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Corporate Responsibility Architecture
- Corporate responsibility methodology and leadership
- Our corporate responsibility contexts
- The management structures which support our organisation
- The business context of corporate responsibility
- Corporate Responsibility Architecture
- Group/corporate functions
- Corporate responsibility in day-to-day management
- Implementation of the Corporate Responsibility Programme
- Roles in relation to corporate responsibility
Corporate responsibility methodology
and leadership
We firmly believe that corporate responsibility does not lend itself
to quick fixes or easy solutions. It cannot be achieved simply by system
or process changes imposed from above, but demands real engagement from
our people at every level of the organisation.
We believe our fundamental strength as a company lies in our combination of talented people and innovative solutions. Our overriding priority is, therefore, to embed our Corporate Responsibility Programme – thus ensuring that a unified approach is maintained, and the value it adds to our business is consistent and sustained.
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The embedding process involves:
- The education of our employees through workshops and related programmes
- Clearly defined process and management structures, through which our Corporate Responsibility Programme is rolled out and implemented
These are now very much in place and the embedding process under way to ensure the stability and robustness of our programme in the context of the dynamism of our business and marketplace.
In this section we explain this process, these structures, and the contexts we feel most relevant to an understanding of our corporate responsibility architecture.
Our corporate responsibility contexts
The Business Review enshrined in the Companies Act 1985 and the enhanced
Business Review, due to be introduced under the Companies Act 2006,
place a responsibility on directors to report on material non-financial
risks which, if crystallised, might adversely affect the financial performance
of the Company. In this report, therefore, we have shifted focus slightly
from prior years, focusing more closely on key risk areas for our business,
notably our people and our marketplace.
A number of regulatory principles are also particularly relevant and integral to our Corporate Responsibility Programme; those most relevant to our activities including:
- The Financial Services Authority principles for businesses, including
the key expectations that a regulated firm should:
- Conduct its business with integrity, due skill, care and diligence
- Take reasonable care to organise and control its affairs responsibly and effectively with adequate risk management systems
- Maintain adequate financial resources
- Observe proper standards of market conduct
- Pay due regard to the interests of its customers and treat them fairly
- Pay due regard to the information needs of its customers and communicate information to them in a way which is clear, fair and not misleading
- Manage conflicts of interest fairly, both between itself and its customers and between one customer and another
- Take reasonable care to ensure the suitability of its advice and discretionary decisions for any customer who is entitled to rely upon its judgement
- Arrange adequate protection for customers’ assets when it is responsible for them
- Deal with its regulators in an open and cooperative way and inform the regulator promptly of anything relating to the firm of which the regulator would reasonably expect prompt notice
- The Turnbull Guidance – a document from the Combined Code of the Committee on Corporate Governance which provides guidance on a number of risk related areas including risk assessment, control environment and control activities. In particular, senior management is obliged to demonstrate, through its actions as well as its policies, necessary commitment, competence and integrity, while fostering a climate of trust and transparency. Turnbull also makes direct reference to risks related to Health and Safety, the environment, and reputation – each of which is an element of our Corporate Responsibility Programme
- The Association of British Insurers (ABI) Disclosure Guidelines on Socially Responsible Investments – guidelines widely recognised as constituting a credible benchmark for corporate responsibility disclosures in Annual Reports and for the creation of effective systems for managing significant non-financial risks
- General – elements of corporate responsibility can be found in most financial services’ corporate governance and related regulation and legislation. This framework offers a useful basis for consistent and cogent reporting of corporate responsibility and, in particular, Performance Indicators appropriate to the nature, scope and scale of our activities and their overall management
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