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Approach

Given the profile of our brands, being recognised as a trusted, responsible company enhances our reputation, improves stakeholder relations, and engages our people.

Our approach is set out in our CSR Charter.

Commitment to stakeholders

These statements outline our position and commitment to our different stakeholders:

Community

Our aim is to build Britian's best retail general insurer. We recognise that achieving this aim requires us to be a good corporate citizen.

Aligned to our core business, our focus is on Making Communities Safer through improving road safety and reducing crime and anti-social behaviour.

Our community investment programme works nationally and locally in the specific communities in which we live and operate.

The programme comprises:

  • A small number of national strategic partnerships, selected by the central CSR team either to support our core focus or our broader CSR agenda
  • One Day, our employee volunteering initiative, which allows all employees to take the equivalent of one full working day away from work to volunteer
  • Payroll Giving, where we match employee donations £ for £ up to £50 per month
  • Community Cashback, which provides individual grants of £250 to organisations for whom our employees regular volunteer or fundraise
  • Employee fundraising

Local community activity is coordinated through our network of Charitable and Social Committees that operate at each of our main office sites.

Please note that we do not support the following:

  • Unsolicited appeals
  • Individuals undertaking their own fundraising
  • Promotion of political or religious beliefs
  • Overseas trips and travel expenses
Public Policy

Our aim is to contribute to public policy debates that have an impact on our business or our stakeholders. We seek to ensure an effective legislative and regulatory environment is in place that encourages responsible business practice and enables our business to flourish.

The following principles govern our approach:

  • Direct Line Group does not make political donations or support party political interests.
  • Direct Line Group does not offer inducements of any kind to public officials, though it may invite officials to events and meet their associated costs.
  • Direct Line Group does seek to inform policymakers, including government officials, legislators, regulators, about the nature of our business, the insurance industry and the business environment generally. Direct Line Group will develop policy positions (often, but not always, at the request of policymakers), which explain clearly what outcomes Direct Line Group seeks from the public policy process and why its proposals should be adopted.
  • Direct Line Group believes in transparency of government relations and ‘policy positions’ are generally in written form and published unless commercially sensitive
  • Direct Line Group may use external consultants and other advisers on matters of public policy, although Direct Line Group believes it should represent its own interests directly wherever possible.
  • Direct Line Group is a member of a large number of bodies, including trade associations, which may participate in public policy activities from time to time.
  • Direct Line Group does not participate in public policy activities in which it has no legitimate interest.
Ethical Code for Suppliers

 

Introduction

We recognise that as one of the UK’s leading general insurers, our responsibilities extend beyond our commercial interests, and that we play an important role in the areas in which we trade. We want to increase our focus on Corporate Social Responsibility (CSR) within our supply chains through specific improvement programmes and to seek to ensure our key supply chains minimise waste and improve efficiency. We have put in place a rigorous assessment process for our key suppliers which takes into account the wide range of factors which we believe are inherent to operating as a responsible business. This code sets out our expectations of suppliers in this area.

We are further committed to conducting our business with suppliers in a fair and honest manner, with openness and integrity, in line with legal & regulatory requirements, and we expect our suppliers to operate to these same principles. This document is divided into two parts, outlining our key commitments to our suppliers, and detailing our ethical expectations of the companies that we work with.

Part I - Our Commitments to Suppliers

The performance of our suppliers is critical to our business. We aim to treat our suppliers with respect and to invest in long-term partnerships that benefit both sides. Direct Line Group’s (DLG) objective is to deliver best value from our suppliers where appropriate on a long-term basis. While price matters, it is only part of the purchasing decision.

Developing our Relationship

Wherever practical and cost-effective, the purchasing and supply requirements of all the brands and businesses within DLG have been centralised and rationalised. This allows us to invest more time with each supplier, and to seek greater shared efficiencies throughout our supply chain.

Our Selection Process

Our sourcing teams aim to conduct the supplier tendering and assessment process in an open and transparent manner, sharing information wherever appropriate to improve performance. When selecting our suppliers, we assess them against a wide range of criteria, which include:

• Management capability and financial strength for long-term reliability.
• Ability to deliver enduring quality and value. We conduct rigorous due diligence before and after the bidding process, involving a full cost breakdown analysis, to ensure that the contract can be fulfilled.
• Commitment to innovation and their ability to help us develop new products, processes and ways of working that can give DLG a commercial edge.
• Commitment to the wider CSR agenda. We encourage suppliers to develop and comply with their own detailed CSR policies and guidelines, and we actively assess their practices and commitment.
• We periodically screen our suppliers against applicable sanctions in order to comply with our responsibilities.

Supplier Diversity

DLG is committed to providing equal opportunities in sourcing, regardless of race, gender, marital status, age, disability, religious belief, political opinion, or sexual orientation.

We aim to maximise supply chain opportunities by proactively seeking and building strong, value-focused relationships with our suppliers.

We believe that diversity in our work force and in our supply base contributes to a stronger, better organisation, able to draw from a variety of resources with the aim of delivering increased value to our customers and investors. We want value created from our supplier relationships to help us achieve long-term growth, solidify our partnerships with our customers and preserve a competitive advantage.

Consultation and Engagement

We meet our suppliers regularly to review our business relationships, share ideas and encourage best practice. Furthermore, we encourage feedback on DLG as a customer. We particularly welcome feedback on how we can improve our policies and processes.

Part II - Our Expectations of Suppliers

Purpose and Scope of this Code

As a financial services business, many of our social and environmental impacts can be manifested through the operations of our suppliers. To ensure that we continue to improve our CSR performance, it is important that we work with suppliers who share our determination to be highly successful and customer focused, and who run their businesses to the same high standards as our own, managing their social and environmental impacts responsibly. This code sets out our expectations of suppliers in this area. The code is applicable to the operations of all our direct suppliers, although we would encourage them to ensure that their own upstream supply chain suppliers adhere to the spirit of these business principles.

Ethical Code for Suppliers

Legal and Regulatory Compliance

We insist that all suppliers adhere rigorously to all relevant legislation and regulation in their operations. This includes all applicable employment, health, safety, environmental,
Anti-Bribery & Corruption and Anti-Money Laundering & Sanctions legislation. Regulatory breaches that come to our attention will be taken into account when renegotiating supplier relationships.

Business Principles

We are committed to conducting our business with suppliers in a fair and honest manner, with openness and integrity, and expect that suppliers operate to these same principles. We further expect that suppliers are committed to operating to relevant best-practice standards of employment, health, safety and environmental management in the workplace, and that suppliers provide adequate working facilities for all employees.

Our expectations of suppliers go beyond regulatory compliance.

Human Rights & Labour Standards

We expect that our suppliers adhere to the core International Labour Organisation (ILO) standards which ban the use of child labour and compulsory/bonded labour, protect workers rights to non-discrimination and comply with legislation. Furthermore we also expect our suppliers to adhere to the non-core ILO standards which include statements that workers should have safe and hygienic working conditions, a living wage should be paid, working hours are not excessive, and abuse and intimidation are prohibited and  to exercise the same promotion of these requirements and standards across their supply chain. UK legislation should also be complied with, including The Modern Slavery Act 2015 which requires organisations to support the eradication of modern slavery through increased transparency across their supply chains and provide assurances via a published statement outlining the steps that are being taken to support The Act.

Environment

We are committed to strong business growth that is not achieved at the expense of the environment, and believe that all businesses should do their utmost to minimise their impact on the environment.

DLG, as a provider of financial services, may affect the environment directly through its own operational activities and indirectly through the activities of our suppliers. The environmental challenges facing us all include our use of resources, the creation of pollution, the effects of its activities on climate change, and our impact on species and habitats. It is important that we not only monitor our own behaviour but also encourage others to adopt best practice.

We therefore expect that Suppliers should support a precautionary approach to environmental challenges, undertake initiatives to promote greater environmental responsibility, and encourage the development and diffusion of environmentally friendly technologies.

Anti-Corruption

DLG has a strict policy on Anti-Bribery and Corruption. It will not engage in bribery or corruption in any form and has a zero tolerance approach to any breach whether it involves private individuals or public officials (including in relation to facilitation payments). As such we expect that our suppliers enforce an equally robust Anti-Bribery & Corruption policy of their own, as well as complying with any relevant legislation.

Modern Slavery Statement

 

STATEMENT ON MODERN SLAVERY

Introduction

This statement on slavery and human trafficking is published on behalf of Direct Line Insurance Group plc and its wholly owned subsidiaries U K Insurance Limited, DL Insurance Services Limited and UK Assistance Accident Repair Centres Limited pursuant to section 54 of the Modern Slavery Act 2015 (“the Act”), each having a turnover in excess of £36m. References to “we”, “us”, “our”, and “DLG” are to all of these companies. This statement applies to the financial year for DLG ending 31 December 2016.

Corporate Social Responsibility

As an organisation DLG takes its responsibilities seriously. We believe that doing the right thing builds trust, trust builds reputation and reputation builds value. We support the aims of the Act and seek to ensure slavery and human trafficking does not feature in our business or supply chain.

DLG does this through our Corporate Social Responsibility (CSR) Charter which is overseen by the CSR Committee. The CSR Committee aims to help ensure we run our business in a responsible manner, and considers emerging social, environmental and ethical issues and opportunities.

Our Organisation’s Structure

DLG is one of the leading providers of general insurance in the UK and through its number of well known brands offers a wide range of general insurance products to customers. These brands include: Direct Line, Churchill, Privilege and Green Flag. DLG also offers insurance services for third party brands through its Partnerships division and also for the commercial sector, via its NIG and Direct Line for Business operations. Further details of our organisation’s structure can be found on our website.

We apply a multi-brand, multi-product and multi-distribution channel business model to sell to retail customers and businesses. Products can be purchased online, including via price comparison websites, by phone and indirectly through partners and’ in our commercial business, via brokers. 

DLG has a varied supply base spanning direct (claims validation and fulfilment) and indirect suppliers, including many that are well known brands and industry leaders in their field. We have established processes to procure services, on-board suppliers, and to provide on-going appropriate oversight of them. We currently and will continue to carry out a range of assurance activity across suppliers to seek to ensure policy standards are being delivered, including through desk and field based audits.

Supply chain ethics

We recognise that as one of the UK’s leading general insurers, our responsibilities can extend beyond our commercial interests, and we want to increase our focus on Corporate Responsibility within our supply chains. Through our Ethical Code for Suppliers available on our website we have outlined our key commitments to our suppliers, and detailed our ethical expectations of suppliers that we work with.

These include adherence to: (a) the core International Labour Organisation (ILO) standards which ban the use of child labour and compulsory/bonded labour, whilst protecting rights to non-discrimination; and (b) the non-core ILO standards which include statements that workers should have safe and hygienic working conditions, working hours are not excessive, and abuse and intimidation are prohibited.

Following the introduction of the Act, we have revised our Ethical Code for Suppliers to show our expectation that our key direct suppliers ensure that they are taking appropriate steps to prevent modern slavery from occurring within their business and supply chain.

We have communicated these changes in our Ethical Code for Suppliers to our key direct supplier base, directing them to publicly available guidance around modern slavery and what suppliers should be looking for.

Risk Assessment, Due Diligence and Assurance Processes

We have developed a risk-based approach to assess the likelihood of modern slavery occurring in our supply chain. The criteria used for this approach take into account many factors including the geographical location from which services are provided, length of the supply chain, use of migrant or temporary labour and the nature of the goods or services being supplied. We use the results of these assessments to categorise key direct suppliers and identify potential areas of focus within our supply base.

We carry out due diligence checks on new key direct suppliers prior to engagement, tailoring the approach according to (amongst other factors) the potential modern slavery risks. Approved key direct suppliers are then subject to checks and audits, with suppliers identified as higher risk receiving greater prioritisation and being subject to an increased level of scrutiny. Issues arising would be escalated via our procurement and/or risk functions.

We also implement pre-employment background checks for employees and contractors and require our key direct suppliers to do the same.

Training

We have created training on modern slavery for our employees to raise awareness of modern slavery and to encourage any employees who do identify potential modern slavery issues within our business or supply chain to report their concerns including via our whistle-blowing policy.

Next steps

We will continue to work to embed understanding of modern slavery in our supply chain and business to raise awareness of modern slavery.

We will continue to evaluate measures that we can take as a business and work with our key direct suppliers with the aim of preventing modern slavery occurring in our business and supply chain.

Board Approvals

The Directors of Direct Line Insurance Group plc and U K Insurance Limited approved this statement on 26th January 2017. The Directors of DL Insurance Services and UK Assistance Accident Repair Centres Limited approved this statement on 6th February 2017.

Read the signed statement

 

Diversity

Direct Line Group recognises and values the promotion of diversity and inclusion in all areas of recruitment and employment. Direct Line Group practices are in line with the Universal Declaration of Human Rights and we will work towards an environment that is based on meritocracy and inclusion, where all employees can develop their full potential, irrespective of their age, belief, disability, ethnic or national origin, gender, gender identity, marital or civil partnership status, political opinion, race, religion or sexual orientation. In particular:

  • We base our relationship on the principles of meritocracy, inclusion and fair treatment for all our people. Qualifications, skills, demonstration of our values and experience are the ONLY basis for recruitment, access to training and development opportunities and promotion decisions.
  • We respect, encourage, understand and allow divergent thinking to grow in DLG.
  • Undertake reviews of diversity data on an annual basis and recommend the appropriate course of action.
  • Provide a Group Policy Learning product.
  • Provide the appropriate training and developmental activity
  • Develop links with external bodies/ agencies to promote best practice.
  • Provide guidance to people managers and our people.
  • Monitor employment policies and practices.
  • Champion the values of equality, diversity and inclusion, internally and externally.
Health, Safety & Wellbeing

People are core to the success of our business, and their health, safety and wellbeing are important to Direct Line Group. We manage health and safety in accordance with statutory and regulatory requirements in a way that takes all reasonable steps to protect the health and safety of employees and others at our business locations, from risks in their work or work environment by:

  • Providing safe and healthy working environments and safe and maintained equipment.
  • Ensuring safe handling and use of substances.
  • Having first aid and emergency response procedures in place.
  • Reporting and reviewing accidents, occupational ill health and significant near misses to minimise the likelihood of a recurrence.
  • Providing information, training & supervision to ensure competency.
  • Defining and communicating roles and responsibilities.
  • Consulting with employees on matters affecting their health and safety.
  • Regularly measuring and reviewing our health and safety performance to drive continuous improvement.
  • Using external independent auditing
  • Ensuring all employees have access to advice, guidance and support regarding well being
  • Having appropriate employer’s liability insurance in place and ensuring it is available for inspection at all reasonable times by employees.
  • Appointing an Executive leader to chair our Executive Health & Safety Committee
Environmental Statement

This Statement sets out our approach to ensuring that the Direct Line Group considers environmental and sustainability issues in all parts of its operations and business activities. We seek to progressively reduce our environmental impact in all our aspects of our operations by minimising and making efficient use of resources.

Our commitment

  • We will comply with environmental legislation and approved codes of practice as a minimum and put in place appropriate internal best-practice standards to continuously improve our environmental performance.
  • We will set clear objectives and targets to measure and take action to reduce the carbon footprint of our business activities.
  • We will implement waste management strategies that promote waste minimisation, re-use, recovery and recycling where appropriate.
  • We will make efficient use of resources and minimise our use of energy, water and paper.
  • We will give due consideration to environmental issues and energy performance in the acquisition, design, refurbishment, location and use of our buildings and assets.
  • We will ensure environmental and sustainability criteria are taken into account in the procurement of goods and services.
  • We will operate and maintain company vehicles with due regard to environmental issues as far as reasonably practical, encourage sustainable travel options and increase the use of technology to reduce overall business travel.
  • We will provide the Board and the CSR Committee oversight and review of environmental policies and performance, and allocate resources for their effective implementation.
  • We will work with our employees, service partners, suppliers, landlords to promote environmental awareness and improved environmental performance.
  • We will communicate internally and externally our environmental policy and performance on a regular basis.

Governance

We have established a sound governance structure to oversee our CSR strategy and programme.

Performance Indicators

We have committed to publicly reporting our progress annually using a set of key performance indicators. We have also set a target for each indicator for the year ahead.

Annual Report & Accounts 2015

Annual Report 2015

Download Annual Report & Accounts 2015 PDF

CSR Contacts

To get in touch with the Direct Line Group CSR team please contact:

Ashley Taylor
Sustainability Manager
01651 831653
ashley.taylor@directlinegroup.co.uk

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