This includes being clear that bribery and corruption are not tolerated anywhere in our business, through robust anti-corruption, conflicts of interest and gifts and hospitality policies which apply Group-wide. We also take steps to address ESG risks to our business operations, through mechanisms such as our High Risk Country framework, which guides the business that we write, and our Human Rights policy, which ensures our operations uphold the principles of human rights.
Environmental, social and governance risks
RSA operates in a global environment and we are frequently asked to provide insurance across borders. As part of maintaining an appropriate level of scrutiny for the work we do, RSA operates a high risk country framework incorporating guidance and requirements to refer the writing of certain business or the payment of certain claims to a more senior level where a matter is linked to a country that RSA deems higher risk in certain regards.
As a signatory member of the United Nations Principles for Sustainable Insurance (PSI), we are also involved in a working group established by the PSI and co-led by Allianz to develop a global Environmental, Social and Governance (ESG) standard for insurance. The working group will develop guiding principles and best practice for underwriters to assess risks around human rights, environmental and social issues following extensive consultation with the insurance industry.
Our human rights policy (PDF) exists in support of internationally-recognised declarations, including the UN Global Compact, of which we are a signatory. We report our progress against the Compact’s ten principles annually.
Anti-bribery and corruption
Bribery and corruption are not tolerated anywhere in our business and this approach, led by our Board and Group Executive, applies globally.
Our anti-corruption, conflicts of interest, gifts and hospitality policies apply Group-wide and are supported by extensive resources and guidance, including our anti-bribery toolkit, which is available to all our businesses. Our resources include due diligence enquiries to be asked of appropriate parties. Our on-line training materials equip our staff to identify and escalate issues and behaviours which may constitute corruption or otherwise be illegal. Our mandatory Group-wide training, which covers recognising and combating corrupt behaviour and what constitutes appropriate corporate hospitality, requires employees to pass a test at the end before they can be deemed to have completed it. It is supplemented by targeted training for staff in higher risk roles. Additionally, all our people are required to complete whistleblowing training.
All operating countries must complete regular anti-corruption risk assessments covering all aspects of their businesses, including procedures and HR matters and the high expectations we have of our partners. Our operating countries are all given guidance to further enhance their anti-corruption controls.
Employees are regularly reminded of our anti-corruption expectations, whether face-to-face or through intranet messages, and information on policy compliance is escalated to management. Our board receives updates on our anti-corruption controls at least annually.
We strongly encourage our people to speak out if they have concerns. Our annually-reviewed Group-wide whistleblowing policy, available on our intranet, sets out the procedure for colleagues to confidentially raise genuine concerns about suspected wrongdoing and malpractice.
Where a breach is material or not in compliance with regulations, we will report externally.
The Group contributes to public policy debates on issues relevant to the business, either individually or through industry bodies such as the Investment Association, the Association of British Insurers (ABI) and the Confederation of British Industry (CBI).
The Group engages with policymakers to improve understanding of the broad role the insurance industry plays in society and the economy, as well as offering views and insights on specific issues such as data protection, fraud, compensation, and financial regulation. Employees apply the principles of openness, transparency, honesty and integrity to all of their activities with policymakers.
The Group adheres to principles of best practice, declaring the interests which it represents and ensuring that, to the best of its knowledge, information provided is unbiased, complete, up to date and not misleading.