Other Policies

Board Diversity Policy

Purpose & scope

This Board Diversity Policy (the “Policy”) establishes the approach to diversity on the Board of Direct Line Insurance Group plc, U K Insurance Limited and Churchill Insurance Company Limited. The Policy applies to the Board only; the Group's wider commitment to diversity and inclusion is encapsulated in a Group diversity policy and in statements about the Group's principles, practices and initiatives disclosed in each Annual Report and to employees and contractors via the Group's intranet and training programmes.

Board diversity

The Board recognises the need to have leaders who live the Group's culture and values and believes that an effective board with a broad strategic perspective should embrace a diversity of gender, race, skills, experience, as well as regional, socio-economic, educational and professional background, among other differences.

The Nomination and Governance Committee regularly reviews the composition of the Board, seeking to balance its skills, experience, knowledge and independence, taking into account the composition best positioned to advance the Group’s strategy for the benefit of all of its stakeholders. When reviewing the Board’s composition, the Nomination and Governance Committee considers the benefit of all aspects of diversity, whilst also considering candidates on merit against objective criteria.

The Board aims to maintain female representation of at least 30% and remains committed to seeking to improve further its position on diversity when appropriate opportunities arise.

In its search for candidates, the Board aims only to engage with executive search firms which are signatories to the Voluntary Code of Conduct for Executive Search Firms.

The Board advocates the importance of cultural and ethnic diversity and aims to increase the ethnic diversity across the Group including at Board and senior management level.


The Nomination and Governance Committee will review the Policy annually and monitor its effectiveness, referring any proposed amendments to the Board for approval, and reporting progress against the Policy in the Annual Report and Accounts.

Approved by the Board on 26 March 2020

Tax Policy

The disclosure below meets the requirements of paragraph 16(2) of Sch 19 of Finance Act 2016 to publish our Tax Policy by 31 December 2021. This Policy applies to all UK entities within the Group, but the principles also apply to any DLG operations overseas.

DLG’s 2021 Tax Policy

This policy sets out the approach of DLG to managing its tax affairs, to ensure it complies with applicable tax laws and regulations, meets its corporate social responsibilities as a contributor of corporate taxes and as a collector of taxes on behalf of HMRC, manages its tax affairs efficiently, and claims tax reliefs and incentives where appropriate.

Approach to risk management and governance

The Risk Management and Governance sections of DLG’s Annual Report and Accounts (available on DLG’s website) provide information about DLG’s management of risk and governance framework. DLG has a risk management model that separates responsibilities into “Three Lines of Defence”.

Having a policy framework (policies and minimum standards) is a central part of DLG’s Enterprise Risk Management Framework (ERMF). Compliance with minimum standards (including the minimum standard relating to tax) is reviewed annually and in addition any changes to minimum standards must be presented to the Risk Management Committee (RMC). Risk assessments are undertaken regularly, along with the setting of appropriate controls.

The CFO is the Executive Committee (ExCo) member with executive responsibility for tax matters. The CFO delegates the day-to-day operational management of tax to the Head of Tax and the Group Tax function at DLG, and oversight is provided by the Audit Committee (AC). The Group Tax function is staffed with appropriately qualified individuals. Processes relating to different taxes help to ensure that all relevant matters are considered in the Group’s tax returns. These are allocated to appropriate process owners who ensure that business and legislative changes impacting these processes are monitored and changes made where applicable.

Tax is within the scope of the Financial Reporting Control Framework (FRCF), which adds additional governance and also ensures that control testing is carried out as appropriate. Any failed tax controls or tax risks identified are raised at the relevant Committee, with potential escalation to the Board where appropriate.

Attitude towards tax planning

Tax will be considered as part of material business decisions to ensure that associated tax consequences are understood and properly costed to enable the business to make informed decisions. DLG will make use of available tax incentives, reliefs and exemptions and will endeavour to structure its business / operations in a tax efficient manner. DLG will only enter into a transaction that is commercially driven and will not undertake any tax planning that is inconsistent with legislation.

Tax advice may be sought externally where the capacity or specific skills to deal with the issue are not available internally. It may also be sought to provide insight into industry practice, or where there could be ambiguity over how a transaction should be taxed or where the transaction is particularly material. In such cases, discussions would also be held with HMRC.

DLG requires the members of its Group Tax function to act lawfully and with integrity, which is consistent with various accounting and tax professional body codes of conduct, and that any tax planning should be based on a realistic assessment of the facts and on a credible view of the law. Members of the Group Tax function must not create, encourage or promote tax planning arrangements or structures that: 1) set out to achieve results contrary to the clear intention of Parliament; or 2) are artificial or contrived and seek to exploit shortcomings within the relevant legislation.

Level of risk in relation to UK taxation the Group is prepared to accept

The Risk Management section of DLG’s Annual Report and Accounts sets out the risk appetite of DLG. The Board sets the overarching risk appetite for the Group, within which tax risk sits. Risk appetite statements which drive decision-making in the business are reviewed and challenged by the Risk Management Committee (RMC) and Board Risk Committee (BRC) and annually approved by the Board, which is ultimately responsible for ensuring that management puts appropriate processes in place to identify all relevant risks and ensure that these are managed accordingly.

DLG has a low threshold for tax risk and aims for certainty in its obligations wherever feasible, including through agreement with HMRC wherever considered appropriate. DLG manages risks to ensure compliance with its legal and regulatory requirements to submit accurate tax returns on a timely basis.

DLG has a number of key tax risk indicators to monitor adherence to tax risk appetite.

Approach of the Group towards its dealings with HMRC

DLG seeks to establish and maintain an open and co-operative working relationship with HMRC through regular communication and meetings with its Customer Relationship Manager (CRM), covering all taxes and duties. Where appropriate, matters are discussed in real time in respect of significant transactions, changes in the business, and the Group’s proposed approach to new legislation.

DLG submits applicable tax returns and makes associated payments in a timely manner. It responds to HMRC’s queries promptly and ensures the disclosure of all relevant facts, particularly where there is ambiguity in the tax treatment of any transaction. Any inadvertent errors are rectified and fully disclosed as soon as practicably possible after being identified.

Where applicable, DLG is proactive in working with HMRC to ensure that new tax legislation is appropriate and that tax anomalies are identified. It is receptive both to providing feedback to HMRC and to inviting HMRC to test any significant changes in its business / systems that may impact tax.

Click here to download the PDF version of the Tax Policy 

Click here to find out where Direct Line Groups Tax Contribution comes from

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.

Click here to find out more about our Code of Business Conduct 

Prevention of Financial Crime

Financial crime results in a heavy cost to the insurance industry and to the United Kingdom as a whole. Financial crime includes Bribery and Corruption, Money Laundering (AML), Terrorist Financing, Fraud and Sanctions. The detection, prevention and reporting of financial crime is important to the Group. It maintains robust systems and controls with clearly defined policies and minimum standards to  promote compliance with all applicable national and international legislation and regulation and industry approved guidance. These are regularly reviewed to ensure that they remain fit for purpose and align to the Group Risk Framework. This includes a robust financial crime governance framework and internal reporting and escalation channels. The framework utilises subject matter expertise to provide direction, guidance and training on financial crime threats and risks.  

Employee Training

Mandatory Financial Crime Awareness training (which covers anti-bribery and corruption, anti-money laundering, counter- terrorist financing, financial sanctions, fraud and the prevention of the facilitation of tax evasion) is undertaken by all employees at induction and on an annual basis thereafter with an assessment that needs to be passed. Completion rates are monitored and reported through the internal governance process.  Additional, bespoke training is delivered to employees who work in business areas considered to have an elevated ABC risk including Board and ExCo members.

Further details of financial crime controls can be found below.

Anti-Bribery and Corruption (ABC)

Bribery is the offer, promise or giving of a payment (or other improper benefit) to influence someone to perform a function improperly. This includes payments to a Public Official intended to secure or expedite an existing duty, otherwise known as a ‘Facilitation Payment.’

Facilitation Payments (or “grease” payments) are unofficial payments made to Foreign Public Officials in order to secure or speed up the performance of a routine or necessary action, which public or private officials are already bound to perform (“routine duties”).They are commonly defined as:

·  Being made only to speed up the performance of a routine duty

·  Not being prohibited by law in the country of the recipient

·  Common practice in the country of the recipient

·  Of a nominal amount relative to the cost of living in the country where the payment is received (i.e £1 in the UK isn't worth as much to someone as it might to in less developed country)

Facilitation payments are illegal under the UK Bribery Act, as a consequence Direct Line Group does not permit the making or approval of facilitation payments.

Corruption occurs when one abuses their position of entrusted power for private gain.

The Group is committed to preventing these offences occurring within its business and to being compliant with anti-bribery and corruption principles and provisions anywhere in the world it has a presence. There are policies, procedures and training in place designed 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 bribery and corruption, including Facilitation Payments, and is dedicated to conducting business with honesty and integrity.

The Group expects the same high standards to be displayed by its employees, suppliers and any of its associated parties. Any breaches of the Group’s anti-bribery and corruption policies or procedures will be dealt with appropriately and necessary action will be taken against the party in breach.

The Group’s Code of Conduct Policy sets out expectations on employee behaviour. Our Anti Bribery and Corruption (ABC) Minimum Standard document can be found here.

The Group’s ABC programme is managed by the Head of Investigations who holds the position of Designated Anti Bribery and Corruption Officer. This position is overseen by the Chief Risk Officer who maintains the position of ABC Accountable Executive. Breach of these of these standards entails a breach of the employment code of conduct and will therefore lead to disciplinary action and possible dismissal. Upon successful recruitment all employees affirm their compliance to the minimum standard document and receive annual ABC training where they must receive a pass mark of at least 80%. The ABC Team review the ABC Minimum Standard Document and the ABC training annually to ensure it is up to date and proportionate. Employees have various ways in which they can consult of ethical issues, they are able to speak with their line manager, approach the ABC Team directly or utilise Direct Line Group’s whistleblowing hotline where their issue(s) will be independently investigated and dealt with appropriately. The employee can choose to remain anonymous.Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF).

The Group has established and maintains effective anti-money laundering and counter-terrorist financing 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 Group by taking proportional and reasonable steps in combating any attempts to launder money. To support effective operation of this requirement, all employees and contractors must report suspicious activities to the dedicated Anti-Money Laundering Team who will investigate and report to the National Crime Agency where necessary.

Fraud Prevention

The Group works proactively to combat and reduce instances of fraud, whether opportunistic or part of a wider organised crime network.  The Group has systems, controls and procedures in place to prevent and detect fraud and works closely with law enforcement to prosecute perpetrators of this crime.  The Group also liaises with industry bodies and government agencies to share fraud data and increase detection rates.  Fraud awareness training is maintained to keep abreast of evolving fraud risks.

Preventing the Facilitation of Tax Evasion

The Group has zero tolerance for any form of tax evasion and will thoroughly investigate any suspected breaches. There is a framework to ensure that the Group has reasonable procedures in place to prevent the facilitation of tax evasion by its associated parties, as required by the Criminal Finances Act 2017.

The Group has a dedicated Sanctions Team, with qualified and competent staff.  The Sanctions Team has processes and procedures in place to complete appropriate and timely investigations of potential sanctions matches. In addition to sanctions screening activity, the Sanctions Team engages with projects and change programmes across the Group to ensure that the relevant sanctions requirements are met.

The Group takes all whistleblowing concerns seriously. The Group’s Whistleblowing Policy sets out the controls within which the Group promotes a climate of openness within the workplace and creates a positive environment in which all persons can raise any concerns without fear of reprisal. 

The Group’s Whistleblowing Policy also provides advice and guidance for employees to make protected disclosures utilising the services of an external third party.  All employees/contractors can raise concerns via their people manager or utilise the services of a reporting tool managed by an independent third party. It provides a free, confidential 24/7 telephone helpline and web based service for disclosures to be made. When making a whistleblowing disclosure, whistleblowers do not have to disclosure their name and contact details and can stay anonymous. All reports remain confidential. 

All whistleblowing reports are reviewed and thoroughly investigated by the Group’s Internal Investigations function. The unit investigates, collates and analyses management information on whistleblowing disclosures including any emerging themes or trends, and reports these regularly to the Board Risk Committee as well as instigating remedial actions.

A Whistleblowers’ Champion provides oversight of the integrity, independence and effectiveness of the Group’s Whistleblowing Policy and procedures.

Internal awareness regarding whistleblowing is maintained by regular updates using the Group’s internal intranet and an annual online policy learning module which is undertaken by all employees.

Conflict of Interest

A conflict of interest is one person’s personal or private interests could affect the objective exercise by them of their duties and responsibilities. Conflicts can arise in the normal course of business between:

▪ DLG’s own interests and those of its customers;

▪ the interests of DLG’s clients; or

▪ the interests of DLG’s employees.

DLG is committed to minimising all conflicts of interest.  Guidance and training is provided to colleagues through the Employee Code of Conduct, the Conflicts of Interest Minimum Standard and our IPL training schedule.


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. The code of conduct is incorporated into our IPL training schedule and is part of The Way we Work, all employees are bound by this code and have to confirm their understanding annually. 

Crisis preparedness

Our business resilience team run three operational teams - bronze, silver and gold -which provide a cross function team structure to deal quickly with a crisis and provide a clear escalation process should the crisis possess the ability to threaten our mission, business plan and future competitiveness. Every year the company runs a crisis exercise which tests our capacity to respond quickly and effectively to a crisis which has the potential to damage our reputation and inconvenience our customers. This exercise tests the structures and lines of communications between bronze, silver and gold teams, so that we can constantly improve our processes to provide confidence to our people, our customers and our shareholders that we are well equipped to deal with any crisis. To support our operational structures, we also have a set of guiding principles which provide the foundations for our actions and decision making.

  • Putting people first: Our primary objective of any crisis response is to ensure the safety and welfare of people; whether they are employees, contractors, customers, suppliers, or the relatives of employees and customers who are involved in a serious incident or issue. Other considerations, such as financial implications of the situation, are secondary.
  • Prudent over-reaction: The principle of prudent over-reaction should guide all elements of crisis response. It is better to over-react, then stand-down resources as more information becomes available, rather than delay mobilisation and the strategic response.
  • Thinking from the ‘outside-in’: Before decisions are enacted, we think though how these actions will be perceived by stakeholders, be they employees, customers, shareholders, regulators or policymakers. Our company value of “do the right thing” applies and if something has gone wrong somewhere, we actively set out to resolve it.
  • Proactively manage any crisis: Where possible, we take a proactive approach to crisis management, ensuring that the organisation is seen by key stakeholders as the authoritative source of information related to the situation.
  • Speed of response: Our crisis response teams may be required to make difficult decisions, often on the basis of partial or incomplete information. Whilst it is vital that any response is considered and well thought through, it is crucial that responses are conducted as quickly as is practicable.
  • Gaining shared awareness and decision making in uncertainty: We always seeks to achieve a shared view of the situation and rapidly generate strategy and action plans. Systems are required to ensure that situation briefs, objectives and action plans can be shared across the company. This is so that management can collaborate and enact timely and effective interventions to resolve the situation or crisis.


Direct Line Group takes any whistleblowing concern seriously. Our Whistleblowing Policy sets out the controls within which the Group promotes a climate of openness within the workplace and creates a positive environment in which all persons can raise any concerns without fear of reprisal.

All employees and contractors can raise concerns via their people manager or utilise the services of “RightCall”, a reporting tool managed by an independent third party.  It provides a free, confidential 24/7 telephone helpline and web based service for disclosures to be made. When making a whistleblowing disclosure, whistleblowers do not have to disclosure their name and contact details and can stay anonymous.  All reports remain confidential.

All whistleblowing reports are reviewed and thoroughly investigated by the Group’s Internal Investigations function. The unit investigates, collates and analyses management information on whistleblowing disclosures including any emerging themes or trends, and reports these regularly to the Board Risk Committee as well as instigating remedial actions.

The Board Risk Committee and, in particular, the Whistleblowers’ Champion, provides oversight of the integrity, independence and effectiveness of the Group’s Whistleblowing Policy and procedures.

Internal staff awareness regarding whistleblowing is maintained by regular updates using the Group’s internal intranet and an annual online policy learning module which is undertaken by all staff.

To make a whistleblowing report please click here or alternatively you can call  the freephone number on 0800 316 0516 to make a disclosure .

Political Involvement

Direct Line Group prohibits any political involvement or donations to any political parties on the company’s behalf.

We are a member of the Association of British Insurers (ABI) who amongst other things, lobby politicians and the Government on industry-wide issues. From time to time we engage with Politicians from all Parties and Civil Servants to highlight issues of concern to our own business interests. Any such activity is approved by senior management and any expenditure is recorded in the gifts and hospitality register.