Insurance Europe welcomes the opportunity to provide feedback on the International Association of Insurance Supervisors (IAIS) draft issues paper on conduct of business risk and its management.

As a general remark, Insurance Europe wishes to stress that the European insurance industry supports the overall aim of the IAIS to raise awareness about conduct of business risks. In this context, Insurance Europe duly acknowledges that the list of the conduct of business risk presented in the paper is comprehensive.

However, while the draft paper constitutes a catalogue of theoretical problems associated with the conduct of business, it gives little consideration to the measures that supervisors, insurers and intermediaries already apply to mitigate these risks or the natural tendency in free markets for consumers to gravitate towards producers offering better-quality products and services. Additional examples, initiatives, evidence and statistics would make the paper stronger.