• Login
  • Register
  • PRO
    • Explore all PRO content
    • PRO subscription plans
    • Curated articles
    • In-depth
    • Market intelligence
    • Practice guides
    • Lexology GTDT
    • Ask Lexy
  • PRO
  • Latest
  • GTDT
  • Research
  • Learn
  • Webinars
  • Instruct
  • Store
  • Blog
  • Events
  • Popular
  • Influencers
  • About
  • Compare
  • Topics
  • Intelligence
  • Guides
Getting The Deal Through joins Lexology
GTDT and Lexology Navigator have merged

CONTENT DEVELOPMENT

Become your target audience’s go-to resource for today’s hottest topics.

  • Trending Topics New
  • Discover Content
  • Horizons Beta
  • Ideation

CLIENT INTELLIGENCE

Understand your clients’ strategies and the most pressing issues they are facing.

  • Track Sectors
  • Track Clients
  • Mandates New
  • Discover Companies
  • Insight Reports

COMPETITOR INTELLIGENCE

Keep a step ahead of your key competitors and benchmark against them.

  • Benchmarking
  • Competitor Mandates Coming soon

Lexology PRO

Power up your legal research with modern workflow tools, AI conceptual search and premium content sets that leverage Lexology's archive of 900,000+ articles contributed by the world's leading law firms. 

Explore all PRO content

Premium content

  • Curated articles
  • In-depth
  • Market intelligence
  • Practice guides

Analysis tools

  • Lexology GTDT
  • Ask Lexy
Explore all PRO content
PRO subscription plans
  • About
  • Find experts
  • Firms
Back Forward
  • Save & file
  • View original
  • Forward
  • Share
    • Facebook
    • Twitter
    • Linked In
  • Follow
    Please login to follow content.
  • Like

add to folder:

  • My saved (default)
  • Read later
Folders shared with you

Register now for your free, tailored, daily legal newsfeed service.

Questions? Please contact customerservices@lexology.com

Register

Insurance Authority finalises codes of conduct for insurance intermediaries

Linklaters LLP

To view this article you need a PDF viewer such as Adobe Reader. Download Adobe Acrobat Reader

If you can't read this PDF, you can view its text here. Go back to the PDF .

Hong Kong September 11 2019

On 3 September 2019, the Insurance Authority (the “IA”) released conclusions on its consultations on the draft Code of Conduct for Licensed Insurance Agents (the “Agents’ Code”) and the draft Code of Conduct for Licensed Insurance Brokers (the “Brokers’ Code” and together with the Agents’ Code, the “Codes”). 

On 3 September 2019, the Insurance Authority (the “IAâ€) released conclusions

on its consultations on the draft Code of Conduct for Licensed Insurance

Agents (the “Agents’ Codeâ€) and the draft Code of Conduct for Licensed

Insurance Brokers (the “Brokers’ Code†and together with the Agents’ Code,

the “Codesâ€).

Our client alert on the April 2019 consultations is included in the Annex below.

The final Codes do not depart materially from the drafts, however the IA has

made some amendments to the Codes and provided further clarity on several

points.

The key amendments and IA comments to take note of are:

GP 1 Honesty and Integrity

• The duty of utmost good faith has been removed from the Brokers’ Code,

which now states that a Licensed Insurance Broker when carrying on

regulated activities should always act with good faith towards its client.

(The Brokers’ Code only)

• The provisions on the offering of an advantage have been aligned with the

Prevention of Bribery Ordinance (the “PBOâ€) and clarify that, in carrying

out regulated activities, insurance intermediaries are expected to give

particular consideration to the PBO in certain situations.

GP 4 Competence to Advise

The Codes now include an explanation that the requisite skills or knowledge

that licensed technical representatives are expected to have will depend on the

particular situation and factors to be considered include the complexity of the

insurance product or transaction, whether the insurance product is of a

specialist nature, the level of the person’s experience and the relevance of the

person’s qualifications.

2

GP 5 Disclosure of Information

• Premium rebates – The IA has clarified that, although it is not stated in

the Codes, restrictions on premium rebates continue to apply in relation to

long-term products and medical insurance products.

• Breach of duty of utmost good faith – The IA has revised the Agents’

Code so that Licensed Insurance Agents will be required to explain the

consequences of a breach of the duty of “utmost good faith†(rather than

ensure the client’s understanding). Guidance on how such explanation

should be given has also been included. (The Agents’ Code only)

• Client agreements – The Brokers’ Code has been amended to clarify that

a client agreement must be in writing, but the form of agreement is flexible

and client agreements do not have to be signed (e.g. brokers’ terms of

business can be e-mailed to a client, with the client confirming his

agreement by e-mail or by conduct). (The Brokers’ Code only)

GP6 Suitability of Advice

The suitability assessment must be carried out where regulated advice is given

and the relevant requirement has been amended to be “outcome-focusedâ€, i.e.

insurance intermediaries are required to take into account the client’s

“circumstances†(which is now a defined term in the Codes) and the relevant

Standard and Practice is applicable to every situation in which regulated advice

is provided.

GP7 Conflicts of Interest

The Codes have been supplemented to require that licensed insurance

intermediaries must disclose any conflicts of interest (where such conflict

cannot be avoided) and at all times act fairly in relation to the client. These

provisions are similar to requirements contained in the Code of Conduct for

Persons Licensed by or Registered with the Securities and Futures

Commission.

GP8 Client Assets

The IA has introduced a new requirement in the Agents’ Code which will require

licensed insurance agents to maintain proper records of premium received

when authorised to receive premium payments by an appointing insurer or

appointing agency. (The Agents’ Code only)

Corporate Governance and Controls and Procedures

The sections on corporate governance and controls and procedures, which

were in Parts D of the draft Codes, are now in Parts C of the final Codes.

• Baseline standards and practices – The IA has clarified that the relevant

sections of the Codes set the baseline standards and practices for

corporate governance which all licensed insurance agencies/broker

companies should meet and that such requirements in the Agents’ Code

3

and the Brokers’ Code are different because of the different roles which

licensed insurance agencies and licensed insurance broker companies

perform.

• Incident reporting – The IA has amended the reporting incidents

requirement to specify types of incidents which must be reported and set

out the considerations of what constitutes a “material†incident (e.g. if the

incident adversely impacts or is likely to adversely impact the

agency’s/broker’s ability to carry on regulated activities).

• Removal of “fit and proper†requirement for certain broker company

employees – The IA has removed the requirement in the Brokers’ Code

that persons who are recruited, employed by or associated with or act for

the broker company must be “fit and properâ€. The IA has amended the

relevant provision to require a licensed broker company to ensure such

persons have “the integrity and competence to discharge their duties and

responsibilitiesâ€. (The Brokers’ Code only)

• Definition of “senior management†– The Codes now include a definition

of “senior management†and note that (i) the exact composition of senior

management will depend on the size of the agency/broker company; (ii)

whether a person is part of senior management depends on that person’s

actual functions and duties (as opposed to position and title); and (iii)

certain persons are likely to be considered part of the senior management

(e.g. in large agencies/broker companies, persons responsible for

oversight of a business line or function).

• Product due diligence by brokers – The IA has clarified that by “due

diligenceâ€, it means that it expects Licensed Insurance Brokers to

understand the insurance contracts they are arranging and the differences

between different insurance products, so that they know which one is best

to address a client’s circumstances. (The Brokers’ Code only)

Product Specific Requirements

The IA clarified that the General Principals are intended to have universal

application and the Codes are not intended to be a full list of laws which apply

to licensed insurance intermediaries. In addition to the Codes, insurance

intermediaries are expected to comply with guidance issued by the IA that are

focused on particular classes of business and types of insurance products.

Technology Neutral

The IA clarified that the Codes are intended to be technology neutral and it has

made several amendments to reflect this.

Referral Business

The consultation conclusions emphasise that referrals may involve the carrying

on of regulated activities. The IA has noted that the entire issue of referrals

requires further consideration and has indicated that it will monitor the issue

and consider taking further regulatory steps after it has taken on the regulation

4

of insurance intermediaries. We will monitor these developments and provide

further updates.

Next steps

The Codes will come into operation upon commencement of the new regulatory

regime for insurance intermediaries on 23 September 2019. However, the IA

has indicated that it will adopt an attitude of flexibility in considering whether

the Codes have been observed during the first few months of their operation.

Full compliance with the provisions of the Codes is expected by 1 January 2020.

All insurance intermediaries who are validly registered with one of the self-

regulatory organisations and who will be deemed licensed under the new

regulatory regime should familiarise themselves with the Code that will apply

to them.

Please refer to the Annex below for our note from April on the Codes.

Contacts

For further information

Annabella Fu van Bijnen

Partner

(+852) 2901 5232

annabella.fu@linklaters.com

Sumit Indwar

Partner

(+852) 2901 5626

sumit.indwar@linklaters.com

Clara Hackney

Managing PSL

(+852) 2901 5611

clara.hackney@linklaters.com

Kaylene Houng-Lee

Associate

(+852) 2901 5249

Kaylene.houng-lee@linklaters.com

5

Annex April 2019

Insurance Authority consults on draft codes of conduct for licensed insurance intermediaries

Introduction and Background

On 28 March 2019, the Insurance Authority (the “IAâ€) launched a two-month

public consultation (the “Consultationsâ€) on the draft Code of Conduct for

Licensed Insurance Agents (the “Agents’ Codeâ€) and the draft Code of

Conduct for Licensed Insurance Brokers (the “Brokers’ Code†and together

with the Agents’ Code, the “Codesâ€).

In recognition of the different capacities served by insurance agents (as

representatives of insurers) and insurance brokers (as representatives of policy

holders or potential policy holders), the IA proposes to issue two codes of

conduct.

The Agents’ Code will apply to all licensed individual insurance agents,

licensed insurance agencies and licensed technical representatives

(collectively, “Licensed Insurance Agentsâ€). The Brokers’ Code will apply to

all licensed insurance broker companies and licensed technical

representatives (collectively, “Licensed Insurance Brokersâ€). In addition, the

proposed Codes will also set out the responsibilities of responsible officers and

senior management of the licensed insurance agencies and licensed insurance

broker companies respectively, relating to the carrying on of regulated activities

by the licensed insurance agencies and licensed insurance broker companies.

At present, insurance intermediaries are required to comply with conduct

requirements promulgated by their respective self-regulatory organisations (i.e.

the Insurance Agents Registration Board set up by the Hong Kong Federation

of Insurers, the Hong Kong Confederation of Insurance Brokers and the

Professional Insurance Brokers Association). Under the new statutory regime

for insurance intermediaries, which is expected to come into effect in mid-2019,

the IA will take over the regulatory functions of insurance intermediaries from

the three self-regulatory organisations.

The IA indicated that, in formulating the proposed Codes, it had taken into

account, amongst others, the norms and practices which have emerged from

the day-to-day operation of the insurance market, existing codes and

guidelines which apply to insurance agents and insurance brokers, other codes

and guidelines and guidelines issued by regulatory authorities in Hong Kong

and overseas and prevailing international standards. In addition, the IA

indicated that the proposed Codes are principles-based to allow flexibility for

the insurance market to evolve, adapt and innovate. Additional product specific

requirements will be imposed through other regulatory instruments that apply

in addition to the proposed Codes such as in relation to investment-linked

assurance schemes and mandatory provident fund products.

6

The proposed Codes will come into operation on the day on which the new

statutory regime for insurance intermediaries comes into operation.

Codes’ contents

Both proposed Codes are divided into four parts. Parts C and D of the proposed

Codes set out the substantive requirements.

Part A contains the introductory paragraphs and background to the relevant

Code.

Part B sets out the defined terms of the relevant Code.

Part C sets out the general principles, standards and practices.

Part D provides guidance on the corporate governance, controls and

procedures that Licensed Insurance Agents and Licensed Insurance Brokers

should establish and implement.

Schedule 1 sets out standards and practices for referral of business.

Certain of the requirements in the proposed Codes appear to be similar to the

requirements contained in the Code of Conduct for Persons Licensed by or

Registered with the Securities and Futures Commission (for example, the

requirement to enter into a written client agreement and the requirement to

report material incidents to the relevant regulator).

The general principles, standards and practices

The proposed Agents’ Code and the proposed Brokers’ Code set out eight core

general principles under each of which, there is elaboration on the relevant

standards and practices applicable to Licensed Insurance Agents/Brokers. In

some instances, the standards and practices applicable to Licensed Insurance

Agents/Brokers are different in light of the different capacities served by

Licensed Insurance Agents (as representatives of insurers) and Licensed

Insurance Brokers (as representatives of policy holders or potential policy

holders). We have highlighted some of the differences below.

The IA noted in particular that the requirements in the Codes serve as minimum

levels of professional conduct which policy holders and potential policy holders

are entitled to expect when dealing with Licensed Insurance Agents or

Licensed Insurance Brokers.

The eight general principles are as follows:

GP 1. Honesty and Integrity

Licensed Insurance Agents and Licensed Insurance Brokers are required to be

trustworthy and act honestly, ethically and with integrity. In addition, Licensed

Insurance Brokers are also required to act in the utmost good faith. The IA

noted that “utmost good faith†remains a sacrosanct tradition of the insurance

market.

7

GP 2. Acting Fairly and in the Clients’ Best Interests/Acting in the Best

Interests of Clients and Treating Clients Fairly

Licensed Insurance Agents should always treat clients fairly and act in their

best interests. The IA noted that a core theme running through the entirety of

the Codes is that of “treating clients fairlyâ€. The IA noted in particular that as

Licensed Insurance Brokers serve as the representatives of their clients, it is

the clients who should always be at the forefront of a Licensed Insurance

Broker’s considerations.

GP 3. Exercising Care, Skill and Diligence

A Licensed Insurance Agent/Broker should act with due care, skill and diligence.

The additional standards in the Brokers’ Code include:

(a) where a client terminates its appointment of a licensed insurance

broker company, the broker company should, amongst others, provide

all reasonable cooperation to bring the appointment to an end in an

orderly manner; and

(b) unless stated otherwise in the client agreement, a Licensed Insurance

Broker should (where requested by a client) provide the client with

reasonable assistance with regards to the client’s insurance claims and

exercise reasonable care to discharge all obligations in relation to the

administration, negotiation and settlement of such claims to the extent

that such obligations are within the scope of the Licensed Insurance

Broker’s services stated in the relevant client agreement.

GP 4. Competence to Advise

A Licensed Insurance Agent/Broker should possess appropriate levels of

professional knowledge and experience and only carry on regulated activities

in respect of which the agent has the required competence.

GP 5. Disclosure of Information

A Licensed Insurance Agent/Broker should provide clients with accurate and

adequate information to enable them to make informed decisions. The

additional standards in the Brokers’ Code include:

(a) a Licensed Insurance Broker should not hold itself out as an insurer or

an agent of an insurer in carrying on regulated activities;

(b) where a Licensed Insurance Broker intends to arrange an insurance

policy with an insurer which is not authorised by the IA, the Licensed

Insurance Broker should disclose to the client: (i) the name and

address of the insurer in the jurisdiction where the insurer has issued

the policy and (if different) the jurisdiction where the insurer is

incorporated, (ii) the fact that the insurer is not regulated by the IA and

is subject to different laws and regulations, (iii) the financial standing

of the insurer (e.g. credit rating), and (iv) the governing law of the

insurance policy and the jurisdiction in which disputes under the policy

will be determined. In the case where the client is an individual, the

8

Licensed Insurance Broker should also obtain written

acknowledgement from the client of the disclosure of (i) to (iv);

(c) when negotiating or arranging an insurance policy with an insurer on

behalf of a client, a Licensed Insurance Broker should: (i) not make

any false statements or mislead the insurer, (ii) disclose to the insurer

all material information in relation to the insurance policy, and (iii)

disclose all material facts in relation to the prospective insurance policy

of which the Licensed Insurance Broker is aware; and

(d) a Licensed Insurance Broker should enter into a written agreement

with each client before arranging an insurance policy with the client

which contains certain prescribed requirements, and a copy of the

agreement should be provided to the client.

GP 6. Suitability

Before giving regulated advice, a Licensed Insurance Agent/Broker should

properly carry out a suitability assessment of the client’s objectives,

circumstances, needs and priorities.

GP 7. Conflicts of Interest

A Licensed Insurance Agent/Broker should make every effort to avoid conflicts

of interests and when such conflicts cannot be avoided, should manage them

with appropriate disclosure to ensure clients are fairly treated at all times.

The proposed Agents’ Code (and its related standards and practices) seeks to

address the conflicts of interests that will likely arise as a result of a Licensed

Insurance Agent’s role as agent of its insurer principals and relationship with

policy holders. For example, the proposed related standards and practices

state that, to avoid potential conflicts of interest and provide transparency, a

licensed insurance agent should disclose that: (i) it is appointed by its

appointing insurer to promote and advise on the insurance products offered by

the insurer; and (ii) the insurance products it can promote and advise on are

limited to the insurance products offered by its appointing insurer.

Although Licensed Insurance Brokers act for policy holders, they are

sometimes remunerated by insurers by way of commission. General Principle

7 of the proposed Brokers’ Code (and its related standards and practices)

requires a licensed insurance broker company which receives remuneration in

this form to give adequate disclosure in relation to such remuneration to the

client before arranging the relevant insurance policy.

GP 8. Client Assets

A Licensed Insurance Agent/Broker should have sufficient safeguards in place

to protect the assets of clients.

Broadly, Licensed Insurance Agents should only receive payment of premiums

where it is within the scope of their authority as granted by the appointing

insurer or appointing agency. On the other hand, as Licensed Insurance

Brokers receive monies on behalf of clients, the proper handling of such client

9

monies is vital; a licensed insurance broker company should have sufficient

controls and security in place to prevent unauthorised access to client assets.

Corporate governance, controls and procedures

Part D of the proposed Codes require licensed insurance agencies and

licensed insurance broker companies to establish and implement

organisational structures and adequate controls to ensure:

(a) that interests of clients are not prejudiced;

(b) that there are clear roles and lines of responsibility; and

(c) accountability of senior management.

In particular, it is proposed that licensed insurance broker companies should

have in place proper controls and procedures to conduct due diligence on

insurers and the nature and key features of insurance products it intends to

provide regulated advice on.

It is also proposed that licensed insurance agencies and licensed insurance

broker companies will be required to report incidents that are material to their

business to the IA as soon as reasonably practicable after they become aware

of such incidents, e.g. a material breach of requirements under the Insurance

Ordinance and any rules, regulations, codes, guidelines, circulars or regulatory

instruments administered or issued by the IA, by the broker company or its

licensed technical representatives.

Additional Standards and Practices for Referral of Business

Schedule 1 of the proposed Codes sets out requirements in respect of referral

of business. It covers two referral arrangements:

(a) where a client is referred to a Licensed Insurance Agent/Broker by

another person (the “Referrerâ€). In such a case the Licensed Insurance

Agent/Broker should ensure that the client is properly informed of a

number of matters such as the Referrer does not represent the

Licensed Insurance Agent/Broker, the Licensed Insurance

Agent/Broker disclaims all liability for any advice given by the Referrer

in relation to the insurance policy, a benefit is to be provided by the

Licensed Insurance Agent/Broker to the Referrer etc; and

(b) where a client is referred by one Licensed Insurance Agent/Broker to

another:

(i) where a Licensed Insurance Agent intends to refer a client to

another Licensed Insurance Agent/Broker with a view to the

latter arranging an insurance policy for the client, the Licensed

Insurance Agent should ensure that it complies with policies,

procedures and other applicable requirements of its appointing

insurer or appointing agency; and

10

A39929603/0.2/11 Sep 2019

Authors: Clara Hackney and Kaylene Houng-Lee

This publication is intended merely to highlight issues and not to be comprehensive, nor to provide legal advice. Should you have any questions on issues reported here or on other areas of law, please contact one of your regular contacts, or contact the editors.

© Linklaters. All Rights reserved 2019

Linklaters Hong Kong is a law firm affiliated with Linklaters LLP, a limited liability partnership registered in England and Wales with registered number OC326345. It is a law firm authorised and regulated by the Solicitors Regulation Authority. The term partner in relation to Linklaters LLP is used to refer to a member of the LLP or an employee or consultant of Linklaters LLP or any of its affiliated firms or entities with equivalent standing and qualifications. A list of the names of the members of Linklaters LLP and of the non-members who are designated as partners and their professional qualifications is open to inspection at its registered office, One Silk Street, London EC2Y 8HQ, England or on www.linklaters.com.

Please refer to www.linklaters.com/regulation for important information on Linklaters LLP’s regulatory position.

We process your data in line with our Global Privacy Notice. You can view this at www.linklaters.com/en/legal- notices/privacy-notice.

To opt-out of receiving any marketing emails from us, or to manage your email preferences and the personal details we hold for you, please contact: marketing.database@linklaters.com.

10th Floor, Alexandra House

Chater Road

Hong Kong

Telephone (+852) 2842 4888

Facsimile (+852) 2810 8133/2810

1695

Linklaters.com

(ii) where a licensed insurance broker company intends to refer a

client to another Licensed Insurance Agent/Broker with a view

to the latter arranging an insurance policy for the client, the

broker company should ensure that it obtains prior consent from

the client concerned before making the referral. Where a

licensed technical representative (broker) intends to refer a

client to another Licensed Insurance Agent/Broker with a view

to the latter arranging an insurance policy for the client, the

technical representative should ensure that it complies with

policies, procedures and other applicable requirements of

appointing licensed insurance broker company.

Effect of a breach of the Codes

A failure to comply with the proposed Codes shall not by itself render a Licensed

Insurance Agent or Licensed Insurance Broker liable to any judicial or other

proceedings. However, the IA may take guidance from the Codes in considering

whether:

(a) there has been an act or omission by Licensed Insurance Agents or

Licensed Insurance Brokers which is or is likely to be prejudicial to the

interests of policy holders or potential policy holders or the public

interest;

(b) a Licensed Insurance Agent or Licensed Insurance Broker is fit and

proper to remain licensed; or

(c) a Licensed Insurance Agent or Licensed Insurance Broker has satisfied

the statutory conduct requirements in the Insurance Ordinance.

Next steps and how we can help

Should the Consultations on the Codes be of interest to you, you have until 28

May 2019 to submit feedback to the IA. We have represented many industry

groups and individual clients in responding to regulatory consultations and

assisting them in effectively presenting feedback on them. We would be

delighted to discuss any aspects of the above with you.

Linklaters LLP - Annabella Fu van Bijnen, Sumit Indwar, Clara Hackney and Kaylene Houng-Lee
Back Forward
  • Save & file
  • View original
  • Forward
  • Share
    • Facebook
    • Twitter
    • Linked In
  • Follow
    Please login to follow content.
  • Like

add to folder:

  • My saved (default)
  • Read later
Folders shared with you

Filed under

  • Hong Kong
  • Company & Commercial
  • Insurance
  • Linklaters LLP

Tagged with

  • Bribery
  • Securities and Futures Commission
  • Due diligence

Popular articles from this firm

  1. Interest Rate Benchmark Reform: Hong Kong, Singapore and recent global developments *
  2. MAS consults on regulatory approach for payment token derivatives *
  3. Prevention is better than cure: Hong Kong Competition Commission clarifies approach to information exchange *
  4. SFC Clarifies Expectations on Use of Cloud and other Virtual Data Storage *
  5. Hong Kong SFC introduces new Code of Conduct requirements on OTC derivative risk mitigation and client clearing and to address risks posed by group affiliates *

If you would like to learn how Lexology can drive your content marketing strategy forward, please email enquiries@lexology.com.

Powered by Lexology

Featured Video

Gernot Fritz
4:17 min

Gernot Fritz

Freshfields Bruckhaus Deringer

The good, the bad and the uncompliant privacy policies

Watch now

Related topic hubs

  1. Due diligence
  2. Bribery
  3. Hong Kong
  4. Insurance
  5. Company & Commercial

Related Hong Kong articles

  1. Ten things you need to know about the new Insurance Authority regime for insurance intermediaries *
  2. The Insurance Authority’s Enforcement Powers over Insurers and Insurance Intermediaries *
  3. New Codes of Conduct for Insurance Intermediaries are Coming Soon! *

Related international articles

  1. Digital Assets: Are they reflected in current Swiss laws and regulations? * - Switzerland
  2. Update on the UAE Foreign Direct Investment Law: Part 1 * - United Arab Emirates
  3. Legal guide to corporate insurance for South-East Asia - February 2016 * - Asia-Pacific
Thomas Grozinger
Principal Trust Specialist
RBC Wealth Management
What our clients say

"Lexology is a great service, providing easy access to a variety of relevant articles from a number of information providers across different geographical zones -- I just wanted to say thank you to all who are involved in providing this reference!"

Back to Top
  • Terms of use
  • Cookies
  • Disclaimer
  • Privacy policy
  • GDPR compliance
  • RSS feeds
  • Contact
  • Submissions
  • About
  • Login
  • Register
  • Follow on Twitter
  • Search
Law Business Research

© Copyright 2006 - 2019 Law Business Research