Quilter International

Quilter International is part of Quilter plc and is one of the leading cross-border providers of wealth management solutions. Qulter help expatriates and local investors in multiple global markets, including the UK, Africa, Asia, Europe, Latin America, and the Middle East.

Quilter plc is one of the leading providers of advice, investments and wealth management both in the UK and internationally, managing £110.4 billion of investments (as at 31 December 2019). Quilter plc is listed on the London and Johannesburg stock exchanges.

Quilter's customer focused approach has been recognised by experts in the investment industry. Covering its products, skills and expertise, below are the latest awards:

International Investment Awards 2019

  • Best International Platform - Wealth Interactive
  • Excellence in Fintech - Wealth Interactive
  • Excellence in Client Service, Industry - Middle East

Also highly commended for ‘International Campaign of the Year – Investing through volatile times’.

For Portfolio Bonds for example, we can submit the policy requests of our clients via the Quilter online platform "Wealth Interactive - where we can submit new business, top ups, dealing requests, make withdrawals, conduct asset review etc. and much more.

At Navigator we take pride in working with Quilter in managing and growing your investments. We are here to help you achieve your specific goals and those for your family and the generations to come.

IF you have any questions, you can speak to Romi Gill on 2530 2530 or email her romi.gill@navigator-insurance.com .

To comply with current tax regulations, i.e;

  • the Foreign Account Tax Compliance Act (FATCA) from the United States (US) and

  • the Common Reporting Standards (CRS),

Quilter is required to obtain certain information from its clients and ask them to complete either :

  • a 'Tax declaration and self-certification' form for individuals or ,

  • corporate clients/trustees form.

Quilter has a legal obligation to obtain certain information under regulations relating to the exchange of information for tax purposes and provide it to the relevant Quilter International local tax authority.

To comply with these regulations, Quilter clients need to

  1. Visit Quilter's website and complete the editable PDF form including the declaration section, typing their name(s) in the signature box (where they would usually sign) and also typing in the date. They then email their completed editable PDF form to QINTLTaxReporting@quilter.com from the email address we hold for them on our records.

  2. Complete the form online, print, sign and return it by post (in the pre-paid return envelope provided); or scan and email it to QINTLTaxReporting@quilter.com.

  3. Complete and return the hard-copy form in the pre-paid return envelope provided.

IF you have any questions, you can speak to Romi Gill on 2530 2530 or email her romi.gill@navigator-insurance.com . You can also visit Quilter’s FATCA webpage for more information about tax reporting.

As of 1-4-2021 the Insurance Authority in Hong Kong has increased the responsibilities of firms like ours to justify the advice we give when selling insurance investment products.

Financial Needs Analysis (FNA)

The Appendix to the GL30 Guideline on Financial Needs Analysis (including the Interpretation Notes) has set out a new template for the standard and minimum level of FNA information that has to be collected.

Navigator is to expand the scope of questions and granularity of the information to be collected, depending on the particular circumstances of our target customer segments and specific business model.

We are to document and incorporate further information as mentioned in GL30 on your FNA form, which includes:

  1. the evaluation and factors considered by us during the FNA process;
  2. the recommendation(s) made by us and
  3. reason(s) for such recommendation(s).

Whenever we offer a unit linked policy to you as a customer, we are required to offer a participating policy as well that meets your investment objective as an option. Please see 6.13 of GL30 for details.

Points ot note in the new FNA template (Appendix to GL30) as highlighted below.

Question 1 of the FNA

In recommending an unit linked product such as :

  • Quilter International Wealth Management Plan,
  • Executive Investment Plan or
  • Collective Investment Plan),

we have to be satisfied that you, the customer has indicated that you have both insurance and investment needs, which means that you have ticked BOTH options “financial protection against adversities” and “investment” as the objectives under this question, and have further answered the ‘supplementary question to Q1’.

If you have ticked the “investment” option only, the new business application is unable to proceed.

Furthermore, if we should recommend an open-architecture ILAS product such as:

  • Quilter International Executive Investment Plan or
  • Collective Investment Plan

to you, we can only do this if you have indicated you have an additional objective of ‘tax planning’ or ‘estate planning’ under the option “Other” of this question. Besides, this has to be specified in item 1 (Statement of purpose) of Qulister's Important Facts Statement (IFS) form as well.

If you, as a customer indicates a wealth accumulation-related objective, i.e. when you have ticked the fourth option “saving up for the future” then because unit linked products do not possess a guaranteed investment return feature (saving) due to the inherent investment risk associated with the product and charges taken under the product. If that option is selected and we recommend a unit linked product, we have to give a sound justification for the recommendation. Without such justification the application will not be able to proceed. Please see item 6.17 of GL30 for details.

Supplementary question to Question 1 of the FNA

Item 6.12 of GL30 requires that if you have indicated that you do not want or are unwilling to choose different investment choices, no unit linked product should be introduced by us. SO if you tick the last option (i.e. “I do not want to choose or manage different investment options…”) under this supplementary question, your application will not be able to proceed.

As Navigator is for now only licensed as a financial adviser (i.e. insurance broker) and are not licensed as a fund adviser we are unable to assist if you tick the second option, (i.e. “I want to make my own decisions (with professional advice to be provided….”),

Please see item 6.12 of GL30 for details.

Target party for the FNA

Where the policy is to be held on trust, the assessment should be made based on the circumstances of the potential policy owner and/or the insured (e.g. settlor, beneficiary as appropriate) rather than the trustee.

As a matter of principle, whenever information privy to the customer is to be collected (e.g. identifying the objectives of the customer through the FNA), the information (e.g. needs, objectives, intention, financial situation) should be collected from the relevant individual(s) e.g. the insured/settlor rather than the trustee.

Please see item 6.7 of GL30 for details. In this connection, the regulatory documentations concerned (e.g. FNA, RPQ and IFS) are to be signed by those relevant individuals from which the information is collected, whereas our product application form will remain to be signed by the trustee as the applicant / prospective policyholder.

Policy Replacement

Under the requirements of the GL27 Guideline on Long Term Insurance Policy Replacement and Interpretation Notes, the definition of policy replacement has been changed as stated in item 5 of the Guideline. In short, policy replacement means that you are using (or intend to use) some or all of the total cash value of the existing life insurance policy or any savings made (or to be made) as a result of reducing the premium payable under the existing life policy, by means of:

  1. reducing the total cash value or sum insured of the existing policy by the customer exercising a right under the policy (e.g. withdrawal, surrender, lapse, etc.);
  2. taking out a policy loan from the existing policy; or
  3. suspending premium payment or ceasing to pay premium under the existing policy.

As specified in item 5.4 of GL27, enquiries have to be made during the sale process of a new long-term policy to identify any policy replacement by means of a set of questions as detailed in Appendix A to GL27. In that policy replacement questionnaire, if you answer ‘yes’ or ‘he has not decided’ as to whether he intends to use some or all of the funds arising from the existing policy (or the savings made by reducing the premium payable under the existing policy) to fund the new policy, you will have to further sign the form “IFS-PR” (Important Facts Statement – Policy Replacement), where the template can be found in Appendix B to GL27.

IF you have any questions, you can speak to Romi Gill on 2530 2530 or email her romi.gill@navigator-insurance.com .

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Navigator Insurance Brokers Ltd
Unit E, 8/F Golden Sun Centre
No. 59-67 Bonham Strand West
Sheung Wan, Hong Kong