Ethics, Rules of Conduct and Professionalism Flashcards
(107 cards)
1
Q
Why do you want to become a member of RICS?
Level 1
A
Gold standard of excellence
- Status - Your professional credentials provide unrivalled client and market confidence
- Recognition - Promotion of your professional excellence to governments and markets
- Market advantage - RICS status and standards give you a competitive advantage
- Knowledge - International practice standards, professional guidance, CPD and knowledge sharing
- Network - Access to 134,000 RICS professionals worldwide
2
Q
What is the role of RICS?
Level 1
A
The 3 main roles are:
1) To maintain the highest standards of education and training.
2) To be leading source of information and independent advice on land, proeprty, construction and environmental issues.
3) To protect consumers through strict regulations and professional standards, and
3
Q
What is a Royal Charter?
Level 1
A
Royal Charters are granted by The Sovereign on the advice of the Privy Council and means they have a seat to advise the Crown. It requires members to promote the profession for public benefit.
RICS was created in 1868 and received royal charter in 1881.
4
Q
Who is the current RICS president?
Level 1
A
Ann Gray FRICS
5
Q
What do you understand by the term self-regulation?
Level 1
A
RICS self-regulates, meaning that it operates within it’s own published regulatory framework, rather than being legislated by Government.
6
Q
What is a Bye-Law?
Level 1
A
A rule made by RICS to control the actions of its members, underpinning the Rules and Regulations set out by the RICS (10 bye-laws)
7
Q
Give an example of one of the RICS Bye-Laws.
Level 1
A
BYE-LAW 5: CONDUCT - e.g. Every Member shall:
(a) conduct himself in a manner befitting membership of RICS
8
Q
Explain to me the new RICS Rules of Conduct - what do they replace? When do they take effect? Who do they relate to?
Level 1
A
The new Rules replace the previous version which had been in place for members and firms since 2007. Take effect 02 February 2022. They apply to RICS members and firms.
9
Q
What are the 6 ethical principles that the Rules of Conduct are based on?
Level 1
A
- Honesty
- Integrity
- Competence
- Service
- Respect
- Responsibility
10
Q
What are the 5 Rules? Give an example behaviour for each.
Level 1
A
- Members and firms must be honest, act with integrity and comply with their professional obligations, including obligations to RICS - Members and firms are open and transparent with clients about their fees and services.
- Members and firms must maintain their professional competence and ensure that services are provided by competent individuals who have the necessary expertise - Members and firms only undertake work that they have the knowledge, skills and resources to carry out competently.
- Members and firms must provide good-quality and diligent service - Members and firms agree with clients the scope of the service to be provided and its limitations, and timescales for the work.
- Members and firms must treat others with respect and encourage diversity and inclusion - Members and firms do not bully, victimise or harass anyone.
- Members and firms must act in the public interest, take responsibility for their actions and act to prevent harm and maintain public confidence in the profession - Members and firms respond to complaints made against them promptly, openly and professionally.
11
Q
What are the core professional obligations of firms and members to RICS?
Level 1
A
Members
1. Members must comply with the CPD requirements set by RICS.
2. Members must cooperate with RICS.
3. Members must promptly provide all information reasonably requested by the Standards and Regulation Board, or those exercising delegated authority on its behalf.
Firms
1. Firms must publish a complaints-handling procedure, which includes an alternative dispute resolution provider approved by RICS, and maintain a complaints log.
2. Firms must ensure that all previous and current professional work is covered by adequate and appropriate professional indemnity cover that meets the standards approved by RICS.
3. Firms with a sole principal must make appropriate arrangements for their professional work to continue in the event of their incapacity, death, absence from or inability to work.
4. Firms must cooperate with RICS.
5. Firms must promptly provide all information reasonably requested by the Standards and Regulation Board, or those exercising delegated authority on its behalf.
6. To display on business literature that they are regulated by RICS.
7. Firms must report to RICS any matter that they are required to report under the Rules for the Registration of Firms.
12
Q
What disciplinary procedures can the RICS impose? In what circumstances can these be imposed?
Level 1
A
Head of Regulation can initiate one of the FOUR if required:
1) Serve a Fixed Penalty Notice
2) Make a Regulatory Compliance Order
3) CPD Sanctions
4) Refer to Disciplinary Panel for consideration
Not every shortcoming will necessarily give rise to a disciplinary – A member may need to justify the steps taken
A disciplinary can be triggered by someone complaining to the RICS – Can be Client or 3rd Party
13
Q
When did RICS last update their disciplinary panel rules? What are the different levels of action within these procedures?
Level 1
A
2019 October
The THREE levels of disciplinary are:
1) Action by Head of Regulation
2) Regulatory Tribunal
3) Appeal Panel
14
Q
What money laundering regulations or legislation are you aware of?
Level 1
A
The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended.
15
Q
What is a red flag of money laundering?
Level 1
A
1) Secrative about source of funds, identity and reason for transaction
2) PEP
3) Has criminal associations
4) Avoids contact for no good reason
5) Large cash payments
6) Willing to pay high fees
16
Q
What bribery legislation are you aware of?
Level 1
A
Bribery Act 2010
17
Q
What is a bribe?
Level 1
A
An inducement or reward offered, promised, or provided to gain commercial, contractual or personal advantage
18
Q
What are the penalties for accepting a bribe?
Level 1
A
Unlimited fines, and individuals can receive a jail sentence of up to 10 years.
19
Q
What are the penalties for being involved in money laundering?
Level 1
A
Money laundering under the Proceeds of Crime Act 2002 carries a jail sentence of up to 14 years or a large fine.
20
Q
What constitutes an offence under the Bribery Act 2010?
Level 1
A
- Bribing another person
- Being Bribed
- Bribing a public foreign official
- Failure by a commercial organisation to prevent bribery
21
Q
What constitutes an offence under the current money laundering
regulations?
Level 1
A
1) Tipping off someone who is under suspicion
2) Assisting a criminal to obtain, hide or invest funds
3) Failing to report knowledge or suspicion
22
Q
How long should you keep anti money laundering records for?
Level 1
A
You must keep your records for five years beginning from: the date a business relationship ends. the date a transaction is completed.
23
Q
What is Professional Indemnity Insurance (PII)?
Level 1
A
Protects you against claims for loss or damage made by clients or third parties as a result of the impact of negligent services you provided or negligent advice you offered
24
Q
Can you tell me about the RICS requirements in relation to PII?
Level 1
A
UK Professional Indemnity Insurance requirements - Version 9 (effect 1st April 2022)
- Firms must have adequate and appropriate PII insurance in place.
- This can be on an ‘each and every claim’ or ‘aggregate basis’
Minimum Cover required based on turnover:
- £100k or less = £250,000
- £100,001 - £200,000 = £500k
- £200,001< = £1,000,000
Maximum Level of Uninsured excess based on turnover for previous year:
- £10,000,000 or less = The greater of 2.5% of the sum insured, or £10,000
- £10,000,000 or more = No limit set
25
What is a PII aggregation clause?
## Footnote
Level 1
A clause which governs what happens if there is more than one claim in the same year.
26
What does ‘claims made’ mean in terms of PII?
## Footnote
Level 1
Claims Made is a term used to describe an insurance policy which only provides cover for claims which are notified during the term of the policy. This is not necessarily the same time period when the actual incident or error causing the claim occurred.
27
In a negligence claim, what would help to show that you acted with
consideration and due process?
## Footnote
Level 1
1. Provide full details and records of meetings and conversations
2. Show evidence of advice and recommendations
28
Can good record keeping help to provide a defence in a PII claim?
## Footnote
Level 1
Yes good record keeping can assist in the defence of negligence.
29
If you were providing services outside of your usual scope to a client,
what might you need to do in relation to your PII cover?
## Footnote
Level 1
1. Inform your PII insurer to update your additional liability
2. You cant carry out work that isn't covered under PII cover
30
What is run off cover?
## Footnote
Level 1
Run off cover is insurance which covers historical liabilities after it ceases to trade (minimum of 6 years)
31
What RICS requirements are there relating to run off cover?
## Footnote
Level 1
RICS expect run off cover for minimum of 6 years
32
What changes did RICS recently make to the Minimum Approved PII Wording?
## Footnote
Level 1
Following consultation, the excess requirements for larger firms have been removed, whilst the 2.5% maximum excess requirements for smaller firms remains
33
What precedent has caselaw set in terms of keeping adequate site notes
(and therefore providing a defence in a PII claim)?
## Footnote
Level 1
A surveyor should make notes on site and subsequently give these further reflective consideration when using them as the basis of his actual report. This is instead of dictating the report during an inspection because it is contrary to the relevant RICS guidance.
34
Would a dictated report avoid the need to have any written site notes?
## Footnote
Level 1
No, as found in the case of Watts v Morrow.
35
How long can a PII claim arise after the work is undertaken?
## Footnote
Level 1
A claim can be brought up to six years after the work was completed or three years after the client could reasonably be expected to know they had a claim.
36
What is the Assigned Risks Pool (ARP)?
## Footnote
Level 1
The ARP is open to all UK RICS regulated firms that are unable to obtain PII, which meets the minimum requirements of the RICS, in the insurance market
37
Who might need to access the ARP?
## Footnote
Level 1
firms that are unable to obtain PII
38
Explain your understanding of the RICS Guidance Note Risk, Liability and
Insurance (1st Edition).
## Footnote
Level 1
It is s intended to assist both RICS-regulated firms and their clients to understand the main risks and liabilities associated with professional services provided by RICS members. It guides firms in the negotiation of equitable contracts with clients and the avoidance of major risks and pitfalls.
39
Explain when you might agree a liability cap.
## Footnote
Level 1
RICS-regulated firms who are no longer able to obtain insurance for risks
relating to fire or where they are providing a valuation in reliance on an EWS1 form may also seek to exclude liability for any claims that would be caught by such exclusions.
40
How would set out third party reliance in Terms of Engagement?
## Footnote
Level 1
State that the advice may only be relied upon by the named client
41
What are the three key terms that should be considered from a risk
perspective in the context of every instruction you undertake?
## Footnote
Level 1
1. The scope of the work.
2.The basis on which the fee will be calculated.
3.The liability cap.
42
Tell me about your companies CHP.
## Footnote
Level 1
My companies complaint handling procedure is in line with RICS Guidance:
1. I would notify my Complaints Handling Officer who would request details of complaint in writing.
2. They would then acknowledge the complaint within 7 days.
3. Within 28 days inform the complainant of the outcome
4. If dissatisfied a secondary partner will conduct a review and respond within 15 days
5. If still dissatisfied then independent RICS redress mechanism is DRS (Mediation)
6. If still dissatisfied then Surveyors Arbitration scheme
43
Tell me what you understand about Complaints Handling Procedures (CHP).
## Footnote
Level 1
Process of dealing with a complaint - RICS Guidance 'Complaints Handling' 2016 (updated 2022).
- Must be fit for purpose
- Readily shared with complainants
- Understood by all staff
- Regularly reviewed at senior level
44
When and how can the RICS be involved in a complaint about a firm or
member?
## Footnote
Level 1
RICS will become involved if a member fails to respond to a claim or prevents the party gaining access to an independent redress mechanism.
45
Can you tell me about the CPD requirements for members of RICS?
## Footnote
Level 1
All members must complete 20 hours of CPD activities by 31 December. You have until 31 January to record your completed activities online. At least 10 hours must be formal CPD. Must maintain understanding of RICS professional and ethical standard during rolling 3 year periods
46
Why is CPD important?
## Footnote
Level 1
Requires members to continually update their skills and knowledge in order to remain professionally competent.
47
Tell me about the RICS’ guidance on dealing with Conflicts of Interest.
## Footnote
Level 1
RICS Conflict of Interest, March 2017 (effective January 2018) - Professional Statement
Outlines 3 types of conflict
1. Party Conflict
2. Own Interest Conflict
3. Confidential Information Conflict
48
What is double dipping (dual agency)?
## Footnote
Level 1
Acting for both parties (buyer and seller)
49
How would you close down a regulated firm?
## Footnote
Level 1
1. Inform RICS of retirement/closure
2. Ensure clients are informed and hand over arrangements to new firm
3. Return any monies held by clients to own accounts
4. Inform insurers and procure PII run off cover for minimum of 6 years
5. Retain copy of client files and records for minimum of 6 years.
50
What can you tell me about RICS guidance relating to bribery, corruption
or money laundering? What status does it hold? What are some of the key principles of this guidance?
## Footnote
Level 1
- 'Countering bribery and corruption, money laundering and terrorist financing'
- Professional Statement (Mandatory)
- General content requires RICS Registered Firms to not accept bribes, conduct written risk assessment for firms, provide staff training, ensure record keeping, and should have the necessary systems in place.
51
What are the current RICS rules for registration of firms?
## Footnote
Level 1
The Rules are made by the Standards and Regulation Board, they set out:
1. Which Firms are required to register with RICS for regulation
2. Circumstances in which a Firm is eligible to apply for regulation, even though it is not required to do so
3. The procedure for registration, deregistration and appeal and
4. Together with the Rules of Conduct, the obligations of registration.
52
What is a phoenix firm?
## Footnote
Level 1
Firms which close in a disorderly way and then rapidly re-establish themselves as a new trading entity
53
When must a firm register for regulation? What are the registration eligibility criteria? Who is a Responsible Principal?
## Footnote
Level 1
A Firm is required to register for regulation by RICS if:
1. the Firm provides surveying services to the public;
2. the Firm is operating in Regulated Area A (UK);
3. at least 50% of the Firm’s Principals are RICS Members.
A Firm is eligible to register for regulation by RICS if:
1. The Firm provides surveying services to the public and
2. At least 25% of the Firm’s Principals are RICS Members
A responsible person is a person who ensures the Firm complies with its regulatory and statutory obligations.
54
What are the rules around use of the RICS logo and ‘Regulated by RICS’
designation? When did these rules last change?
## Footnote
Level 1
As a qualified RICS member, you have the right to use the logo for personal use, whether you are a partner, director or employee.
Effective from February 2022
55
Tell me about the restrictions to the use of the designation ‘Chartered
Surveyors’ by firms.
## Footnote
Level 1
The designation is intended to be subtle, while showing the public that they can trust your firm to work to the highest ethical and professional standards.
56
What must be included in ToE relating to firm regulation?
## Footnote
Level 1
Complaints Handling Procedure
57
What is a locum and who might need one?
## Footnote
Level 1
A locum is effectively another professional who is appointed to ‘stand in’ for the surveyor if they are unable to work, e.g. in the event of an accident/illness, unforeseen circumstances, prolonged absence (e.g. holiday or a sabbatical) or death.
Needed by a Firm which has a sole principal (i.e. a sole practitioner or a sole director in a corporate practice)
58
How could a sole trader set up their CHP using a locum?
## Footnote
Level 1
In the usual course of business, a locum may be appointed by a sole practitioner as their complaints handling officer to ensure that their Complaints Handling Procedure can be run fairly and impartially.
59
What RICS guidance relates to handling client money? When was this last updated?
## Footnote
Level 1
Client money handling Professional Statement effective 1 January 2020
60
What do the RICS Rules of Conduct say about client money?
## Footnote
Level 1
Within Rule 1 - Honesty and Integrity the rules state that:
1. Firms keep clients money safe and have appropriate accounting controls
2. Members do not misuse client money and comply with controls intended to keep it safe
61
Explain your understanding of the RICS Scheme Rules relating to client
money protection.
## Footnote
Level 1
RICS runs a Clients Money Protection Scheme:
Provides last resort protection where a RICS regulated firm is unable to repay clients money. There are limits and exceptions set out in the rules.
62
What are the main schemes available to firms relating to client money?
## Footnote
Level 1
' Client Money Protection for Surveying Services'
63
What is the current compensation limit?
## Footnote
Level 1
The current compensation limit is £50,000 per claim, which must be made within 12 months of a loss occurring.
64
What does the annual regulatory review fee relate to?
## Footnote
Level 1
Firms who hold clients’ money pay an annual regulatory review fee, depending on the number of directors or principals the firm has.
65
What might client money include? How does this differ to office money?
## Footnote
Level 1
Rent.
It is not the firm's money and needs to be repaid to the client.
66
What are some of the key principles of the RICS Professional Statement
relating to client money protection?
## Footnote
Level 1
1. Client accounts must be kept seperately and identifiable
2. Client must be able to have their money on demand
3. Accurate records are kept with a running balance sheet
67
Explain the key themes from the RICS Futures 2020 Report.
## Footnote
Level 1
We are in a period of transition and change to our sector.
RICS to help navigate this change, the report touches on points such as building roads out of plastic and adopting drone technology.
68
Explain the potential implications of the Hart v Large case
## Footnote
Level 1
In this case the missed defects, failure to advise further investigations and lack of advise to obtain a PCC that led to the court assessing damages on a much broader scale (rather than just assessing the damages based on the actual value of the proeprty and the price paid).
Surveyors must be clear and advise clients on level of survey, scope of inspection, limitations and caveats.
Surveyors must recommend justifiable further investigation.
Consider if new information will affect advise after reporting and update if need to
69
Explain your understanding of precedent set in Burgess v Lejonvarn.
## Footnote
Level 1
Established that professional working pro bono and without contract owe a duty of care in tort to act in reasonable care and skill for services they provide. However not under a duty to advise or give warnings.Also are not liable for work they do not do.
70
What do RICS set out as good practice for the use of social media in their
Regulation document (June 2021)?
## Footnote
Level 1
RICS is more likely to start investigations into social media posts that:
• are discriminatory
• are dishonest
• are abusive or threatening, or likely to cause significant harm, distress or offence to a person
• bully, harass or victimise a person or people
• show a pattern of frequent or a large number of concerning communications
• ignore previous advice or warnings about concerns.
RICS is unlikely to start investigations about social media posts that:
• are critical of an organisation or its policies and performance, rather than individuals
• use professional and respectful language
• are removed if a member receives a request to do so
71
Explain your understanding of the RICS Levitt review.
## Footnote
Level 1
Alison Levitt was appointed to conduct an independent review, which focused on issues raised following the commissioning by the RICS Audit Committee of a Treasury Management Audit in 2018.
Aim was to investigate articles in the press that alleged that RICS ‘tried to supress a critical internal report into its finances in 2018/2019 and then unfairly dealt with those who sought to explore the issue’.
The outcome of the review is that governance principles were not followed by RICS. A key factor was lack of clarity around roles and responsibility of the various RICS boards, senior leadership and management. - Lack of scrutiny over actions of the CEO and COO. Power struggle rather than cover up.
There were 18 recommendations set out. Included Governance, executive remuneration, whistle blowing and legal advise.
72
What is whistleblowing?
## Footnote
Level 1
A person, often an employee who reveals information about activities taking place which is deemed illegal, immoral, illicit or unsafe (wrongdoing).
73
What does good governance mean to you?
## Footnote
Level 1
Good governance is where the governing body is able to work harmoniously to set and execute strategies, selecting and supporting leadership to deliver that strategy.
74
What are the key values of the interim Governing Council statement
relating to ethics, behaviour and culture?
## Footnote
Level 1
Post Levitt Review
1. Integrity
2. Transparency
3. Inclusion
4. Collaboration
5. Advocacy
6. Passion
75
Explain what the Pandora Papers are and the ethical issues raised within
them.
## Footnote
Level 1
The pandora papers are the largest ever leak of documents and files revealing how a global network of offshore companies, trusts and financial mechanisms are enabling wealthy individuals to avoid tax, and in some cases reportedly to also engage in criminal activities such as money laundering. There are also fears that the UK property market is being targeted by investors who are buying valuable properties through offshore companies to conceal their ownership and avoid taxation.
76
Explain what you understand by the RICS Bichard Review. How will these recommendations be implemented by RICS?
## Footnote
Level 1
Lord Michael Bichard has published his independent Bichard RICS Review which was commissioned by the RICS Governing Council to review the Institution’s purpose, governance and strategy.
The RICS Governing Council has strongly endorsed the report and recommendations which aim to hand decision-making to members and ensure the Institution’s activities are centred on the public advantage.
Five new working groups being established to take the recommendations forward.
77
Explain some of the recommendations of the Bichard Review.
## Footnote
Level 1
RECOMMENDATION 4: S Matrics should be re-invigorated to give younger members a stronger voice in the Institution, including by allowing an appropriately selected representative from the community of younger members to sit on Governing Council, and participation by younger members should be encouraged throughout the whole RICS governance structure.
78
How do professional integrity and professional ethics differ?
## Footnote
Level 1
Ethics can be defined as rules and regulations that have been formed which allow an individual to work in accordance to moral principles.
Integrity can be defined as the quality of being honest and fair.
79
What is modern slavery and how would you identify red flags of it?
## Footnote
Level 1
Severe exploitation of other people for personal or commercial gain.
Red Flags include: False documentation, multiple property purchases of low value housing, excessive increase or decrease in property value. Many red flags will link with AML.
80
Explain the implications of the Sanctions and Anti-Money Laundering Act
2018.
## Footnote
Level 1
Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018) was passed to allow the UK to impose economic and other sanctions, and money laundering and terrorist financing regulations once it left the EU at 11pm on 31 December 2020.
81
What are the six RICS values published as a result of the Levitt review?
## Footnote
Level 1
1. Integrity
2. Transparency
3. Inclusion
4. Collaboration
5. Advocacy
6. Passion
82
Explain the impact of the Economic Crime (Transparency and Enforcement) Act 2022.
## Footnote
Level 1
A Bill to Set up a register of overseas entities and their beneficial owners and require overseas entities who own land to register in certain circumstances; to make provision about unexplained wealth orders; and to make provision about sanctions.
83
How do you ensure that you comply with bribery legislation?
## Footnote
Level 2
By not accepting bribes.
84
How do you ensure you comply with money laundering regulations?
## Footnote
Level 2
Carry out AML checks using internal system credus.
85
How do you ensure you comply with your firm’s bribery and gifts policy?
## Footnote
Level 2
86
Tell me about what you would do if you felt that an instruction was outside your scope of experience or knowledge.
## Footnote
Level 2
Decline the job.
87
How would you keep client’s money securely and safely held?
## Footnote
Level 2
I would ensure the word Client is on the account name and that the monies are available on demand. I would ensure that a running balance is kept and annual audits carried out by accountant employed by RICS.
88
Tell me about how you would handle a client complaint.
## Footnote
Level 2
1. I would acknowledge receipt of complaint
2. Notify my Complaints Handling Manager
89
Tell me about your understanding of your firm's process for escalating a complaint to Alternative Dispute Resolution (ADR).
## Footnote
Level 2
If the complainant was dissatisfied with the Complaint Handling Officers full response and the independent partner secondary review. The company could then try and settle via RICS independent redress mechanism, this could be mediation and then arbitration.
90
Tell me about a conflict of interest check you have carried out.
## Footnote
Level 2
I undertook a Conflict Check for my valuation of 29 St James's Street which resulted in no conflicts of interest.
91
If you identified a potential or actual conflict of interest, how could you handle this?
## Footnote
Level 2
1. Conflict Avoidance - Decline the instruction
2. Conflict Management - Accept but manange process by putting in palce information and ethical barriers - Must obtain informed consent from all aprties in a transparent manner
92
How have you ensured all Matrics events are accessible, diverse and inclusive?
## Footnote
Level 2
All events are open to everyone to attend and I am have no control over who registers to attend which removed bias.
Not all events for example are social/networking events which involve drinks.
Feedback is taken from events anonymously and them implemented for future events.
93
How do you ensure you act with integrity when promoting your business?
## Footnote
Level 2
Ensure you do not target work where other firms are instructed, if known.
94
Give me an example of when you have acted with integrity?
## Footnote
Level 3
When targeting work through business generation I have sent letters to owners of properties but caveated the letter by saying 'provided you have not instructed someone else' I would be glad to act for you.
95
Tell me about when you have provided a high standard of service.
## Footnote
Level 3
96
Tell me about how you have promoted trust in the profession.
## Footnote
Level 3
97
Explain how you have taken responsibility in your current role.
## Footnote
Level 3
98
Tell me about how you treat clients with respect.
## Footnote
Level 3
99
Tell me about how you treat other surveyors with respect.
## Footnote
Level 3
100
Explain the key steps you would take if you decided to set up in practice as a sole trader after qualifying.
## Footnote
Level 3
* Inform RICS
* Appoint a Contact Officer
* Register with RICS for Regulation
* Arrange Professional INdemnity Insurance
* Set up Client Account for handling Client Money
* Set up a complaints handling procedure
* Set up staff training and CPD
101
If a prospective purchaser offered you a financial incentive to accept their offer, explain how you dealt with this.
## Footnote
Level 3
102
What would you do if you were asked by a client to reduce a fee proposal to win new work?
## Footnote
Level 3
I would consider if the job would remain profitable and potentially look at reducing my scope of service to reflect the fee change.
103
What would you do if you became suspicious that a client was involved in money laundering?
## Footnote
Level 3
104
What would you do if you became suspicious that a client was involved in terrorist activities?
## Footnote
Level 3
105
If you were to set up in practice on your own, tell me about the types of insurance you would need.
## Footnote
Level 3
PI Insurance
106
Worthing – how did you identify and deal with the conflict of interest? Why could you not set up an information barrier?
## Footnote
Level 3
When we were informed of the tenant's name, I made the necessary people aware that that person was known to me.
An information barrier was not suitable because of how close my interest was with the tenant, being a family member.
107
Brighton – why could you not share your valuation? Who did you have a duty of care towards?
## Footnote
Level 3
My duty of care was to the client and their customer, not the selling agent.
