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:

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.

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 and safety

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.

Prompt Payment Code

The Prompt Payment Code sets out standards for payment practices for the benefit of suppliers. The Group is committed to maintaining the highest possible standards of integrity with suppliers and partners and is a long-standing signatory of the Prompt Payment Code. During the financial year, the Group remained committed to prompt payment terms to ensure fair payment practices.

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.

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.