We take our commitments to preventing bribery and corruption very seriously. These are not tolerated anywhere in our business. Our anti-corruption and conflicts of interest policies apply Group wide, both supported by extensive resources and guidance. We provide mandatory training on recognising and combatting corrupt behaviour, as well as on what constitutes appropriate corporate hospitality. All operating countries are required to complete regular anti-corruption risk assessments.
We strongly encourage our people to have the courage and integrity to speak out when 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.
Across the Group, a Cultural Risk Index and Assessment helps our leaders and HR teams manage cultural issues that could lead to a possible failure of ethics, controls or governance.
Our Human Rights policy exists in support of a number 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.
We hold approximately £13 billion of investments, the majority of which is in bonds. Our investment fund managers include Deutsche Asset and Wealth Management, Skandinaviska Enskilda Banken, AXA Investment Managers, TD Asset Management and PH&N Investment Services.
Our Group Investment Committee manages investment policy and strategy and oversees the Group’s investment portfolios within strictly defined frameworks. Within our publicly available Annual Reports and Accounts 2015, we communicated our strategy to maintain a core high quality, low risk portfolio.
To date, we have not formally incorporated climate change into our investment policies. We will continue to assess the risks and opportunities of responsible investment, as well as how to deliver maximum shareholder value whilst reducing carbon emissions and improving human capital.
We engage with political opinion formers and policy makers on issues relevant to our business. We do so openly and transparently, ensuring the information we provide is unbiased and accurate. We utilise our memberships of industry sector bodies to help voice our concerns.
Several global agreements on sustainability were reviewed and amended in 2015, including 17 UN Sustainable Development Goals (SDGs) adopted in September and the historic Paris Agreement of the UN Framework Conventions on Climate Change signed by 190 world leaders in December. Through our memberships of the United Nations Environment Programme Finance Initiative Principles for Sustainable Insurance (UNEP FI PSI), Association of British Insurers (ABI), Confederation of British Industry’s (CBI) Energy and Climate Change Committee and ClimateWise, we have supported statements, attended meetings with policy makers, published opinion statements and contributed to the outcomes of these processes.
In the UK, we are part of the Government-backed Flood Re initiative, helping those in high risk flood areas maintain access to affordable insurance.
We also held two roundtable sessions with MPs, transport officials and industry experts to discuss the future of motoring. In this way, we endeavour to work with the government to ensure new technologies, likeTelematics is the use of technology to record data on how an object is being used in real-time. Examples include 'black boxes' in cars and mobile phone apps that can record how the car is being driven (its speed, location and fuel consumption); home monitoring devices; or collars that monitor a pet's activity.
and driverless cars, bring real benefits to people, such as reduced premiums.
In Sweden, we have linked up with other insurers as part of the Swedish Insurance Society, to lobby decision makers on climate-related issues and actions.
We considered environmental, social and governance (ESG) risks when engaging stakeholders to create Making Things Better Together.
Our aim is to both provide products that protect our customers from the impact of risk and to make sure the risks we accept are managed collaboratively. This has the twin effect of maximising returns for investors and benefitting the environment and societies we operate in.
The Board’s Risk Committee (BRC) ensures we operate a robust risk management system and the Group Chief Risk Officer shares any material ESG risks within a quarterly update to the BRC. We consider it imperative to continually evaluate any emerging risks.
We monitor global developments that could present social or political risks, such as human rights issues. As signatories of the UN Global Compact, we are committed to protecting human rights and eliminating discrimination. We report our progress against the Global Compact’s ten principles annually.
We comply with all relevant law and regulation concerning financial and economic sanctions. A dedicated committee oversees our procedures and our approach to dealing with countries we perceive as higher risk. This approach is reviewed at least twice a year.