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Code of Business Conduct

The Board requires the highest possible standards of professional and ethical conduct of itself and from all employees. Each business unit within the Group operates with policies and minimum standards and as such, we adhere to a code of business conduct which sets out the basic ethical standards that are required across the Group and takes into account the following:

  • Business Practices
    We are committed to engaging in honest, professional and ethical conduct and maintaining effective procedures to prevent confidential information being misused.
  • Dealing with Customers
    We are committed to treating customers fairly, openly and honestly and operate an effective complaints process to deal with situations where these standards may be challenged.
  • Dealing with Shareholders and other Stakeholders
    We shall seek to maximise shareholder value over time, recognising that wealth generated also benefits customers and employees as well as the communities within which we operate.
  • Dealing with Employees
    Maintaining a working environment that attracts, motivates and retains employees and will be intolerant of any type of discrimination, harassment or victimisation.
  • Dealing with Suppliers of goods and services and Business Partnerships
    Maintaining the highest possible standards of integrity in business relationships with suppliers and partners by treating them honestly and with respect and avoiding compromising offers of gifts and hospitality.
  • Dealing with Communities and the environment
    We are committed to contributing to the social and economic well-being of those communities where we are an employer and encourage employees to participate in projects and initiatives to strengthen those communities.
  • Dealing with Competitors
    We are committed to ensure we compete with competitors honestly and in accordance with the relevant Competition Law.
  • Dealing with Regulators
    Maintaining a constructive and open relationship with our regulators to foster mutual trust, respect and understanding and will not offer anything to officials in return for favourable treatment in any way.
Prevention of Financial Crime

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.
  • Sanctions
    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.
Employee Code of Conduct

We employ the highest business and personal standards when dealing with customers, colleagues and suppliers. The Employee Code of Conduct helps employees to act with integrity and comply with relevant legislation and regulations, including those on whistleblowing. All employees are bound by this code.

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