|Dear Member ,|
We are preparing a briefing document on all queries that have arisen from members in the last ten days on the Covid 19 crisis. We hope to send this to you in the next 24 hours.
Latest Government Measures
One of the issues that requires immediate information is the question whether Brokers are able to open their offices this morning (25 March 2020) i.e. are they providing an essential service requiring staff to attend their offices? We have lobbied Government and the Central Bank on this matter and while we await definitive guidelines which we have been advised should be clarified later today by the HSA, brokerages would be included in the category referred to by Chief Medical Officer, Dr Tony Holohan when he said: “People should only leave home to go to work where attendance at a workplace is essential.”
Although no offices have been specifically asked to close, there is personal responsibility on employers in terms of ensuring a clean work environment, physical distancing etc. The key guidelines which should be considered (not meant to be an exhaustive list):
- Can your staff work from home? – if so, they should.
- Is your office set up to maintain social distance (2 metres between staff / consumers, etc.)?
- Is any of your staff in higher risk groups (pre-existing medical issues/age)?
- Is their work an essential service to consumers (e.g. renewal of policies etc.) which can’t be deferred?
Remember that in addition to complying with government regulations, you have a legal obligation to provide a safe place of work to your employees and must take steps to ensure that they do not contract COVID 19 as a result of coming to work. Your attention is drawn to the following official information, which is a link to the letter from the Chief Medical Officer to the Minister :
https://twitter.com/SimonHarrisTD/status/1242482772028952577/photo/2. These measures have now been put in place until 19 April 2020.
It has been stipulated that certain specified retail and other outlets are to close. This is an official list of essential retail outlets that includes Banks, post offices and credit unions. An omission from this list is the insurance sector, including Brokers:
Brokers Ireland has sought confirmation from relevant parties as to whether there will be clarity on the position to be adopted by Brokers. Pending our receiving such further information to relay to Members, we draw your attention to the speech yesterday by An Taoiseach, which taken with the letter from the Chief Medical Officer, may provide guidance.
An Taoiseach has said, without specifically mentioning insurance: “I am asking you to stay home if at all possible….So, you should only leave home to go to work if you can’t work from home and your attendance is essential”.
Brokers, as employers, must carefully consider what attendance in the workplace by staff is essential for your businesses. Keep in mind, at all times, that employers have a legal obligation to provide a safe place of work for all their employees and that consideration as to what is and is not essential should take account of this ongoing duty.
One interpretation of all this is that the specified sectors will have to close, others are definitely deemed essential and can open. All other businesses have to make judgement calls – work from home if at all possible and if you want to open, assess the risk to your staff and consumers and the necessity of the work. We will clarify this matter as soon as possible and email you.
Commission Summary / Remuneration Disclosure Regulations
On other key issues, we have contacted the Central Bank about the commission summary / remuneration disclosure regulations and other annual return deadlines coming on 31 March and we expect their decisions shortly. In the meantime, you should make as much progress with these regulatory requirements as you can and document the reasons why you can’t complete them by the end of this month (if applicable). Again we will email you as soon as we have clarity on these issues.
We are working hard on your behalf to clarify all issues Brokers have. You will appreciate that in a fast moving crisis, with complex and unprecedented issues, this can take some time. Rest assured, we are tackling these matters with Government, Central Bank, Insurers and Life Offices. If you have any further matters you wish us to raise, please email:
Life/Financial Services firstname.lastname@example.org
General Insurance email@example.com
Compliance / Central Bank firstname.lastname@example.org
We hope to email you with further information on Covid 19 issues for the Broker sector in the next 24 hours.