These statements outline our position to our different stakeholders

Direct Line Group Transparency Statement on Modern Slavery 2020

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 2020 and is the 5th annual statement produced by the organisation.

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

This is reflected through DLG’s purpose and sustainability strategy which is overseen by the Board and can be located on our website (see link).  As part of the strategy, the Sustainability Committee aims to help ensure we run our business in a responsible manner, and considers emerging social, environmental and ethical issues and opportunities.

Covid Response

2020 has been an unprecedented year that has impacted all aspects of life across the UK and the rest of the world. This has resulted in a shift in our supply chain focus as we respond to the impact of the pandemic and the resulting restrictions we have faced. We have worked with our supply chain through the Covid-19 pandemic for what, for a large proportion of our suppliers, brings challenges on how they adapt and preserve their operations to survive the economic impact that the pandemic has brought.

DLG’s initial response in managing our supply chain through the pandemic required the identification of those key suppliers most impacted by the restrictions brought in by the UK government and an understanding of the implications for each supplier based on their circumstances, the impact to our customers and government guidelines. This allowed us to work closely with those suppliers and implement mitigating measures to support them through the necessary changes they have had to make to adapt to a Covid-safe way of working, which is ongoing as together we continue to navigate the uncertainty created by the pandemic and seek to ensure both customers and staff remain safe, as our supply chain continues to provide the necessary services on our behalf.

Our Organisation’s Structure

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

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 our partners, and, in our commercial business, via brokers. 

Within our structure we employ approximately 10,000 people across multiple UK locations, in addition to our DLG Auto Services garage network which supports our Motor claims function through motor repairs. All direct employees of the Direct Line Group are paid a salary which exceeds the current National Living Wage.

DLG has in place robust recruitment policies that cover permanent, fixed term and contingent employees and require all employees to undergo background checking prior to beginning their employment with DLG. Supplier contracts also include requirements around background checking and suppliers must adhere to the applicable level of screening for employees working on DLG services which is based on the services being provided.

All our employees are required to adhere to our Code of Conduct which sets out to promote honest and ethical conduct and compliance with all applicable laws, rules and regulations. Adherence to this code, alongside practicing our Values, is key to the successful delivery of our business strategy.

Supply Chain

We recognise that, as one of the UK’s leading general insurers, our responsibilities can extend beyond our own commercial interests. Through our Ethical Code for Suppliers, available on our external website (see link) and shared with suppliers when tendering, 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 forced compulsory or bonded labour (including where the threat of penalty or discipline is used to compel work) 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, a living wage should be paid, working hours are not to be excessive, and abuse and intimidation are prohibited.

In addition, we expect suppliers to comply with the Act and provide assurances of compliance through a published statement which outlines the steps that are being taken to support the Act. In 2020 we have reviewed our actively managed supply chain (c. 80% of overall supplier spend) and have identified that 75% of those suppliers have statements published.

DLG’s supply chain covers both the provision of services for direct (claims validation and fulfilment) and indirect suppliers, including many well-known brands and industry leaders in their field. Across our direct supply base, our supply chain focuses on the fulfilment of claims across our key product areas.

Household Claims

Our household claims supply chain can be split into two key areas, validation and fulfilment. Fulfilment of our building claims is primarily through a network of home repair providers. Within this supply chain there is more seasonal, volume-driven and manual labour to support the service provision alongside additional subcontracted services, particularly where there is a response to severe weather events.

Our contents claims routes for validation and fulfilment include repair and replacement of household contents, including electrical goods, furniture, carpets and valuables. Our supply chain within this category is made up of a combination of UK-based goods fulfilment and service providers offering repair services; however, due to the nature of the goods requiring fulfilment by our supply chain (including raw materials) extends outside of the UK.

Motor Claims

Within our motor claims supply chain we look at the potential aspects of a motor claim journey including motor repair garages, recovery providers and salvage services. In addition, we also source goods provided to facilitate vehicle repairs, including parts replacement and paint. Both parts and paints categories have elements where we source goods from third parties outside the UK, either directly or through our suppliers’ supply chains.

Travel Claims

Our travel claims supply chain is service-based – focusing on cost containment and patient repatriation and based in a variety of locations worldwide to service our Travel insurance policy holders should they require medical care or repatriation whilst travelling.

Indirect Supply Chain

Our indirect supply chain provides us the necessary services to run our business including technology, facilities (catering and cleaning), professional services, marketing, print and recruitment. In addition, we receive back-office and claims handling services from our offshore service providers located in India and South Africa.

Although our core operations (and most of our immediate supply chain) are based in the UK, we are aware that we could have risks of potential modern slavery risk exposures within our supply chain, and the supporting processes we follow across our Procurement and Supply Chain function are key to supporting our adherence to the Act.

Procurement Processes

The Procurement & Supply Chain processes include steps intended to ensure that risks associated with modern slavery within the supply chain are identified, managed and mitigated.

DLG has a centralised Procurement & Supply Chain function that operates to the processes established within our Supplier Management and Outsourcing policy. Our processes are designed to ensure we select and manage our suppliers appropriately to support the given service provision and potential risk exposure to DLG, and our Policy sets out the mandatory requirements for the Group when procuring goods and services as follows.

Our suppliers are segmented based on multiple factors including value, expenditure and risk exposures, and our supporting processes provide a higher level of assurance, oversight and diligence for those suppliers and services segmented at higher levels.

In addition to our existing supplier segmentation process, annually we also review our modern slavery risk assessment, which was developed to assess the likelihood of modern slavery occurring in our supply chain. This allows us to identify where we may have increased or reduced risk exposure across areas including the geographical location from which goods or services are provided, length of the supply chain, use of migrant or temporary labour and the nature of the goods or services being supplied. 

Due diligence is undertaken on new suppliers sourced through the Procurement & Supply Chain function – we require suppliers either to provide a link to their most recent modern slavery statement or (should they fall below the reporting threshold) to respond to a number of questions, in order to articulate the steps they are undertaking to support the Act. 

On-boarded suppliers are then subject to assurance activity. Our Supplier Compliance Monitoring team conducts regular field reviews of our actively managed suppliers, and the scope includes the requirement to ascertain the supplier’s adherence to the Act and confirmation of the activity they are undertaking to comply with the Act.  This is tailored dependant on the supplier’s alignment to the reporting threshold. In addition, background checking of compliance with contractual clauses also forms part of the assurance scope.

Findings from assurance activity is documented, managed and reported through Procurement & Supply Chain governance and escalated as appropriate within the DLG governance framework.

During the course of 2020, due to the restrictions faced throughout the Covid pandemic the volume of external field audits has not been to the level usually achieved by the team; however, where possible more virtual audits have taken place across suppliers, assessing the same scope of assurance but with altered approaches to assuring evidence provided by suppliers.

Supporting processes are reviewed on an annual basis to ensure alignment with legislation and raise awareness of modern slavery to encourage any employees who do identify potential modern slavery issues within our business or supply chain to report their concerns, either through normal channels of escalation or via our whistle-blowing line.

Next steps

Owing to the need in 2020 to respond to the Covid-19 pandemic and manage our supply chain to ensure minimal disruption for our customers, we have not progressed the areas of improvement and development identified within our modern slavery 2019 statement to the extent planned;  however, we made progress in all areas identified and will look to continue working on the key areas identified in our 2019 statement, alongside reviewing any updated legislation and supporting government guidance following the outcome of the 2020 consultation process.

Next steps will include the following:

  • Induction training on modern slavery will be rolled into our first Procurement & Supply Chain induction sessions of 2021 following the refresher training for members of the Procurement & Supply Chain function in the first half of the year.
  • Approval of the initial Key Risk Indicators identified will be sought after a period of initial tracking across the first half of the year rolling into an ongoing reporting process in time for our next Statement review.
  • Enhanced supply chain mapping across categories where there is a higher risk of the occurrence of modern slavery will be undertaken throughout the course of 2021.

Read the signed statement

Environment 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 aspects of our operations by minimising and making efficient use of resources.

Our Planet mission: Protect our business from the impact of climate change and give back more to the planet than we take out.

  • 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, use renewable electricity 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 Sustainability 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 improve environmental performance.
  • We will communicate internally and externally our environmental policy and performance on a regular basis.

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.

Flexible Working Policy

At Direct Line Group, we have a set of policies to support you to do the things that matter to you outside of work so you can flourish and thrive in work.

Whether parents, grandparents, carers or pursuing your dreams in other ways, we want to help you focus on the things that are important to you.

Our policies are simple and flexible. They recognise the fact that everyone’s circumstances are different and they’re the starting point for you to have a conversation with your people manager about balancing the things that matter in your life.

Support at Direct Line Group includes:

  • Employees with at least one year’s service receive full pay during the first 20 weeks of maternity and adoption leave. Those with six months’ service receive full pay during the first 10 weeks whilst all core benefits remain in place for all employees.
  • Shared parental leave and pay mirrors our maternity and adoption benefits and our employees can ask to split their leave into shorter periods with periods of work in between.
  • Up to 12 weeks’ full pay as part of a phased return to work following a period of maternity/adoption/shared parental leave for all employees.
  • Two weeks’ paid paternity leave for all employees.
  • Up to four weeks’ unpaid parental leave each year is also available to all parents, carers and grandparents (recognising the increasingly important role that they play in childcare).
  • A period of paid compassionate leave can be agreed for anyone experiencing, for example, the bereavement, or serious illness of, a close relative or dependent.
  • Paid time off and/or flexible working arrangements can be agreed during IVF investigations and treatment.
  • Up to 12 months unpaid lifestyle break for anyone wishing to pursue something that really matters to them such as volunteering, travelling, extending maternity leave or re-training.
  • Reasonable time off to deal with emergencies involving those that depend on them.
  • All of our employees have the right to request to work flexibly. We’ll always do our best to be as flexible as possible.

Human rights, diversity and inclusion

The Group is committed to fighting discrimination and working towards an environment that is based on meritocracy and inclusion, where everyone 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, or any other characteristic protected by applicable law.

Our diversity and inclusion practices are in line with the Universal Declaration of Human Rights and the International Labour Organisation's conventions. Our Ethical Code for Suppliers requires that all our suppliers adhere to the core International Labour Organisation standards. We support the aims of the Modern Slavery Act 2015 and are committed to ensuring that modern slavery is not present in our supply chain. In accordance with the Act, we publish an annual statement on slavery and human trafficking.

Building a diverse and inclusive culture takes multiple initiatives. We remain focused on bringing in new methods to improve our performance, ensuring that all employees take ownership in communicating the importance of inclusive behaviour. 

Our commitment to ensuring equal opportunity is included in our Code of Conduct, and reflected in everything we do, using several initiatives:

  • We have a Diversity & Dignity at Work Policy
  • Our senior leaders have Diversity and Inclusion priorities
  • We are signatories to the Women in Finance initiative
  • We have an internal diversity forum called DNA
  • We sponsored This Can Happen, a conference aimed at promoting positive mental health
  • We are members of Outstanding, which gives us mentoring programmes for both LGBT+ and BAME. Giving us access to the same suite of benefits, including programmes, events, thought leadership and advisory services
  • We have signed the Inclusive Behaviours in Insurance Pledge, setting out expected minimum standards of inclusive behaviour. It commits us to speaking up and calling out inappropriate or discriminatory behaviour, even when it is uncomfortable to do so
  • We are building inclusive leadership programmes, including unconscious bias training for all managers to assist them in managing their teams. Senior leadership teams are also setting specific diversity commitments aligned to their function’s needs, including, but not limited to, recruitment and performance decisions
  • Last year our recruitment team received training on removing gender biased language when advertising for roles, including how to use tools which identify gender specific wording
  • 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

We’re committed to ensuring the health, wellbeing and safety of all our people encouraging those employees who can work from home to do so. For employees who can’t work from home and so work at one of our offices we have completed risk assessments and introduced a number of measures, in line with and exceeding government guidance,  to reduce the risk of transmission of coronavirus including:

  • Temperature screening across all our sites
  • Enhanced cleaning of work areas and equipment between uses
  • Encouraging regular handwashing and providing hand sanitising stations
  • 2m social distancing measures including floor marking and one-way routes have been implemented in office areas
  • Introducing one way routes
  • Using screens or barriers to separate people from each other in reception areas
  • Signage has been installed across the offices at key points reminding employees of social distancing and hand washing measures
  • Communication to our employees to ensure they are fully aware of all the new measures introduced

COVID-19 information and updates are posted regularly to employees and available via our internal intranet – Covid-19 hub and the Together Wherever hub.

Legacy Executive Pension Plan

All trust-based Defined Contribution pension schemes,  including the Direct Line Group Services Pension Scheme (1993), are required to produce an annual Chair’s Statement.  
 
This, amongst other things, ensures that schemes:

  • Meet governance standards
  • Process core financial transactions promptly and accurately
  • Disclose costs and charges (including transaction costs) relating to investments

To read the statement click here

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 and prohibits political involvement of any kind on behalf of the company, which includes political donations.
  • 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. Activity and engagement involves oversight or approval from senior management. 
  • 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.

Statements under section 172 of the Companies Act 2006

Direct Line Insurance Group plc

Section 172(1) Statement

Direct Line Group is a leading motor, home and commercial insurer which depends on its reputation for high standards of business conduct and on the trust and confidence of its stakeholders to operate sustainably in the long term. The Group seeks to put its customers’ best interests first, continually invests in and engages with its employees, supports the communities in which it operates and strives to generate value for shareholders.

The Directors of Direct Line Insurance Group plc (the “Company”) have been subject to the duties codified in law, which include the duty to act in the way in which they consider, in good faith, would be most likely to promote the success of the Group for the benefit of its members as a whole, having regard to the stakeholders and matters set out in Section 172(1) of the Companies Act 2006 (“Section 172(1)”).

The Board recognises that the Group has a range of stakeholders with diverse interests and an analysis of its principal stakeholders can be found on pages 48 to 61 and on page 86.

Section 172(1) considerations are embedded in decisionmaking at Board-level and are demonstrated throughout its governance framework.

The underlying principles of promoting the success of the Company for the benefit of its members as a whole, and of considering stakeholders when making decisions that could affect them, is understood by the senior leadership team and consideration and respect for stakeholders is demonstrated throughout the Group.

The Group has adapted to a change of working practices throughout the year and keeps engagement mechanisms under review so that they remain effective and so that the Board understands the evolving needs of its stakeholders.

In taking decisions, the Directors carefully consider the balance of interests of the stakeholders who might be affected. The Board and its Committees discuss stakeholders and their interests during the cycle of Board meetings, and in 2020 we increased both the frequency and length of meetings, not least to focus on stakeholder needs as a result of the Covid-19 pandemic.

We are committed to ensuring that the Group takes action both to protect the business and to reduce its direct and indirect impact on the environment.

In March 2020, the Board considered it prudent to cancel its share buyback programme and, in April 2020, to cancel the 2019 final dividend as a result of the volatile conditions arising from the Covid-19 pandemic, although an interim and a special interim dividend were paid later in the year when conditions stabilised and on the basis of a strong capital position. See pages 86 to 87 for more detailed examples of how the Board considered Section 172(1) when making decisions that affected its stakeholders. 

Churchill Insurance Company Limited

Section 172(1) Statement

The Group is a leading motor, home and commercial insurer which depends on the trust and confidence of, and the quality of its engagement with, its stakeholders to operate sustainably in the long term. It seeks to put its customers’ best interests first, invests in its employees, supports the communities in which it operates and strives to generate sustainable profits for shareholders.

The Directors of the Company have acted in accordance with their duties codified in law, in particular their duty to act in the way in which they consider, in good faith, would be most likely to promote the success of the Company for the benefit of its members as a whole, having regard to the stakeholders and matters set out in section 172(1) of the Companies Act 2006.

The Directors of DLIG, the ultimate parent entity of the Group, are also the Directors of the Company. Except in cases in which a decision relates solely to the Company, such as arrangements for the Company’s policyholders or the adoption of new Articles of Association, the debates and decisions of the Directors concern both companies. The Group’s governance framework, which is consistent with the 2018 UK Corporate Governance Code, applied to the Company during the year. Further information about the Group’s governance arrangements can be found in DLIG’s annual report for the year ended 31 December 2020 on page 76. The Company relies on resources made available by the Group including staff and suppliers who are respectively employed and contracted by a fellow subsidiary undertaking, DL Insurance Services Limited. Disclosures relating to employees, suppliers, customers and others may be found in the financial statements of DL Insurance Services Limited and the DLIG annual report for the year ended 31 December 2020.

The Group’s vision, purpose and values are set out in the strategic report of DLIG for the year ended 31 December 2020 on page 12 and further information on the Group’s five-pillar sustainability strategy, which includes engagement with the community and protection of the environment and which applies to the Company, can be found on pages 44 to 68 in DLIG’s 2020 annual report.

The Directors consider the likely consequences of any decision in the long-term. Each company within the Group is bound by Group policies consistent with the Group’s culture in all key areas including supplier management and outsourcing, customer conduct, human resources and the environment. Group policies and minimum standards applied by the Company during the financial year included, for example, the Capital Management minimum standard to which the Directors adhered when making decisions concerning the Company’s solvency capital requirement (“SCR”). Further information on the Company’s SCR can be found on pages 2 and 23.

The Directors and management operate the business in a responsible manner with the aim of ensuring that the Company maintains a reputation for high standards of business conduct and good governance. Each year, the Directors of DLIG, who are also the Directors of the Company, review the Group's Code of Business Conduct which embodies the Group’s culture, purpose and values. The Code of Business Conduct provides guidance to the Group’s employees and contractors on the high standards of professional and ethical conduct expected of them and aims to preserve the Group’s and the Company’s reputation for high standards of conduct. Information on the Group’s Ethical Code for Suppliers can be found in the DLIG’s annual report for the year ended 31 December 2020 on page 142.

Green Flag Limited

Section 172(1) Statement and engagement with stakeholders

The Group is a leading motor, home and commercial insurer which depends on the trust and confidence of its stakeholders to operate sustainably in the long term. It seeks to put its customers’ best interests first, invests in its employees, supports the communities in which it operates and strives to generate sustainable profits for shareholders. The principal activity of Company is the provision of insurance intermediary services.

The Directors of the Company have acted in accordance with their duties codified in law, in particular their duty to act in the way in which they consider, in good faith, would be most likely to promote the success of the Company for the benefit of its members as a whole, having regard to the stakeholders and matters set out in section 172(1) of the Companies Act 2006.

One Director of the Company is a member of the Group’s principal management committee, which helps the Group’s Chief Executive Officer manage the Group’s operations and implement the Group’s strategy, including its approach to sustainability. The Group’s governance framework, which is consistent with the 2018 UK Corporate Governance Code, applied to the Company during the year. Further information about the Group’s governance arrangements can be found in DLIG’s annual report and financial statements for the year ended 31 December 2019 on page 90. The Company relies on resources made available by the Group including staff and suppliers who are respectively employed and contracted by a fellow subsidiary undertaking, DL Insurance Services Limited. Disclosures relating to employees, suppliers, customers and others may be found in the annual report and financial statements of DL Insurance Services Limited and DLIG for the year ended 31 December 2019.

The Group’s vision, purpose and values are set out in the Strategic Report of DLIG for the year ended 31 December 2019 on pages 20 and 21 and further information on the Group’s five-pillar sustainability strategy, which includes engagement with the community and protection of the environment and which applies to the Company, can be found on pages 59 to 73 in DLIG’s 2019 Annual Report.

The Directors consider the likely consequences of any decision in the long-term. Each company within the Group is bound by Group policies consistent with the Group’s culture in key areas including supplier management and outsourcing, customer conduct, human resources and the environment. Group policies and minimum standards applied by the Company during the financial year included, for example, the group accounting minimum standard to which the Directors adhered before approving the Company’s financial statements.

The Directors and management operate the business in a responsible manner with the aim of ensuring that the Company maintains a reputation for high standards of business conduct and good governance. Each year, the Directors of DLIG review the Group's Code of Business Conduct which embodies the Group’s culture, purpose and values. The Code of Business Conduct provides guidance to the Group’s employees and contractors on the high standards of professional and ethical conduct expected of them and aims to preserve the Group’s and the Company’s reputation for high standards of conduct. Information on the Group’s Ethical Code for Suppliers can be found in the DLIG’s annual report and financial statements for the year ended 31 December 2019 on page 67.

U K Insurance Limited

Section 172(1) Statement and engagement with stakeholders

The Group is a leading motor, home and commercial insurer which depends on the trust and confidence of, its stakeholders to operate sustainably in the long term. It seeks to put its customers’ best interests first, continually invests in and engages with its employees, supports the communities in which it operates and strives to generate value for shareholders.

The Directors of the Company have acted in accordance with their duties codified in law, which include the duty to act in the way in which they consider, in good faith, would be most likely to promote the success of the Company for the benefit of its members as a whole, having regard to the stakeholders and matters set out in section 172(1) of the Companies Act 2006.

The Directors of DLIG, the ultimate parent entity of the Group, are also the Directors of the Company. Except in cases in which a decision relates solely to the Company, such as the payment of a dividend, the debates and decisions of the Directors concern both companies. The Group’s governance framework, which is consistent with the 2018 UK Corporate Governance Code, applied to the Company during the year. Further information about the Company’s governance arrangements can be found in the Directors’ report on page 8. The Company relies on resources made available by the Group including employees and suppliers who are respectively employed and contracted by a fellow subsidiary undertaking, DL Insurance Services Limited. Disclosures relating to employees and suppliers may be found in the financial statements of DL Insurance Services Limited and the DLIG annual report for the year ended 31 December 2020.

The Group’s vision, purpose and values are set out in the DLIG’s strategic report for the year ended 31 December 2020 on page 12 and further information on the Group’s five-pillar sustainability strategy, which includes engagement with the community and protection of the environment and which applies to the Company, can be found on pages 44 to 46 in DLIG’s 2020 annual report.

Examples of how the Group has engaged with its stakeholders and had regard to the need to foster the Company’s business relationships with suppliers, customers and others, and the effect of that regard, including on the principal decisions taken by the Company during the financial year are detailed in DLIG’s corporate governance report for the year ended 31 December 2020 on pages 86 and 87. The Company is the principal underwriter of the Group and the combined Board meetings of DLIG and the Company monitor customer engagement by receiving customer experience and conduct and complaints reports at scheduled meetings. During 2020, the Board focused on supporting customers in financial difficulty and introduced a mileage moneyback proposition for the Company’s motor customers.

The Directors consider the likely consequences of any decision in the long-term. Each company within the Group is bound by Group policies consistent with the Group’s culture in all key areas including supplier management and outsourcing, customer conduct, human resources and the environment. Group policies and minimum standards applied by the Company during the financial year included, for example, the Capital Management minimum standard to which the Directors adhered when making decisions concerning the management of the Company’s capital and declaration of dividends. Details of decisions made regarding dividends can be found on page 3.

The Directors and management operate the business in a responsible manner with the aim of ensuring that the Company maintains a reputation for high standards of business conduct and good governance. Each year, the Directors of DLIG, who are also the Directors of the Company, review the Group's Code of Business Conduct which embodies the Group’s culture, purpose and values. The Code of Business Conduct provides guidance to the Group’s employees and contractors on the high standards of professional and ethical conduct expected of them and aims to preserve the Group’s and the Company’s reputation for high standards of conduct. Information on the Group’s Ethical Code for Suppliers can be found in the DLIG annual report for the year ended 31 December 2020 on page 142. The Company’s statement on modern slavery can be found on the Group’s corporate website.

U K Insurance Business Solutions Limited

Section 172(1) statement and engagement with stakeholders

The Group is a leading motor, home and commercial insurer which depends on the trust and confidence of its stakeholders to operate sustainably in the long term. It seeks to put its customers’ best interests first, invests in its employees, supports the communities in which it operates and strives to generate sustainable profits for shareholders. The principal activity of Company is the provision of insurance intermediary services.

The Directors of the Company have acted in accordance with their duties codified in law, in particular their duty to act in the way in which they consider, in good faith, would be most likely to promote the success of the Company for the benefit of its members as a whole, having regard to the stakeholders and matters set out in section 172(1) of the Companies Act 2006.

Most Directors of the Company are members of the Group’s principal management committee, which helps the Group’s Chief Executive Officer manage the Group’s operations and implement the Group’s strategy, including its approach to sustainability. The Group’s governance framework, which is consistent with the 2018 UK Corporate Governance Code, applied to the Company during the year. Further information about the Group’s governance arrangements can be found in the DLIG annual report for the year ended 31 December 2020 on page 83. The Company relies on resources made available by the Group including staff and suppliers who are respectively employed and contracted by a fellow subsidiary undertaking, DL Insurance Services Limited. Disclosures relating to employees, suppliers, customers and others may be found in the financial statements of DL Insurance Services Limited and the DLIG annual report for the year ended 31 December 2020.

The Group’s vision, purpose and values are set out in the strategic report of DLIG for the year ended 31 December 2020 on pages 109 to 110 and further information on the Group’s five-pillar sustainability strategy, which includes engagement with the community and protection of the environment and which applies to the Company, can be found on pages 44 to 45 in the DLIG annual report and accounts 2020.

The Directors consider the likely consequences of any decision in the long term. Each company within the Group is bound by Group policies consistent with the Group’s culture in all key areas including supplier management and outsourcing, customer conduct, human resources and the environment. Group policies and minimum standards applied by the Company during the financial year included, for example, the Group Accounting minimum standard to which the Directors adhered before approving the Company’s financial statements.

The Directors and management operate the business in a responsible manner with the aim of ensuring that the Company maintains a reputation for high standards of business conduct and good governance. Each year, the Directors of DLIG review the Group's Code of Business Conduct which embodies the Group’s culture, purpose and values. The Code of Business Conduct provides guidance to the Group’s employees and contractors on the high standards of professional and ethical conduct expected of them and aims to preserve the Group’s and the Company’s reputation for high standards of conduct. Information on the Group’s Ethical Code for Suppliers can be found in the DLIG annual report for the year ended 31 December 2020 on page 142.

UK Assistance Accident Repair Centres Limited

Section 172(1) Statement and engagement with stakeholders

The Group is a leading motor, home and commercial insurer which depends on the trust and confidence of its stakeholders to operate sustainably in the long term. It seeks to put its customers’ best interests first, invests in its employees, supports the communities in which it operates and strives to generate sustainable profits for shareholders.

The Directors of the Company have acted in accordance with their duties codified in law, in particular their duty to act in the way in which they consider, in good faith, would be most likely to promote the success of the Company for the benefit of its members as a whole, having regard to the stakeholders and matters set out in section 172(1) of the Companies Act 2006.

The Directors of the Company are members of the Group’s senior management population, which supports the Group’s Chief Executive Officer in managing the Group’s operations and implementing the Group’s strategy, including its approach to sustainability. The Group’s vision, purpose and values and the five-pillar sustainability strategy, which includes engagement with the community and protection of the environment, are set out in the Strategic Report of DLIG for the year ended 31 December 2020 on page 12 and pages 109 to 110. The Group’s governance framework, which is consistent with the 2018 UK Corporate Governance Code, applied to the Company during the year. Further information on the Company’s governance arrangements can be found in the Directors’ report on page 7. The Company relies on resources made available by the Group including staff and suppliers who are respectively employed and contracted by a fellow subsidiary undertaking, DL Insurance Services Limited. Disclosures relating to employees, suppliers, customers and others may be found in the annual report and financial statements of DL Insurance Services Limited and DLIG for the year ended 31 December 2020.

Examples of how the Group has engaged with its stakeholders and had regard to the need to foster the Company’s business relationships with suppliers, customers and others, and the effect of that regard, including on the principal decisions taken by the Company during the financial year are detailed in DLIG’s annual report and financial statements, for the year ended 31 December 2020 on pages 86 to 87. The Company operates the Group’s motor vehicle repair centres. Thr Group’s ‘Greener, Cleaner Action Plan’ aims to mitigate the Group’s impact on climate change and aims for the Company to be the most energy efficient repair network in the UK, by investing in it’s estate and repair processes.

The Directors consider the likely consequences of any decision in the long-term. Each company within the Group is bound by Group policies consistent with the Group’s culture in all key areas including supplier management and outsourcing, customer conduct, human resources and the environment. Group policies and minimum standards applied by the Company during the financial year included, for example, the Group Accounting minimum standard to which the Directors adhered before approving the Company’s financial statements. The Group’s Capital Management minimum standard was applied when the Directors made decisions concerning the declaration of dividends.

The Directors and management operate the business in a responsible manner with the aim of ensuring that the Company maintains a reputation for high standards of business conduct and good governance. Each year, the Directors of DLIG review the Group's Code of Business Conduct which embodies the Group’s culture, purpose and values. The Code of Business Conduct provides guidance to the Group’s employees and contractors on the high standards of professional and ethical conduct expected of them and aims to preserve the Group’s and the Company’s reputation for high standards of conduct. Information on the Group’s Ethical Code for Suppliers can be found in the DLIG’s annual report for the year ended 31 December 2020 on page 142. The Company’s statement on modern slavery can be found on the Group’s corporate website.

DL Insurance Services Limited

Section 172(1) Statement and engagement with stakeholders

The Group is a leading motor, home and commercial insurer which depends on the trust and confidence of its stakeholders to operate sustainably in the long term. It seeks to put its customers’ best interests first, invests in its employees, supports the communities in which it operates and strives to generate sustainable profits for shareholders.

The Directors of the Company are subject to duties codified in law, in particular their duty to act in the way in which they consider, in good faith, would be most likely to promote the success of the Company for the benefit of its members as a whole, having regard to the stakeholder and matters set out in section 172(1) of the Companies Act 2006.

Most Directors of the Company are members of the Group’s principal management committee, which helps the Group’s Chief Executive Officer manage the Group’s operations and implement the Group’s strategy, including its approach to sustainability.  The Group’s vision, purpose and values and the five-pillar sustainability strategy, which includes engagement with the community and protection of the environment, are set out in the strategic report within the DLIG annual report for the year ended 31 December 2020 on page 12, and pages 109 to 110.  The Group’s governance framework, which is consistent with the 2018 UK Corporate Governance Code, applied to the Company during the year.  Further information on the Company’s governance arrangements can be found in the Directors’ report on page 7.

The principal activity of the Company is the provision of services to DLIG and other companies in the Group, including contracting with suppliers, buying or leasing premises and employing staff.  Further information on the Company’s engagement with employees can be found in the Directors’ report on pages 6 and 7 and in the corporate governance report within the DLIG annual report for the year ended 31 December 2020 on pages 86 to 87.

Examples of how the Group has engaged with its stakeholders and had regard to the need to foster the Company’s business relationships with suppliers, customers and others, and the effect of that regard, including on the principal decisions taken by the Company during the financial year are detailed in the corporate governance report within  the DLIG annual report, for the year ended 31 December 2020 on pages 86 to 87.  The Company enters into substantial majority of all contracts with suppliers to the Group and, during the year, the Directors had particular regard to maintaining a relationship a relationship with the major suppliers engaged in systems integration, the provision of new technology and platforms for trading systems.

The Directors consider the likely consequences of decisions in the long term.  Each company within the Group is bound by Group policies consistent with the Group’s culture in all key areas including supplier management and outsourcing, customer conduct, human resources and the environment.  Group policies and minimum standards applied by the Company during the financial year included, for example, the Cyber Risk minimum standard, to which the Directors adhered when making decisions concerning the Group’s transformation programmes to deliver technology and organisational change.

The Directors and management operate the business with the aim of ensuring that the Company maintains a reputation for high standards of business conduct and good governance.  Each year, the Directors of DLIG review the Group’s Code of Business Conduct, which the Company also applies, which embodies the Group’s culture, purpose and values.  The Code of Business Conduct provides guidance to the Group’s employees and contractors on the high standards of professional and ethical conduct expected of them and aims to preserve the Group’s and the Company’s reputation for high standards of conduct.  Information on the Group’s Ethical Code for Suppliers, which the Company also applies, can be found in the DLIG annual report for the year-ended 31 December 2020 on page 142.  The Company’s statement on modern slavery can be found on the Group’s corporate website.