Curtis R. Trotter brought this action against State Farm Mutual Automobile Insurance Company and its agent, D. Kim Ledford, alleging: (1) that they negligently failed to advise him of an exclusion in his motor vehicle insurance policy, (2) that they breached their insurance contract with him, (3) that State Farm negligently failed to settle a lawsuit within the policy limits, (4) that State Farm negligently trained Ledford, and (5) that State Farm had engaged in unfair trade practices. State Farm and Ledford answered with general denials and raised the defense that Trotter was contributorily negligent in failing to read his policy. Before trial, the judge granted State Farm’s motion for summary judgment as to the unfair trade practices cause of action. At the close of testimony, State Farm and Ledford made motions for directed verdicts on all causes of action. Trotter dismissed his breach of contract claims with prejudice. The *469judge denied the motions for directed verdicts on the remaining causes of action. The jury returned a verdict against State Farm and Ledford for $753,521.33 actual damages. State Farm and Trotter made motions for judgment notwithstanding the verdict and for a new trial, which the court denied. State Farm and Ledford appeal. We reverse.
When reviewing a jury verdict, we are limited to determining if there is any evidence to support it. Willis v. Floyd Brace Co., Inc., 279 S. C. 458, 309 S. E. (2d) 295 (Ct. App. 1983). The evidence and all reasonable inferences arising therefrom must be viewed in the light most favorable to the respondent. Merrill, Lynch, Pierce, Fenner & Smith, Inc. v. Bruce, 284 S. C. 227, 325 S. E. (2d) 77 (Ct. App. 1985).
Trotter is the sole proprietor of an upholstery business in North Augusta. In the operation of his business, Trotter uses a pick-up truck to collect and deliver his customers’ furniture.
In 1975, Trotter contacted Ledford, a State Farm agent, about insuring his vehicles. He chose Ledford because friends had spoken well of him and Ledford’s office was only one block from his shop.
When Trotter first met with Ledford, he told him that he wanted “full protection” on his truck. He filled out an application and explained about his business, his employees, and how many miles the truck would be driven. Since the truck was used in Trotter’s business, Ledford wrote a commercial policy on Trotter’s truck and a personal policy on his other vehicles. The commercial policy included a standard exclusion for any injury to an “employee of the insured arising out of his or her employment.”1
Ledford neither reviewed the policy with Trotter, told him about the exclusion,2 discussed other types of insurance, nor asked whether Trotter needed workers’ compensation insur*470anee.3 Ledford did not discuss coverage for employee injuries, because he did not think Trotter’s business was eligible for State Farm’s business insurance, due to the poor condition of Trotter’s building.
Trotter, likewise, neither asked Ledford to assess his insurance needs nor inquired about other types of insurance. He did not communicate a desire for workers’ compensation4 or any other insurance. Their conversation was confined to the procurement of insurance on his vehicles.
Trotter insured his vehicles through Ledford until 1983. He described his relationship with Ledford, between 1975 and 1983, as “ongoing.” He testified that during this time he5 periodically visited Ledford’s office to pay premiums, to give notification of a change in vehicles, to discuss insurance, or to conduct other routine business. Normally, he would deal only with Ledford’s receptionist, but on two occasions he spoke with Ledford himself. He further testified that, in approximately 1981, Ledford contacted him about increasing his coverage. Acting on Ledford’s recommendation, he did so. Trotter admitted, however, that no one insurance agent was ever responsible for all of his insurance needs. Furthermore, there was evidence that Trotter insured other risks through different agencies.
In March, 1983, Trotter and an employee, Charles Brunson, were traveling in Trotter’s truck on Highway 25, just north of Edgefield, when Trotter crossed the center line to make a left turn and hit an oncoming truck. Trotter and Brunson were picking up a customer’s furniture at the time.
Following the accident, State Farm wrote Trotter a letter denying coverage for Brunson’s injuries due to the exclusion.6 Until he received the letter, Trotter was unaware of the exclusion, as he had not read his policy.
Brunson brought suit against Trotter in the United States District Court for the Southern District of Georgia to recover for his injuries. Brunson’s attorney offered to settle *471the claim for the limits of Trotter’s policy, $100,000.00. Based on the exclusion, State Farm refused to settle the claim or defend Trotter. Brunson was eventually awarded a judgment against Trotter in the amount of $660,000.00. This amount was reduced by $40,000.00 to reflect amounts already recovered from the other driver’s insurance carrier.
I.
State Farm and Ledford argue that they were under no duty to advise Trotter of the employee exclusion in the policy or to advise him that he needed workers’ compensation insurance. For this reason, they maintain the trial judge should have granted their motions for directed verdicts on the cause of action for negligent failure to advise. Generally, an insurer and its agents owe no duty to advise an insured. Nowell v. Dawn-Leavitt Agency, Inc., 127 Ariz. 48, 617 P. (2d) 1164 (App. 1980). If the agent, nevertheless, undertakes to advise the insured, he must exercise due care in giving advice. See Riddle-Duckworth, Inc. v. Sullivan, 253 S. C. 411, 171 S. E. (2d) 486 (1969).
An insurer may assume a duty to advise an insured in one of two ways: (1) he may expressly undertake to advise the insured; or (2) he may impliedly undertake to advise the insured. See Bicknell, Inc. v. Havlin, 9 Mass. App. 497, 402 N. E. (2d) 116 (1980); Precision Castparts Corp. v. Johnson & Higgins of Oregon, Inc., 44 Or. App. 739, 607 P. (2d) 763 (1980); Northern Assurance Co. of Am. v. Stan-Ann Oil Co., Inc., 603 S. W. (2d) 218 (Tex. Civ. App. 1979). It is the insured, however, who bears the burden of proving the undertaking. See Riddle-Duckworth, Inc. v. Sullivan, supra.
An implied undertaking may be shown if: (1) the agent received consideration beyond a mere payment of the premium, Nowell v. Dawn-Leavitt Agency, Inc. supra; (2) the insured made a clear request for advice, see Precision Castparts Corp. v. Johnson & Higgins of Oregon, Inc., supra; or (3) there is a course of dealing over an extended period of time which would put an objectively reasonable insurance agent on notice that his advice is being sought and relied on. See Nowell v. Dawn-Leavitt Agency, Inc., supra; Northern Assurance Co. of Am. v. Stan-Ann Oil Co., Inc., supra.
It was incumbent on Trotter to prove Ledford agreed to *472advise him about his insurance needs. Courts cannot create contracts for the parties. There must be a clear oral or written agreement for a court to enforce. Trotter may not seek, after the fact, to have a court or jury create an undertaking favorable to him, if the parties themselves did not enter such an agreement. See Chapman v. Williams, 112 S. C. 402, 100 S. E. 360 (1919); Somerset v. Reyner, 233 S. C. 324, 104 S. E. (2d) 344 (1958); Texcon, Inc. v. Anderson Aviation, Inc., 284 S. C. 307, 326 S. E. (2d) 168 (Ct. App. 1985).
Trotter presented no evidence to show that either State Farm or Ledford expressly undertook to advise him. He testified that he saw several State Farm advertisements which in effect said that State Farm’s agents are well trained and highly qualified individuals, who will advise people with respect to their insurance needs. These advertisements, however, do not amount to an express undertaking. Ordinarily, an advertisement is a mere invitation to the public to contact the advertiser and request its services, as opposed to an offer to perform those services. See, Georgian Co. v. Bloom, 27 Ga. App. 468, 108 S. E. 813 (1921). State Farm’s advertisements were nothing more than invitations to the public.
There was likewise no evidence of an implied undertaking. Trotter did not contend that State Farm or Ledford received any consideration beyond the payment of premiums from which an implied undertaking could arise. Moreover, he produced no evidence to show he made a clear request which would put Ledford on notice that his advice was being sought and relied on. A request for “full coverage,” “the best policy,” or similar expressions does not place an insurance agent under a duty to determine the insured’s full insurance needs, to advise the insured about coverage, or to use his discretion and expertise to determine what coverage the insured should purchase. See Ethridge v. Assoc. Mut., Inc., 160 Ga. App. 687, 288 S. E. (2d) 58 (1981) (“full coverage”); Nowell v. Dawn-Leavitt Agency, Inc., supra (“the best policy”). Trotter himself was admittedly aware of workers’ compensation insurance before he first went to Ledford. When asked if he had ever purchased workers’ compensation coverage from other agents in the past, he replied, “No. I asked about it and I was told I didn’t *473need it.” He conceded that he did not ask Ledford to advise him about worker’s compensation:
Q. ... You never put the questions to Mr. Ledford as to whether or not you needed workmen’s compensation coverage, did you?
A. I didn’t feel I needed it.
Q. Well, you relied on what that other person told you and you didn’t get the coverage, did you?
A. Because the other person told me — maybe the other person didn’t know what he was doing____
Trotter also failed to prove a course of dealing over an extended period of time which would put a reasonable insurance agent on notice that his advice was being sought and relied on. Trotter’s “ongoing relationship” with Ledford consisted of periodic visits to pay premiums, to change vehicles, to discuss insurance,7 and to conduct routine business. During all but two of his visits, Trotter dealt with Ledford’s receptionist, not Ledford. Trotter never approached Ledford about purchasing other types of insurance, but instead continued to maintain other types of insurance through other agents.
Because there is no evidence to prove essential elements of his case, we hold, as a matter of law, that Trotter failed to create an issue of fact for the jury.8 Therefore, the judge *474should have granted directed verdicts for State Farm and Ledford on the failure to advise causes of action.
II.
State Farm also contends that the trial judge erred in failing to grant its motion for directed verdict with respect to Trotter’s negligent training cause of action. To establish a cause of action for negligence a plaintiff must show the concurrence of three essential elements: (1) a duty of care owed by the defendant to the plaintiff; (2) a breach of that duty by negligent act or omission; and (3) damage proximately resulting from the breach of duty. Brown v. South Carolina Ins. Co., 284 S. C. 47, 324 S. E. (2d) 641 (Ct. App. 1984), cert. dismissed, 290 S. C. 154, 348 S. E. (2d) 530 (1985). The absence of any one of these elements renders the cause of action insufficient. South Carolina State Ports Authority v. Booz-Allen & Hamilton, 289 S. C. 373, 345 S. E. (2d) 324 (1986).
In this case, Trotter has, at the very least, failed to establish the element of proximate causation. Negligence is the proximate cause of an injury when without the negligence the injury could have been avoided. Willis v. Floyd Brace Co., supra. If, as a result of negligent training, Ledford either had breached a duty to give advice or had given “bad advice,” then a causal link to Trotter’s damages might be inferred. Since, however, Ledford did not advise Trotter — and was under no duty to advise on the facts presented — his lack of proper training, if any, was irrelevant. In other words, Ledford’s training made no difference one way or the other. The judge ought to have granted the motion for a directed verdict on this cause of action.
*475III.
State Farm finally asserts that the judge should have granted its motion for a directed verdict on Trotter’s negligent failure to settle cause of action.
In South Carolina, a liability insurer owes its insured a duty to settle a personal injury claim covered by the policy, if settlement is the reasonable thing to do. Tyger River Pine Co. v. Maryland Casualty Co., 163 S. C. 229, 161 S. E. 491 (1931). If an insurer undertaking the defense of a suit covered by the policy unreasonably refuses or fails to settle within the policy limits, it is liable to the insured for the amount of the judgment against him in excess of the policy limits. Id. Of course, the rule does not apply if the personal injury claim is not covered by the policy. See Miles v. State Farm Mut. Auto. Ins. Co., 238 S. C. 374, 120 S. E. (2d) 217 (1961); Stroup Sheet Metal Works, Inc. v. Aetna Casualty & Surety Co., 268 S. C. 203, 232 S. E. (2d) 885 (1977) (insurance company fails to defend at its own peril, but it is obligated to defend only actions involving claims covered by the insuring contract).
Trotter does not argue that Brunson’s injuries are covered by his insurance contract with State Farm. In fact, he dismissed his cause of action for breach of contract at the close of the evidence and proceeded on the theory that the policy did not cover his liability to Brunson. Having conceded this much, Trotter also conceded a necessary predicate for his negligent failure to settle cause of action. If the policy did not cover injuries to Trotter’s employees, State Farm had no duty to settle the case with Brunson. Accordingly, the judge also should have granted the motion for a directed verdict on this cause of action.
In light of our disposition in this matter, we need not address the other issues raised by the appeals. For the reasons stated, the judgment is
Reversed.
Shaw and Cureton, JJ., concur.Ordinarily, injuries to an employee, arising out of the course and scope of employment, are covered by workers’ compensation insurance. See Section 42-1-160, Code of Laws of South Carolina, 1976. To prevent double coverage of these injuries, a commercial vehicle policy will typically exclude them from its coverage.
Trotter concedes, however, that Ledford never told him the policy would cover injuries also covered by workers’ compensation insurance.
Ledford knew or should have known that Trotter had employees.
Trotter knew workers’ compensation existed to cover on the job injuries to employees.
Trotter testified, as did his wife, Blondell C. Trotter, that on occasion Blondell was the one who performed these tasks.
State Farm paid the claim for Trotter’s injuries.
Trotter said he sometimes discussed insurance when he went to Led-ford’s office. Trotter had the burden of proving these discussions would put a reasonable insurance agent on notice that his advice was being sought. See Riddle-Duckworth, Inc. v. Sullivan, supra. Since there is nothing in the record which establishes the substance of these discussions, Trotter failed to carry his burden of proof.
Apparently recognizing his problems of proof, Trotter, at oral argument, asserted this is a “bad advice” case, not a failure to advise case. His assertion is not only unsupported by the evidence, but also raises new matter which he is precluded from arguing on appeal. The statement of the case says Trotter brought a “cause of action against the defendants for ... negligent failure to advise the insured about the exclusion in his policy____” The complaint alleges that State Farm and Ledford, “Negligently failed to advise ... [him] that there was ... a gap in the coverage of [his] ... insurance policy,” that they negligently failed to advise him that workers’ compensation insurance would fill the gap, and that they “Negligently *474failed to include in the contract of insurance” a provision covering injuries to employees arising within the scope of their employment. Nothing indicates Trotter asserted the “bad advice” claim at trial. An issue not raised in the circuit court cannot be raised for the first time on appeal. Cudd v. John Hancock Mut. Life Ins. Co., 279 S. C. 263, 310 S. E. (2d) 830 (Ct. App. 1983).