Financial crime results in a heavy cost to the insurance industry and to the United Kingdom as a whole. The detection, prevention and reporting of financial crime is important to the Group and special measures are taken to combat the associated risks. Financial crime is defined to include Anti-Money Laundering (AML), Sanctions, Anti-Bribery and Corruption (ABC) and Fraud. The Group policies on financial crime seek to comply with all applicable national and international legislation, as well as with additional guidance provided by regulators and industry bodies, and are updated periodically.
The Group operates a company wide framework, across its brands, to ensure management and oversight of compliance. The framework utilises subject matter expertise to provide direction, guidance and training on financial crime threats and risks. Further details of financial crime controls can be found below.
- Anti-Money Laundering
The Group has established and maintains effective anti-money laundering systems and controls. To facilitate compliance, an anti-money laundering programme has been developed and implemented. This consists of policies, procedures, internal controls and systems. It aims to protect the financial and operational integrity of the company by taking proportional and reasonable steps in combating any attempts to launder money.
The Group undertakes transactional business in line with sanctions restrictions and obligations, with regard to countries, entities and individuals.
- Anti-Bribery and Corruption
The Group is committed to compliance with anti-bribery and corruption principles and provisions anywhere in the world it has a presence. There are policies, procedures and training in place to ensure that the group conforms to the provisions of the UK Bribery Act 2010. Risk assessments are conducted by all Group businesses to identify, mitigate and control potential bribery and corruption risks. The Group operates a zero tolerance policy to instances of bribery and corruption and is dedicated to conducting business with honesty and integrity.
- Fraud Prevention
The Group works proactively to combat and reduce instances of fraud, whether opportunistic or part of a wider organised crime network. System controls and procedures are in place to detect instances of fraud and it work closely with law enforcement to prosecute perpetrators of crime. The Group also liaises with industry bodies and government agencies to share fraud data and increase detection rates. Training is maintained to keep ahead of evolving fraud risks.