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Distributor's Code of Conduct

This page is an English translation of the Italian original, provided for convenience. In case of discrepancy, the Italian version prevails.

SOTHIS S.r.l. distributes insurance products in compliance with the duties of fairness, transparency and suitability of the offer set out in the Italian Private Insurance Code (Legislative Decree 209/2005) and in IVASS Regulation no. 40/2018. This page summarises the main conduct obligations observed towards the client; full detail is set out in the Modulo Unico Precontrattuale (Single Pre-contractual Information Form), handed over before any proposal or contract is signed.

1. How SOTHIS operates towards the client

SOTHIS S.r.l. acts in the name and on behalf of the appointing insurance undertakings, under an agency mandate, and not on the client's instructions. It distributes insurance products on behalf of HDI Assicurazioni S.p.A. (non-life classes, including motor liability, and life classes) and, for surety and guarantee classes only, through a horizontal cooperation agreement with the freedom-to-provide-services (FOS) intermediary Delta Prima Broker EOOD, pursuant to article 22(10) of Decree-Law 179/2012 and article 42 of IVASS Regulation no. 40/2018. Where such cooperation applies, the client is always informed in advance of the identity of all intermediaries involved in the distribution of their contract, who are jointly and severally liable for any damage caused.

The names of the insurers with which SOTHIS has, or may have, business relationships are published on the website and can be requested at any time.

2. Analysis of the client's demands and needs

Before the contract is concluded, SOTHIS identifies the policyholder's insurance demands and needs through a dedicated questionnaire, pursuant to article 119-ter, paragraphs 1 and 2, of the Italian Private Insurance Code, and assesses the consistency of the proposed contract with them.

3. Information provided before signature

SOTHIS provides the client, in a clear and comprehensible form, with objective information on the product — features, duration, costs and limits of cover — including by handing over the DIP, the additional pre-contractual information document (DIP aggiuntivo) and the policy conditions, in compliance with the transparency rules of article 119-bis, paragraph 7, of the Italian Private Insurance Code.

For insurance-based investment products (IBIPs), distribution takes place without advice: SOTHIS obtains information from the client on their knowledge and experience of investments and assesses the appropriateness of the product pursuant to article 121-septies of the Italian Private Insurance Code, and also provides the Key Information Document (KID, Regulation (EU) 1286/2014) and the additional pre-contractual information document referred to in article 185 of the Code.

4. Conflicts of interest

SOTHIS S.r.l. does not hold, directly or indirectly, a shareholding or voting rights of 10% or more in any insurance undertaking; conversely, no insurance undertaking (nor any of its parent companies) holds a shareholding or voting rights of 10% or more in SOTHIS. SOTHIS distributes contracts with no contractual obligation of exclusivity towards one or more insurers, and does not provide advice based on a fair and personal analysis of the market.

5. Remuneration policies

For its intermediation activity, SOTHIS receives commission-based remuneration paid by the appointing insurers, included in the insurance premium. For Motor Liability and Watercraft Liability contracts, the exact level of commission received from HDI Assicurazioni S.p.A. is published in detail in the Modulo Unico Precontrattuale, pursuant to article 131 of the Italian Private Insurance Code and ISVAP Regulation no. 23/2008.

6. The right to be forgotten for cancer survivors

Pursuant to article 2 of Law no. 193 of 7 December 2023, policyholders and insured persons have the right not to be asked about oncological conditions for which active treatment ended, with no relapse, more than ten years earlier (five years if the condition arose before the age of twenty-one). Such information, even if obtained, cannot affect eligibility, contract terms or premium. This right does not apply to motor liability cover; implementation details are set out in the additional pre-contractual information document (DIP aggiuntivo) for each product.

Regulatory references: Legislative Decree 209/2005 (Italian Private Insurance Code); IVASS Regulation no. 40/2018 as amended; ISVAP Regulation no. 23/2008; Law 193/2023. Full text in the Modulo Unico Precontrattuale. Last updated: 1 September 2026.