Other Business Activities and Conflict of Interest

The potential for conflict of interest should be considered as a part of the application process for licensing as well as ongoing licensed practice.

Conflict of Interest exists when there is a risk that a licensee’s loyalty to, or representation of, a client, an insurance company, or other principal could be materially or adversely affected by a licensee’s own interests or by a licensee’s duty to another client, former client, insurance company, or other third party. 

Examples of conflict of interest may arise where a licensee:
  • Has a personal, private, financial, or professional interest that could prevent the licensee from being able to objectively exercise their responsibilities to a client, principal, or insurance company. 
  • Engages in other employment or business activity (paid or unpaid) that may include real or perceived positions of power or trust.
  • Is in a position that could take advantage of a consumer’s inexperience, age, lack of sophistication, lack of education, language barrier, or ill health. 
Insurance licensees are expected to abide by the Conflict of Interest Guidelines for Insurance Agents, Adjusters, and Salespersons (Appendix A) in the Insurance Council's Code of Conduct.

Council Rule 7(11.2), which came in to effect on July 1, 2023, prohibits licensees from engaging in insurance business for a strata corporation where there is common ownership between the licensee and a corporation, business or other entity that provides strata management services. Common ownership includes ownership arrangements involving holding companies, immediate family, and significant individuals. For more information, licensees can refer to Notice ICN 23-001 | Conflict of Interest in Strata Insurance Business as it outlines licensees duties and obligations relating to this rule.

Impact of Other Employment/Business Activities on Licensing

The Insurance Council has identified a number of business activities where the potential for a conflict of interest is so significant it is either not prepared to issue a licence, or in other cases, requires conditions or restrictions on the licence to address the conflict. 
  • Licence applicants should review the List of Other Employment and Business Activities Considered by Council before starting the licence application process so that they are aware that a business activity may prevent them from obtaining a licence. Licence applicants are required to disclose their other employment and/or other business/volunteer activities when submitting their licence application to Insurance Council.
  • Current Licensees should review the List of Other Employment and Business Activities Considered by Council and the guidelines periodically by considering whether their Business Activity is similar to one on the list and if so, take reasonable steps to identify and avoid or manage conflicts of interest accordingly. Review Frequently Asked Questions regarding other business activities for more information.
The list of Other Employment and Business Activities Considered by the Insurance Council does not cover every possible conflict of interest scenario. To request a review and guidance regarding your other business activities, please submit a Request for Review of Other Business Activities form.

Frequently Asked Questions - Other Business Activity

You don’t have to notify Council, if it’s not a business activity similar to one on the List where Council has declined to issue a licence.
Even if your business activities are not on the List of Other Employment and Business Activities Considered by Council, use discretion to ensure they do not have the potential to create a conflict of interest. Review Insurance Council Code of Conduct's Conflict of Interest Guidelines (Appendix A) periodically on how to plan for and address situations when a conflict of interest arises, and how to manage or avoid such conflicts.
Immediately notify Council using the Request for Review of Other Business Activities form. Council will review and determine an appropriate course of action.
  • Immediately modify your insurance activities in accordance with the licence conditions outlined in the List:
    • If a complaint arises that is related to the business activity, directly or indirectly, licensees who do not modify their insurance activities could have their suitability reviewed.
    • If licensees are found to have acted in a conflict of interest based on their business activity, they can be subject to disciplinary or other action as warranted.