We have been made aware of potentially fraudulent activity in relation to DLG bonds where members of the public have been contacted and asked to invest in our bonds. We never contact people to sell bonds. If you are contacted by anyone asking you to invest in our bonds we encourage you to report this to Action Fraud, the UK’s national fraud and cyber reporting centre. If you have any further questions or concerns then please email our Investor Relations team.   

These reports, policies and statements outline our position to our different stakeholders

Reports

2022 Reports

Annual Reports and Accounts 2021

Download now

2021 Gender & Ethnicy Pay Gap Report

Download now

SASB Disclosure 2021                             

Download now

2021 Reports

Sustainability Report 

Download now

   

Gender Pay Gap Report

Download now

Climate Change Report

Download now

   

Annual Report & Accounts 2020

Download now

Black Inclusion Report

Download now

2020 Reports

TCFD Report 

Download now

 

 

Annual Report and Accounts 2019

Download now

Sustainability Report

Download now

Gender Pay Gap Report

Download now

Anti-Bribery & Anti- Corruption Policies

Code of Business Conduct

Download the Code of Business Conduct here

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.

Ethical Code for Suppliers

Download the Ethical Code for Suppliers here

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.

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.

Sanctions

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.

Whistleblowing

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.

Whistleblowing Policy

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 call  the freephone number on 0800 316 0516 to make a disclosure or click on this link: https://secure.ethicspoint.eu/domain/media/en/gui/108494/index.html

 

Business Model Policies

Board Diversity Policy

Purpose and scope

The Board of Direct Line Insurance Group plc, U K Insurance Limited and Churchill Insurance Company Limited believes that having diverse representation and an inclusive culture is essential for the long-term sustainable success of the business. This Policy applies to the Board and aims to promote diversity and inclusion in its composition. The Group's wider commitment to diversity and inclusion is encapsulated in a Group diversity policy.

Board diversity

The Board sets the tone for diversity, equity and inclusivity in the management of DLG’s business. It 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 range of gender, ethnicity, skills, experience and cognitive diversity, as well as diversity of socio-economic, educational and professional background.

The Nomination and Governance Committee regularly reviews the composition of the Board, seeking to balance its skills, experience, knowledge and independence to put it in the best position 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. In addition, the Committee oversees executive succession planning and the development of the talent pipeline, which aims to drive diversity, including gender and ethnic diversity, throughout the organisation and into senior management positions.

The Board is also supported by its Sustainability Committee which, as part of its supervision of the People Pillar of DLG’s sustainability strategy, oversees the Group’s performance in diversity and inclusion initiatives and practices.

Measuring progress

At the date of this Policy, the Board has met the targets established by the Hampton-Alexander and Parker reviews. The Board has also met the FTSE Women Leaders Review target of 40% women on boards by 2025. Currently, 40% of its members are women, including the Chair and the Chief Executive, and one member of the Board has an ethnic minority background. The Board aims to preserve and further improve 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.

Review

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 24 March 2022

Complaints Data

At Direct Line Group we always seek fair outcomes for our customers. We welcome all feedback from our customers because it gives us a chance to put things right. We aim to deal with every complaint quickly and fairly, and to learn from our mistakes so we can improve our service. The following data details the volumes of complaints reportable to the Financial Conduct Authority (FCA) for each half year since January 2012.

Firm Name:

U K Insurance Limited

Other firms included in this report (if any):

None

January - June 2022

July - December 2021

January – June 2021

July – December 2020

Jan - June 2020

July – Dec 2019

Jan - June 2019

July – Dec 2018

Jan - June 2018

July – Dec 2017

Jan - June 2017

July – Dec 2016

 

Crisis Preparedness Policy

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.

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

Net Promoter Scores

We put our customers at the heart of everything we do. Our long-term sustainability is driven by understanding customers’ needs and acting in their best interests. As part of our customer strategy, and to ensure that the business strives to achieve a sustained and competitive level of service, the Board sets challenging customer centric KPIs. These are intended to ensure that remuneration is aligned with and supports continuous improvement.

Net Promoter Score (“NPS”) is an index that measures the willingness of customers to recommend products or services to others. It is used to gauge customers’ overall experience with a product or service, and customers’ loyalty to a brand. Overall, performance on the customer agenda against our 11 key customer metrics remains very strong, with the Direct Line and Churchill brands performing well in independent customer experience benchmarking studies and good progress on key Net Promoter Score measures and customer journeys.

We understand that customer expectations are continually changing. As a result we continue to strive forward, aim higher and improve what we deliver for our customers. We pride ourselves on continually improving the customer journey through a series of incremental improvements. That is why we have introduced a new customer experience framework, helping us to focus on customers and their needs. 

  DL
Index
CH
Index
2013 (12MR) 100 100
2014 (12MR) 110.8 110.3
2015 (12MR) 118.3 109.2
2016 (12MR) 129.1 116.7
2017 (12MR)

2018 (Oct YTD)
144.0

145.5
124.6

124.5

To view our performance over the last 3 years 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.

Responsible Investment

As Direct Line Group’s investment strategy evolves, the company is regularly looking for ways to align its investment practices with Environmental, Social and Governance ("ESG") issues. The investment strategy is determined by the Director of Investment Management and Treasury and approved by the Direct Line Group Investment Committee.

To date, the Direct Line Group investment strategy has reflected the following initiatives:

Corporate credit assets account presently for three quarters of the total investment portfolio benchmark. Initiatives within corporate credit include:

  • the majority of assets are managed in portfolios where investment objectives include the requirement to achieve at least a weighted average MSCI ESG rating of ‘A’; 

  • portfolio managers are encouraged to prefer investments in green bonds where they offer a similar risk-reward profile to other issues;

  • the company has committed to reducing the weighted average Green House Gas Emissions Intensity1 by 50% before the end of 2030 (benchmarked against the end of 2020 levels);

  • issuer exclusions include (1)  companies which manufacture controversial weapons2 , (2) mining companies that generate >5% of revenues from thermal coal production3, (3) electricity generators that derive >5% of revenues from thermal coal power generation3 and (4) any companies that are developing new thermal coal plants or new thermal coal mines.

All externally managed assets are run by managers who are currently signatories to the United Nations-supported Principles for Responsible Investment; 

Almost 90% of the investments in the infrastructure debt portfolio are in schools, hospitals and other social infrastructure assets;

The commercial property portfolio invests only in assets with an energy efficiency level of D or higher (or with apportioned funds to achieve this level), exceeding the government’s present minimum requirement of an E rating.  The portfolio also has a tailored set of 2022 ESG targets which cover, inter alia, carbon, energy, water and waste.

1Green House Gas (GHG) Emissions Intensity is the weighted average scope 1 and scope 2 GHG emissions in tonnes per million USD of sales

2Controversial weapons include cluster munitions, landmines, and chemical & biological weapons 

3Companies considered to be taking positive climate action (PCA) may be held in the portfolio. A PCA company is one which has either committed to Science Based Targets for reducing GHG emissions, or has a “2 degrees or better” Carbon Performance Alignment from the Transition Pathway Initiative (TPI)

 

Risk Behaviours and Attitudes

The Risk Function uses the Assessment of Risk Behaviours and Attitudes (ARBA) to keep driving improved attitudes and behaviours across the Group, and the Risk Communications Plan to ensure that there is a consistent understanding of risk management and the concept of risk ownership throughout the Group.

The ARBA approach was developed jointly by Risk and Group Audit (GA) functions to assess the Group’s risk behaviours and attitudes. ARBA makes use of a number of indicators, including the various interactions Risk and GA have with the organisation during the year, observations from individual GA audits, observations from committees and risk and action management.  Risk and GA use these observations to form a view of the Group’s position across various areas including:  tone from the top, decision-making and the Risk Management Framework as well as the Group’s response to Covid-19 and the implementation of the Group’s new ways of working as part of the business transformation programme.

In 2020, the Plan featured a programme of activity to reinforce the message that risk is everyone’s responsibility. It involved staff awareness campaigns and feature articles on the internet. 

A major part of the 2020 Risk Communications Plan was the imaginative ‘Risk Heroes’ campaign which enabled members of staff to harness social media and mobile phone photograph filters.  The approach enabled Risk to engage with colleagues about the importance of risk management in an interesting and conversational way, and was the most successful campaign of its kind for the Group, garnering over 3600 click-throughs and online interactions.

The Risk Communications Plan was supplemented by other mechanisms such as training for the business and other business as usual activity. As a result of this, Risk increased its visibility, increased staff understanding of risk and built relationships across the Group.

Underwriting Standards

DLG considers Environmental & Social responsibilities as part of its underwriting practices. For example, we are a member of the Flood Re scheme helping customers whose property may be at risk of flooding obtain affordable insurance.  Our approach to flood modelling supports strong risk assessment of properties in flood prone areas helping ensure customers can access insurance and benefit from this joint initiative between the government and insurers. Linked to this, we offer support to our customers in raising awareness of the potential benefits and availability of flood resilient repairs during the claims process.

Within commercial lines business we employ surveyors that visit numerous clients to provide professional advice on all elements of insurance risk around their business. This feedback can help businesses to act more responsibly with respect to their immediate environmental and resultant impacts on their local community.

All of our business areas expect all of our suppliers to comply with all relevant laws and regulations. 

Employee Policies

Flexible Working Policy

Here at Direct Line Group we support our people to work at their best. And we know that offering choice, flexibility and a good work life balance help us to achieve that.

We all have different things that matter to us – whether that’s driven by our stage of life, external commitments or personal interests. We value these differences and are committed to supporting your unique blend of work and home life where we can.

That’s why we offer a variety of working arrangements – from how you divide the time you spend working at home and in the office, to flexibility in the hours you work. It includes different working patterns, being flexible to support outside of work activities, supporting you in times of crisis, and understanding changing needs which might include when you are expecting an addition to your family, winding down to retirement or when you need to care for others.

These arrangements will depend on the type of role you do and the area of the business you work in. Speak to your hiring manager or recruiter to find out what’s possible in the role you’re applying for. It’s about finding the right balance that works for you, our business and our customers.

Where you work

We’ve introduced a hybrid working model at Direct Line Group, where most of our people split their time between home and the office. There are also some people who will spend most of their time working from home, and some who will spend most of their time working from a site.

There’s no one-size-fits-all approach across Direct Line Group, so we’ve created a simple framework with three areas – hybrid working, home first and location first.

Hybrid working

Most of our people split their time between home and the office, including those in our customer-facing and central function roles. There are lots of positives about working from home – it can be a quiet place to focus and get things done, it provides flexibility between personal and work commitments and less time is spent commuting. But it’s also important that we can connect with each other, and you can’t beat doing that in person. Spending time working together in our offices, sharing ideas, collaborating on projects, or having a natter over a break.

How much time our people time spend working at home versus the office will vary for each business area and team, depending on the requirements of the role and how often you need to be in the office. It could vary from a couple of days a week to a couple of times a month.

Home first

There are some people who work from home most of the time, including people we’ve recruited on that basis. We know that for them connecting with their colleagues is just as important – and we’ll provide ways to strengthen those relationships and explore opportunities for them to spend time at a Direct Line Group site during the year.

Location first

Some roles by their very nature are based 100% at one of our sites, for example colleagues who support our customers in our Auto Services repair centres.

The hours and pattern you work

Normal working hours mean different things to different people. We welcome applications for full time, part-time, job sharing or flexible hours for the majority of our roles. We’ll always aim to support flexible working where we can, but this will of course depend on the role and area of the business. Some of our customer facing teams and Auto Services repair centres have specific shift patterns which your hiring manager or recruiter will be able to share.

Here are some of the options available:

  •  Full time – You’ll work a standard number of full time hours across set days each week or a variable shift pattern each week.
  • Part time – You’ll work fewer hours a week than someone on a full time contract, either by working on fewer days, or for fewer hours each day
  • Job share – You and a colleague share the duties of one full time job, with each of you working part time hours
  • Flexible start/finish times – Vary your start and finish times, covering core working hours, completing your contracted hours in the way that suits you best
  • Compressed hours – You compress your regular normal working week into fewer days for example a nine-day fortnight

Parental and other leave

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.

That’s why we have a range of policies to support you to do the things that matter to you outside of work so you can flourish and thrive in work. They recognise the fact that everyone’s circumstances are different and are the starting point for you to have a conversation with your people leader 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.

Health & Safety Policy

Download the Health & Safety Policy here

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.

Political Involvement Policy

Download Political Involvement Policy

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.

Environment Policies

Environment Statement

Download the Environment Statement here 

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.

Human Rights Policies

Human Rights, Diversity and Inclusion

Download the Human Rights &Diversity and Inclusion Policy

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.

Modern Slavery Statement

Read the signed statement

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 2021 and is the 6th 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.

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 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. 

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. As an organisation we have a published Human Rights, Diversity & Inclusion Policy.

Supply Chain

We recognise that, as one of the UK’s leading general insurers, our responsibilities can extend beyond our own commercial interests. Although DLG, as a general insurer, can be seen as within a lower risk industry it is still important to highlight areas within our supply chains that can be more vulnerable to the potential risks. Throughout the implementation and embedding of the Modern Slavery Act and key responsibilities within DLG the focus has been on suppliers that provide services direct to DLG whilst understanding the areas within our supplier’s supply chains that could be a higher risk area and building those into our future action planning activity. 

Through our Ethical Code for Suppliers, available on our external website (see link) and shared with suppliers when tendering, we have outlined both 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. It is our intention to refresh this code in 2022 and rolling out to our managed supply chain.

In addition, we expect our 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, where applicable. Through our risk mapping activity it has been identified that the areas where we feel there is more vulnerability across the supply chain tend to be those supply chains where we have suppliers who fall below the reporting threshold of The Act, although this is taken into consideration in the design of our Procurement processes.

In 2021, we have reviewed our actively managed supply chain and have identified that 71% of those suppliers are required to have statements published and of those 71%, 95% have published statements

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 our products (rescue provisions or claims management) across our key product areas. 

Household

Our household claims supply chain can be split into two key areas, Building Repair and Contents repair and replacement. The fulfilment of our building claims is primarily through a network of home repair providers, supported by specialist disaster and restoration supply chains. Within this supply chain there is a requirement for more seasonal, volume driven and manual labour to support the service provision alongside the addition of subcontracted services, particularly where there is response to severe weather events which can lead to the labour force being more vulnerable to potential Modern Slavery exposures.

Our repair and replacement supply chain for our household contents claims includes 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. Although the direct services provided by these suppliers are lower risk in their provision the goods being provided do extend beyond our contracted supply chain and out-with 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 repair within our own Auto Services including parts replacement, paint, equipment needed for car repair and, in a small number of repair centres, outsourced car valets. The motor repair industry is a global network of manufacturers and so the source of many of the parts that are used by DLG Auto services, our Green Flag recovery providers and our ThirdParty repairer networks come via extended 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

DLG has a centralised Procurement and 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. Supporting processes are reviewed on an annual basis and refreshed to ensure they remain relevant and aligned with the potential exposures faced by DLG.

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, we also review our Modern Slavery risk assessment on an annual basis, enhancing the data captured through additional information available, to overlay a proportionate depth of analysis on the areas that have greater vulnerability.

Through 2021 this assessment , which allows us to identify any areas where we may have increased risk across areas including the geographical location from which services are provided, length of the supply chain, use of migrant or temporary labour and the nature of the goods or services being supplied, has been adapted to include key information to size the areas of focus - cross referencing the expenditure, tiering and audit status of our supply chain. This assessment process also forms the basis of the development of our risk indicators.

As part of the Sourcing process, due diligence is undertaken on new suppliers sourced through the Procurement and Supply Chain function where our engagement threshold is for activity resulting in expenditure of £100,000 or higher across the term of engagement. We request suppliers to either provide a link to their most recent Modern Slavery statement or respond to a number of questions (should they fall below the reporting threshold) to articulate the steps they are undertaking to support the Act. As an enhancement of this process we will be looking to provide our sourcing community relevant information pertaining to Modern Slavery from the central data gathering and, where applicable, assurance activity.

On-boarded suppliers are subject to assurance activity. Our Supplier Compliance Monitoring team conducts regular field reviews on 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 contractual clauses also forms part of the assurance scope which looks at employees’ right to work and proof of residence alongside compliance to the overall contractual terms.

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

Training

Modern Slavery training within the Procurement function is carried out as part of the annual schedule of mandatory training, tailored to support the individual supply chain categories and updated annually to include any updates, examples and relevant process changes. Basic guidance is now included with the Risk & Governance section of the induction process within the function.

Next steps

As we continue to develop our understanding and approach to Modern Slavery within our supply chain, we are looking at how we can improve on the activity we have implemented through a number of key activities.

  • Continue to enhance our supply chain analysis, incorporating information collated from our suppliers, due diligence, and assurance activity
  • Build on existing key risk indicators to develop a suite of management information pertaining to Modern Slavery for procurement colleagues
  • Define a centralised reporting mechanism for Key Risk indicators
  • Complete a refresh of the existing Ethical Code for suppliers
  • Increase awareness of Modern Slavery beyond those within our Procurement and Supply Chain team 

Social & Community Matters Policies

Corporate Website Privacy Notice

1. Introduction

Direct Line Group is committed to protecting the personal data that we collect from users of our corporate website and individuals who subscribe to our email alert service. This Privacy Notice summarises:

  • Who ‘we’ are
  • The categories of data we collect and the purposes of processing
  • How we share your data
  • How we retain and protect your data
  • Your rights under Data Protection law
  • How you can contact us
  • Please click here if you are looking for our Data Privacy Policy, which provides more detail on our privacy and security programmes, framework and governance.

2. Who ‘we’ are

DL Insurance Services Limited is the data controller in respect of the information covered by this Privacy Notice.

3. Categories and sources of data collected

To provide you with the services offered on our website, we collect the following types of data:

  •  Personal details - including name, country and occupation.
  • Contact details - including email addresses.
  • We may collect other data where we have used cookies to collect information from your computer or portable electronic devices. Please see our cookies policy for more information.

If you do not provide information that we require, we will be unable to provide you with these services.

4. Purpose and Legal Basis of processing

We and/or persons acting on our behalf may process your personal data for any of the following purposes:

  • To provide you with tailored email alerts that highlight significant changes on our website (the ‘email alert subscription service’) related to company news and results information.
  • Any other legitimate business purpose or as otherwise permitted by any applicable law or regulation to facilitate the organisation and delivery of activities that support your ongoing relationship with us.
  • For each of the purposes outlined above, one or more ‘Legal Bases’ for processing apply. The relevant conditions are outlined below, in order of our level of reliance upon them:
  • Consent – This accounts for the processing performed to provide the email alert subscription service and to keep you informed about other products and services that may be of interest.
  • Necessary for legitimate interests – This is only used where processing that we wish to undertake is not based on consent. For example, storing of IP addresses for limited periods of time to assist with operational or troubleshooting purposes.

5. How we share your data

To fulfil the purposes for which personal data is processed, we may share personal data with a range of individuals, external companies and other organisations.

Any disclosures of personal data are made using the minimum personal data necessary for the specific purpose and circumstances. Information is only shared with third party organisations where deemed necessary to fulfil the services describer above or where you have consented to the disclosure of your personal data to such persons.

We may obtain and share personal data on a regular and ongoing basis with a wide variety of organisations, which may include but is not limited to:

  • Third parties who process your personal data on our behalf (such as the providers of our corporate website hosting services and email alert subscription service).
  • Any regulatory, exchange body, enforcement, or court where we are required to do so by applicable law or regulation or at their request.
  • Any subsidiary of the ultimate holding company, Direct Line Insurance Group plc, as required for the proper conduct of our business.

6. Where we may transfer your data

The personal data we collect from you may be processed in (including accessed in or stored in) a country or territory outside the United Kingdom, which may not enforce the same level of protection by law or regulation. To safeguard your data, we put in place contractual obligations with third parties, to define technical and organisational measures to provide appropriate protection.

7. How we retain your data

We will only retain your personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. For example:

Personal and contact details used for the email alert subscription service are processed for the duration of the service provision.

IP addresses are stored for 14 days to assist with operational or troubleshooting purposes.

Depersonalised web analytics data is held up to 1 year for website performance trending.

Please be advised that you can change your alerting preferences or unsubscribe at any time directly by visiting our email alert page, or by following ‘unsubscribe’ links in our alert emails.

8. How we protect your data

We are committed to protecting your personal data and maintain a robust Information Security framework to ensure it remains confidential and secure.

Our approach to Information Security is formalised within the Cyber Risk Minimum Standard and supported by further policies, requirements for Third Party Suppliers and security awareness initiatives.

9. Your rights

Under Data Protection law, you have various rights in relation to your own data (i.e. where you are the ‘data subject’), which are summarised below:

1.    Right of Access

You have the right to request a copy of all the personal information that we have about you. Please note that you can directly access the data we hold about you by visiting our email alert page.

2.    Right to Rectification

You have the right to ask us to update information that we hold about you where it is incorrect or incomplete. Please note that you can change your alerting preferences or unsubscribe at any time directly by visiting our email alert page.

3.    Right to Erasure

You have the right to request the deletion of your personal data, for example where processing is no longer necessary for the purposes for which the data were collected.

4.    Right to Restriction of Processing

You can ask us to stop processing your data (i.e. we cannot make any further changes, delete, or share it). For example, this could be where you wish to challenge the accuracy of data or where you make use of your ‘Right to Object’.

5.    Right to Data Portability

You are entitled to an electronic copy of the data that you provided to us as part of subscribing to the email alert service.

6.    Right to Object

You can object to processing conducted under the ‘Legitimate Interest’ condition (as outlined in Section 4 “Purpose and Legal Basis of processing”) and we must then cease processing unless we can demonstrate compelling grounds.

7.    Right to withdraw consent

You have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

8.    Automated decision-making and profiling

You have the right not to be subject to a decision which is based solely on automated processing (including profiling), which would have a significant or legal effect on you. You have the right to contact us to express your point of view and challenge the decision.

To exercise these rights, please contact us as described in Section 11 “How to contact us”.

Please note that there will be situations where exceptions apply under Data Protection law that we may rely on. We will tell you if we are unable to comply with your request, or how your request might impact you, when you contact us.

10. How we update this Privacy Notice

We may update this Privacy Notice at any time, in accordance with applicable legislative and regulatory requirements or our internal policies and processes. Service users may be notified of significant changes, for example via an email communication.

11. How to contact us

If you would like to discuss any aspect of this Privacy Notice or anything else about the personal data we collect on you, please contact us using the details below.

Specific queries in relation to exercising your Rights should be directed to:

The Data Protection Officer, DL Insurance Services Limited, Churchill Court, Westmoreland Road, Bromley, BR1 1DP

12. Complaints

If you have any concerns or complaints in relation to the processing of your data, we ask that you contact us first to give us the chance to understand the issue and see how we can address it.

In any event, you have the right to lodge a complaint with our supervisory authority, the Information Commissioners Office. To report a concern to the ICO:

  • Telephone helpline 0303 123 1113
  • Textphone service 01625 545860
  • ico.org.uk/concerns/

Data Privacy Policy

Summary

Direct Line Group (DLG) has implemented a control framework to manage privacy and security risks to meet our responsibilities under data protection legislation, following regulatory and industry guidance and standards. Governance forums ensure privacy and security considerations receive high levels of visibility. All business areas within the Group are required to meet the standards set out in our privacy and security framework. Our internal standards require all business lines and subsidiaries to adhere to and evidence compliance with UK GDPR obligations, including implementing privacy by design, fulfilling data subject rights and reporting and resolving potential incidents. Security controls have been reviewed against UK GDPR requirements. All staff, including temporary staff and contractors, are trained on their data protection and security responsibilities and are contractually subject to confidentiality obligations.

Direct Line Group’s Privacy Programme

The Group has implemented a clear Target Operating Model to instill a privacy focused culture across the organisation, through a Three Lines of Defence Model. We have an established first line Privacy team who work with business areas to build privacy requirements into our processes. Regular assurance and audit activity is conducted to demonstrate our commitment to our privacy standards.

Our Privacy and Data Protection Officer (DPO) provides independent oversight and challenge as part of our second line risk function in accordance with their responsibilities under UK GDPR and provides Board Level reporting at least annually. This is supported by regular reporting to the Board by the Chief Information Security Officer on security aspects.

Internal Audit, who perform robust periodic audits to assess compliance, constitute our third line of defence.  Identified control deficiencies are logged, tracked and managed to resolution.

Privacy Framework

DLG maintains an extensive privacy and security framework to meet the requirements of the UK General Data Protection Regulation ( UK GDPR) and the Data Protection Act 2018, including processes to enable DLG to demonstrate accountability and adherence to UK GDPR obligations. Records of processing activities have been documented. All business areas are required to collect and process personal information fairly and lawfully, including clearly defining the purpose of any use of data, as outlined within our Privacy Policy. Controls are in place to ensure that personal information collected is accurate and up to date.

Our fair processing notices (Privacy Policy) provide transparency to individuals as to how their personal information will be processed. These notices meet the requirements of UK GDPR to ensure individuals are informed as to what personal information is collected, how it will be processed, why we are legally permitted to use their data in that way and how to exercise their rights. For further information, please see:

An Employee Privacy Notice is also provided internally to all DLG staff.

Processes to fulfil requests from individuals exercising their rights under UK GDPR are embedded within DLG, allowing individuals to receive responses within the prescribed timelines under UK GDPR. Individuals are clearly informed how to exercise all of their rights under GDPR  in our Customer Privacy Notice and Corporate Website Privacy Notice  to facilitate a response from our dedicated Data Rights Team. Where possible, functionality has been created to allow individuals to correct their information easily and self-serve where possible.

Concerns, complaints and queries about our use of personal information can be addressed directly to the organisation’s Data Protection Officer, contact information is available in our Privacy Notices.

We have a bespoke privacy incident reporting process which has been enhanced to enable all incidents, breaches and near misses to be identified and escalated to the Privacy Team and DPO for review. This process enables DLG to assess any risk of harm to data subjects and meet requirements to notify the Information Commissioner’s Office (‘ICO’) within 72 hours as prescribed under GDPR. This process also enables data subjects to be notified as soon as possible, where required.

Our change governance process enables early assessment of privacy and security risks and a culture of Privacy and Security by Design. All new initiatives which involve the use of personal information are required to undertake an impact assessment, through use of an online tool, which are reviewed by security and privacy teams for validation before the initiative can go live. We ensure all systems which are used to record or process personal information have the functionality to correct, delete and, where appropriate, support a request to exercise the right to erasure (right to be forgotten) and restrict processing of personal information. We also apply the UK GDPR concept of ’data minimisation’, collecting the minimum amount of personal information necessary to fulfil our purposes for processing the information, using technology solutions to support this. DLG also use technology to anonymise or pseudonymise data sets where required.

Significant investment has been made to our retention strategy so that personal information is not kept longer than required, and the defined periods have been set out within our retention schedule. Once the retention period ends, the data is either deleted, anonymised or put beyond use in accordance with the ICO guidance. As a general rule, customer information is retained for 6 years from the end of the customer’s relationship with DLG to comply with regulatory requirements or to allow us to process claims. Data related to unaccepted quotes are retained for 90 days or for the period the quote is valid for plus 30 days (whichever is the greater), and then for a limited time after for fraud prevention purposes.

Requests for information from government bodies, law enforcement agencies and public authorities are handled by a dedicated disclosure unit who follow regulatory guidelines on data sharing practices and in compliance with data protection legislation.

Direct Line Group’s Security Programme

The DLG Information Security, Risk and Assurance department is led by the Chief Information Security Officer (CISO), who has responsibility for cyber security, risk and business resilience programs. The CISO reports to the Chief Operating Officer (COO). Periodic updates on cyber security, technology risk and business resilience programmes are provided to the Board of Directors and executive management.

Appropriate technical and organisational measures are implemented to protect personal information. DLG utilises sophisticated tools designed to protect information and prevent data breaches.  In addition, we proactively perform self-assessments against our regulatory frameworks such as the NIST cyber security Framework and compliance with our internal cyber security controls is validated through the use of security monitoring utilities and through rigorous audits. External independent audits are conducted at a minimum of once every two years. Legal, regulatory and contractual obligations are reflected in and exceeded by the mandatory requirements of DLG’s Minimum Standards framework, against which performance is measured and audited.

DLG’s encryption policy is to secure data in accordance with industry best practice, such as compliance with encryption requirements set out in the PCI DSS both at rest and in transit.  We participate in vulnerability information sharing networks and track industry and government intelligence sources for impact in the marketplace and deploy necessary updates as appropriate. DLG has a robust software patch management process that includes risk assessment and risk-based update schedules. These systems are designed, implemented and maintained to provide a high level of security to safeguard sensitive data.

DLG has implemented a Cyber Response Framework. The framework is a set of coordinated procedures and tasks that are executed to ensure timely and accurate resolution of computer security incidents.

Governance

The Policy and Minimum Standards Framework governs our business directorates and helps to ensure that personal and company data is protected in line with our obligations under data protection legislation and ensure adequate technical and organisational measures are in place to protect personal information. All business areas are required to comply with the Minimum Standards and attest and evidence compliance with each standard.

We have an established Privacy & Data Protection Minimum Standard..

DLG also has a Cyber Risk Minimum Standard, which incorporates a number of Information Security Minimum Requirements (ISMRs) including user access controls to limit access to personal information to a need to know basis, network, application and operational security and third party supplier security. All ISMRs are reviewed on an annual basis.

The Information Management Minimum Standard defines our approach to record keeping and retention of both personal and corporate information.

Privacy and data security is within the remit of our Risk Management Committee, who review our Policy and Minimum Standard Framework on an annual basis. We have also established a group-wide Privacy & Information Management Steering Committee which reviews any privacy risks and developments across the business. Issues are escalated to the Customer Conduct Committee, Operational Risk Committee, Risk Management Committee or Board Risk Committee as appropriate.

Third Parties

DLG  shares the minimum data necessary with third parties and specifically notes how data is shared in the Privacy Notice and Privacy Policy. The organisation utilises a comprehensive information security due diligence and oversight process for its third-party vendors. Prior to the commencement of services, we perform a risk/impact rating assessment of all vendors that will have access to and process DLG information and conduct formal, comprehensive privacy and security assessments on service providers. Re-assessment occurs on an ongoing basis, the frequency of which is determined based on a risk assessment and rating process. The assessment process utilises a variety of tools to address aspects of the vendors' cyber security controls and policies, including business resilience and privacy and data protection. Regular onsite assessments are undertaken for vendors perceived to carry higher inherent risk.

All third parties are expected to meet data protection standards including UK GDPR obligations. UK GDPR compliant contractual clauses are in place with third parties to ensure they meet the high standards demanded. We also require all suppliers to meet our high security standards and adhere to our Information Security Minimum Requirements. Suppliers are contractually required to meet and demonstrate adherence to these requirements.

Tax Policy

Tax Contribution

Direct Line Group makes a substantial tax contribution to the UK economy. The Group's tax contribution is not limited to the UK corporation tax that Direct Line Group pays on its profits – we pay a number of different taxes and levies at various stages in our supply chain and in respect of our people and property footprint. Direct Line Group’s tax contribution is used to fund public spending on key services such as the NHS, education and the welfare system. This diagram shows some of the ways in which we contribute to HM Treasury and ultimately to public spending in the UK.

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 2022. This Policy applies to all UK entities within the Group, but the principles also apply to any DLG operations overseas.

DLG’s 2022 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

Statements under section 172 of the Companies Act 2006

Direct Line Insurance Group plc

Section 172(1) Statement

The Board of Direct Line Insurance Group plc (“Direct Line”) confirms that during the year under review, it has acted in the way it considers would be most likely to promote the long-term success of the Company for the benefit of its members as a whole, whilst having regard to the matters set out in Section 172(1)(a)-(f) of the Companies Act 2006 (“Section 172(1)”).

Purpose and Vision

The matters set out in Section 172(1) underpin Direct Line’s purpose and vision and form the foundation for the Board’s considerations and decision making. Our purpose – to help people carry on with their lives, giving them peace of mind now and in the future – is centred on customers and their long-term interests. Our vision – to create a world where insurance is personal, inclusive and a force for good – reflects our desire to do business in a way that benefits all stakeholders, the environment and wider society.

Stakeholders

Information on Direct Line’s key stakeholders is set out in the Sustainability section of the Strategic report on the following pages: Customers, 58 to 60; People, 61 to 65; Society, 66 to 69 and Environmental, 70 to 75. The diagram on page 55 sets out factors that we have assessed as being important to our stakeholders.

Engagement

The Board recognises that our stakeholders have diverse and sometimes competing interests that need to be finely balanced, and that these interests need to be heard and understood in order for them to be effectively reflected in decision making. Information about how the Board has engaged with stakeholders during the year and outcomes of that engagement can be found on pages 109 to 110 in the table titled “How the Board engages with stakeholders”.

Board decisions and oversight

Examples of how stakeholder engagement and Section 172(1) matters have influenced Board discussion and decision making during the year can be found in the table titled “Consideration of Section 172(1) factors by the Board” on page 108. The table covers a number of key topics including: the return of capital to shareholders; the future of Direct Line’s workplace and culture; and the implementation of rules resulting from the FCA’s Pricing Practices Review. The metrics and processes which the Board looks at to ensure that business practices and behaviours reflect the Company’s culture, purposes and values, including the impact of decisions on key stakeholders, are set out under “Culture and purpose” on page 105. Information about Board oversight of environmental matters can be found on page 76 in the TCFD Report.

Section 172(1) Factor Relevant Disclosures
(a) the likely consequences of any decision in the long term Innovating for the future (pages 1 to 13)
Vision, purpose, strategic objectives (page 23)
Consideration of Section 172(1) factors by the Board (page 108)
(b) the interests of the company’s employees Key Performance Indicators – Colleague engagement scores (page 31)
Outcome of employee engagement surveys (page 65)
Diversity and Inclusion (pages 61 to 64)
Employee Representative Body (page 111)
How the Board engages with stakeholders (pages 109 to 110) 
(c) the need to foster the company’s business relationships with suppliers, customers and others Key Performance Indicators – NPS and customer complaints metrics (page 31)
Supporting customers (pages 58 to 60)
Supply Chain Sustainability Programme (page 82)
How the Board engages with stakeholders (pages 109 to 110)
(d) the impact of the company’s operations on the community and the environment External ratings, memberships and benchmarks (page 57)
Social Mobility Action Plan (page 67)
Community Fund 2021 (page 68)
Science-Based Targets setting (page 86)
TCFD disclosures (pages 76 to 87)
How the Board engages with stakeholders (pages 109 to 110)
Sustainability Committee Report (pages 130 to 131)
(e) the desirability of the company maintaining a reputation for high standards of business conduct Our values (page 62)
Internal controls (pages 117 to 118)
The role of the Board – Culture and Purpose (page 105) 
(f) the need to act fairly between members of the company Capital returns (page 14)
How the Board engages with stakeholders (pages 109 to 110)
Annual General Meeting (page 97)
Shareholder voting rights (pages 161 to 162)

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 considering the calculation of technical provisions, 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 2021 on page 96. 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 2021.

The Group’s vision, purpose and values are set out in the strategic report of DLIG for the year ended 31 December 2021 on page 23 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 54 to 55 in DLIG’s 2021 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 Management Best Estimate (MBE) Reserving minimum standard to which the Directors adhered when making decisions concerning the Company’s best estimate reserving risks in line with risk appetite.

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 2021 on page 110. 

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 motor vehicle assistance, repair and recovery 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 vision, purpose and values are set out in the Strategic Report within the DLIG annual report 2021 on page 23 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 54 to 55 of the DLIG annual report 2021.  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 2021 on page 96.

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, DLIS. Disclosures relating to employees, suppliers, customers and others may be found in the annual report and financial statements of DLIS and DLIG for the year ended 31 December 2021.

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 annual report 2021 on page 110.

U K Insurance Limited

Section 172(1) Statement

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 7. 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 2021.

The Group’s vision, purpose and values are set out in the DLIG’s strategic report for the year ended 31 December 2021 on page 23 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 54 to 55 in DLIG’s 2021 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 2021 on pages 109 and 110. 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 2012, the Board oversaw work being undertaken to ensure the business was ready to comply with new rules brought in for the pricing of home and motor insurance as result of the FCA’s Pricing Practices Review.

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 2021 on page 110. 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.

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 within the DLIG annual report 2021 on page 23 and pages 54 to 55. 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 for the year ended 31 December 2021 and the DLIG annual report 2021.

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 DLIG annual report 2021 on pages 109 to 110. The Company provides insurance intermediary services. The 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 its 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 annual report 2021 on page 110.

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 2021 on page 23 and pages 54 to 55. 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 pages 6 and 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 2021.

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, for the year ended 31 December 2021 on pages 109 to 110. The Company operates the Group’s motor vehicle repair centres. The 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 its 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 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 can be found in the DLIG’s annual report for the year ended 31 December 2021 on page 110. 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 Directors of the Company confirm that during the year under review, they have acted in the way they consider would be most likely to promote the long-term success of the Company for the benefit of its members as a whole, whilst having regard to the matters set out in Section 172(1)(a)-(f) of the Companies Act 2006 (“Section 172(1)”).

The matters set out in Section 172(1) underpin the Group's purpose and vision and form the foundation for considerations and decision making. The Group's purpose - to help people carry on with their lives, giving them peace of mind now and in the future - is centred on customers and their long-term interests. The Group's vision - to create a world where insurance is personal, inclusive and a force for good - reflects the desire to do business in a way that benefits all stakeholders, the environment and wider society. Further key disclosures in respect of each of the Section 172(1) matters can be found in the DLIG annual report for the year ended 31 December 2021 on page 20.

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 2021 on page 23, and pages 130 to 131. 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 2021 on pages 106 to 107.

Examples of how the Group have 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 2021 on pages 86 to 87. The Company enters into the substantial majority of all contracts with suppliers to the Group and, during the year, the Directors approved the Company's transparency statement on modern slavery which demonstrates how the Company takes its supply chain responsibilities seriously.

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 Group Accounting minimum standard, to which the Directors adhered before approving the Company's financial statements.

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 2021 on page 110. The Company's statement on modern slavery can be found on the Group’s corporate website.