial insurance policies do not routinely have cancellation rights except those
available to the insurer. As a Commercial customer, you do not have the same cancellation
rights by law as a consumer but may still have specific contract rights and reference
should be made to the policy document to ascertain your position. Where returns of
commercial premiums are made on cancellation, it is usually following cancellation by the
insurer, not the policyholder. On cancellation of a policy any refund or premium allowed by
the insurer will be paid to you after deducting our annual commission and fees.
Fees, charges and our remuneration
In return for placing business with insurers, underwriters and/or other product providers,
we generally receive a commission from them which is a percentage of the annual
premium that you are charged. Generally, this is around 10% for motor insurance, 20%
for home and commercial insurances, up to 27.5% for let property or unoccupied
insurance and up to 30% for travel insurance. This is based on the premium before insurer
fees and IPT are added on. We may also occasionally be given a commission overrider or
performance related bonus by an insurer based on growth of a particular account and low
claims ratio. This is not something which affects our duty to you. For arranging premium
instalment facilities, we earn a variable amount of commission from our premium finance
provider which is usually a percentage of the interest that you pay. This means that the
amount you pay for credit and the overall cost of arranging your insurance will vary
according to the interest charged by the lender and the amount of commission we earn.
There may be occasions where there is a choice of instalment payment options which may
charge different interest rates. Typically, we will not receive any commissions from
insurers if policies are placed on direct debit instalment arrangements with the insurer.
We will receive commissions from the premium finance providers.
You are entitled, at any time, to request information regarding any commission which we
may have received as a result of placing your insurance business or arranging premium
finance. Please be assured that the way in which we are remunerated will not at any time
conflict with our responsibilities to meet your needs and treat you fairly.
In addition to the commission paid to us by the insurer and your premium finance provider
(where applicable), we will make an administration charge of £20 for consumer products
and up to £50 on commercial products for the following: new business, renewals & mid
term adjustments. Policy cancellations will be subject to a cancellation fee of £25. In the
event of you cancelling your policy, our commission will also be deducted from any refund
which you may be entitled to.
Commission on a commercial business
In good time before the conclusion of each insurance contract, or upon renewal, we will
remind you of your right to be informed of the level of commission which we receive from
underwriters and premium finance providers. You are entitled, at any time, to request
information regarding any commission which we may have received as a result of placing
your insurance business.
Premium Finance
We may be able to arrange finance for insurance instalments through the insurer or
through a preferred premium finance provider. We act as a credit broker in arranging
premium finance facilities and we will give you further information about this before we
finalise your instalment arrangements.
When we are aware there is an alternative premium finance arrangement available, with a
lower annual percentage rate, for example direct with your insurer, we will let you know.
This will enable you to make an informed decision.
We will not make a specific recommendation or provide you with specific advice, we will
give you the relevant information you require, honestly, fairly and professionally and in a
way that is in your best interests this may include information about one or more
agreements that you may be eligible for, so that you can compare them, which will enable
you to make your own choice about whether to go ahead with any particular finance
agreement.
Important: Using premium finance makes the overall cost of the insurance more
expensive. We will ask you to confirm that you have actively elected (that you have “opted
in”) to pay via premium finance.
A full breakdown of the cost of your insurance and the cost of credit will be provided as
part of your new business or renewal quotation before you make a decision whether to
proceed.
Your agreement will last for 12 months but the premium finance may last for a shorter
period.
If you choose to enter a finance arrangement, your details will be passed to a third party
(insurer or lender) to enable them to contact you and you should contact us at the address
given in this document if you do not want your details passed to that party.
This finance arrangement will be subject to interest charges that we will confirm to you
when providing the full details. Importantly, the arrangement you will enter into will be
with the finance company not us.It is an entirely separate contract irrespective of the
insurance contract. In the event of your failure to meet with the contractual obligations
regarding payment the finance provider could approach the insurer to seek a termination
of the insurance contract to recoup their outstanding finance arrears. You will be liable to
pay their costs and charges if you do not keep up your repayments and cover is cancelled
under your policy. This is because the agreement is between you, the policyholder, and
the finance company direct, not us or the insurer. It is important that you read the finance
agreement that is sent to you before you agree to enter into such an agreement.
For the provision of premium finance facilities, a credit check will be performed if you wish
to use this payment. We do not charge any fees to you for introducing you to a credit
provider.
If you are a consumer as defined under the Consumer Credit Act, you will have the benefit
of a 14-day cooling off period. Please note that we only use Premium Credit Ltd for the
provision of premium finance facilities.
Please Note: Your policy cover will cease if you fail to keep up payments on an
instalment agreement or premium finance facility related to it.
Ending your relationship with us
Subject to your immediate settlement of any outstanding premiums and fees, you may
instruct us to stop acting for you and we will not impose a penalty. Your instructions must
be given in writing and will take effect from the date of receipt. In circumstances where
we feel we cannot continue providing services to you, we will give you a minimum of 7
days’ notice. Valid reasons may include but are not limited to non-payment of premium or
fees, commission clawback by insurers where instructions are given to another party to
handle the customer’s insurance(s), failure to provide requested documentation or
information, deliberate failure to comply with terms set out within the Terms of Business
or insurer’s documentation, deliberate misrepresentation or non-disclosure or attempted
fraud, use of threatening or abusive behaviour or language, or intimidation or bullying of
our staff or suppliers.
Unless otherwise agreed in writing, if our relationship ends, any transactions previously
initiated will be completed according to these Terms of Business. You will be liable to pay
for any transactions concluded prior to the end of our relationship and we will be entitled
to retain commission received for conducting these transactions, together with all fees
charged by us for services provided.
Ownership
There is no ownership between any insurer and ourselves.
Complaints procedure
Should you feel that you have any cause for complaint at any time during or after the term
of your policy, please contact Sean Scanlon or Lorraine Adams in the first instance either
by telephoning the above number or writing to either of them at the above address in
order that the situation can be resolved to your satisfaction.
If we are unable to resolve the issue to your satisfaction by the end of the third business
day following receipt, we will formally investigate the matter. You will receive an
acknowledgement of the matter together with a copy of our complaints process promptly
and certainly within 5 working days. We will then aim to investigate and provide a
resolution as quickly as possible, informing you of a final response no later than 8 weeks.
If you are not happy with our response, or the position after a period of 8 weeks, you may
be eligible to refer your complaint to the Financial Ombudsman Service (FOS) for an
independent assessment and opinion. Access to the FOS is available for complainants
coming within one of the following categories at the time we receive their complaint: 1/
Consumers (private individuals acting for purposes which are wholly or mainly outside that
individuals trade, business, craft or profession. 2/ Micro-enterpirses (businesses employing
fewer than 10 persons and with a turnover or balance sheet total not exceeding £2million.
3/ Other small businesses (with an annual turnover of below £6.5million and less than 50
employees or with an annual balance sheet total of below £5million. 4/ Charities with an
annual income of under £6.5million. 5/ Trustees of a trust with a net asset value of under
£5million. 6/ Certain types of guarantor.
The FOS Consumer Helpline is on 0800 023 4567 (free for people phoning from a “fixed
line” (for example, a landline at home) or 0300 123 9123 (free for mobile-phone users
paying monthly charge for calls to No’s starting 01 or 02). Alternatively, you can contact
them at Financial Ombudsman Service, Exchange Tower, Harbour Exchange Square,
London, E14 9SR. www.financial-ombudsman.org.uk
A full copy of our complaints procedure is available on request.
Financial Services Compensation Scheme (FSCS)
If we are unable to meet our obligations, you may be entitled to compensation from the
FSCS. If we have advised or arranged insurance for you this will be covered for 90% of a
claim, without any upper limit, however claims under compulsory insurance, professional
indemnity insurance and certain claims for injury, sickness or infirmity of the policyholder
are protected at 100%. Further information is available from the FSCS helpline on 0800
678 1100 or 020 7741 4100 and www.fscs.org.uk.
The FSCS is the UK’s statutory fund of last resort for customers of authorised financial
services firms. Compensation is usually payable if an authorised firm is unable or unlikely
to pay claims usually because it has ceased trading or become insolvent.
Your Data
We aim to process your data responsibly, fairly and in strict accordance with the General
Data Protection Regulations (GDPR) and The Data Protection Act (DPA) 2018.
The GDPR modernised data protection law requiring enhanced disclosures about what we
do with your information including (but not limited to): Our lawful bases of processing;
The information we collect, and how we use and share that information; How long we
keep information, including the purposes (e.g., administer your policy); The technical and
organisational measures we have in place to safeguard your information; Your individual
rights; and Our approach to marketing.
As with many organisations, and to ensure Customers can easily access details on the
areas listed above, we have developed a separate Privacy Notice which can be found on
the following page
It is vitally important to take time to read our Privacy Notice carefully as it contains full
details of the basis on which we will process (i.e., collect, use, share, and or transfer) and
store your information. If you have any questions, including obtaining a copy of our
Privacy Notice, or any further information about our approach to the GDPR you can write
to us at the above address, contact us by email: westnorfolkinsurance@gmail.com or
telephone us: 01553 774301.
Combating Financial Crime
We are obliged to conduct reasonable due diligence to protect you and us against the risk
of financial crime. We may require you to provide evidence to assist us with verifying your
identity and any payment details you provide to us to ensure that the transactions that we
conduct on your behalf are legitimate.
Neither party shall be involved in the offering, promising or giving of any financial or other
advantage to any person in breach of any applicable anti-bribery laws (including the
Bribery Act 2010). We are obliged to report evidence or suspicion of financial crime to the
relevant authorities at the earliest reasonable opportunity and may be prohibited from
disclosing any such report to you.
We shall not provide any services, provide any benefits, or make any payments to any
client that is the subject of any trade and economic sanctions or embargos or provide
services to any client located, organised in or resident in a country or territory that is the
subject of comprehensive country sanctions.
We will carry out checks of the consolidated list of financial sanctions targets designated
by the United Nations, The European Union and the United Kingdom and maintained by
the Office of Financial Sanctions (OFSI) for all customer transactions. If sanctions apply we
are obliged to report the transaction to the relevant authorities and, in such cases, we
shall not make any further payments or process already notified claims and insurers may
invoke cancellation rights to terminate affected insurance contracts.

V.3 December 2025