Group Code of Business Ethics

Message from our Chairman

In a complex world it is impractical to set specific rules and regulations to cover every situation. However, we in the esure group of companies do have a Code of Business Ethics which offers clear standards and guidance for the business dealings of the company.

Our objective is not only to protect the reputation of our group and to safeguard the investment of our shareholders, but also to help set our interactions with colleagues, customers, business associates and the communities in which we work on strong ethical foundations.

Whilst the Code cannot deal with every circumstance, it creates a framework to help us decide how to behave.

I ask for the commitment of every employee and the support of business associates to uphold the Code and to contribute towards the success of a great company.

Peter Wood

Introduction

This Code outlines standards that we expect each company or individual that we do business with to adhere to. All suppliers, advisers, business partners, contractors, consultants and regulators (together ‘Business Associates’) should act within the spirit of the Code, not withstanding any other contractual arrangements which may have been agreed. This Code is not designed to take precedence over any contractual agreement but to help enhance our relationship with Business Associates and guide Business Associates to make decisions as to what is appropriate conduct.

Supporting this Code of Business Ethics are separate policies that our employees must additionally personally comply with, which includes a Code of Conduct. All policies are available on the esure intranet site and set out in more detail how we should conduct our business. They underline the important message that behaving responsibly, and ethically, is an integral part of our business. As such it is the personal responsibility of each employee, as well as an important duty of line management to monitor compliance.

This Code has been approved by and has the full support of our Board and executive management.
 

Our Code

 

We comply with the law

 

Our employees and anyone with whom we may have business dealings, are required, as a minimum standard, to comply with all laws and regulations. For employees help and advice on legal and regulatory requirements can be requested from the Legal and Risk & Compliance teams based in Reigate. Business Associates should obtain independent legal advice where necessary.
 

We compete fairly

We believe in competing fairly. We do not engage in, nor are we party to, agreements, business practices or conduct that, as a matter of law, are anti-competitive.

We ensure that all Business Associates are treated fairly and we select Business Associates based on fair assessments of each associate’s offering. The procurement team will assist employees in the selection of Business Associates, which must be conducted in accordance with the Procurement Policy.
 

We act with honesty and integrity in all our business dealings

We expect our employees to act with honesty and integrity at all times to safeguard the trust in which esure is held by its customers, shareholders, suppliers and other individuals and organisations with which our business interacts.

No employee shall engage in personal activities or pursue financial or business interests which might give rise to, or give the appearance of, conflicts of interest with esure, or which might compromise their ability to meet the responsibilities of their job.

We adopt a strong stance and take steps to deter, prevent, detect and investigate all forms of fraud and financial crime. For employees, our requirements regarding financial crime can be found in our Financial Crime Policy.

In particular, the esure Group has a zero tolerance for any practice that is, or might reasonably be construed as, corrupt or involves bribery. We do not offer, promise, give, demand or accept bribes or other unethical advantage in order to obtain, retain or give business or other advantage. Any third party attempting to offer a bribe will be reported to senior management and the relationship between esure and such third party may be terminated. We do not accept excessive hospitality and will not accept any gifts or hospitality during a tender process or when in any negotiations with a business associate.

Employees and Business Associates who have access to privileged or confidential information (including proprietary and confidential information, whether belonging to esure or others) must not disclose such information, use it to achieve personal gain for themselves or for any reason other than that which is necessary to perform their function.

Our employees and any Business Associates with access to esure assets must ensure proper and responsible use of all our assets, including physical property, intangible assets, IT equipment and communication resources. Employees must comply with the Acceptable Use of Technology Policy, Mobile Communication Device Policy and Laptop Policy.
 

We treat Business Associates and customers properly and fairly

We treat our Business Associates in a fair and reasonable manner, we do not use aggressive commercial practices.

We expect our employees and Business Associates to act lawfully and ethically, and in accordance with the values and standards set out in this Code.

We believe in working in partnership with our Business Associates, so as to meet the expectations of esure customers, and to ensure quality, value and timeliness throughout the supply chain.

We seek to provide our customers with products and services, which meet or exceed their expectations, through the application of quality management systems and continuous improvement programmes. We are committed to treating our customers fairly throughout their relationship with us.

We respect customers, employees and Business Associates and take steps to ensure proper use of their personal information. We comply, and expect our Business Associates to comply, with good practice guidance on data protection. Employees must ensure they adhere to our Data Protection Policy.
 

We treat our co-workers respectfully

We believe that all employees should be treated with respect and dignity. We do not tolerate harassment or bullying, whether by co-workers or third parties.

We recruit, select, and promote employees on the basis of their qualifications, skills, aptitude and attitude.

We vet employees to a suitable level in accordance with their role, all vetting is conducted fairly, with consent and in accordance with our Pre Employment Screening Policy.

In employment related decisions, esure complies with anti-discrimination requirements concerning matters of race, colour, national origin, gender, marital status, sexual orientation, religious belief, age or physical or mental disability.

Further information, for employees, on issues of equality can be found in our Equality and Diversity Policy, we expect all Business Associates to comply with this policy.
 

We contribute to healthy, safe and secure workplaces

We are committed to conducting all our activities in a manner which achieves the highest practicable standards of health and safety.

We seek to protect our employees, visitors, physical assets, information and reputation from potential security threats and we require those who operate at our sites to comply with our Health and Safety Policy.
 

We respect the environment

We are committed to ensuring that, as far as reasonably practicable, any detrimental effects of our activities, products and services upon the environment are minimised.

We expect our Business Associates to continuously strive to reduce the environmental impact of their operations.
 

We contribute to our communities

In addition to the provision of employment opportunities, we contribute to the communities in which we operate by participation in, and support for, community and charitable initiatives.
 

We have high standards of record-keeping and reporting

We record all business transactions accurately, prudently and transparently.

Comprehensive assessment and management of risk, together with strong systems of internal control, are essential aspects of our structure and serve to ensure that it is managed effectively and that reported results are accurate.

An independent Internal Audit function monitors and reports to our Audit Committee on the effectiveness of internal controls and on the ongoing risk management process for identifying, evaluating and managing significant business risk. We expect Business Associates to regularly conduct internal audits to ensure compliance with law, regulation and contractual obligations.

For employees, our Risk & Compliance team based in Reigate can provide assistance on risk and compliance based issues.


The Code applies to all of us

Our Code applies throughout esure and to all our Business Associates, agents and group companies. Disregard or breach of the Code by an employee will result in disciplinary action. Any disciplinary action will be taken in accordance with our Disciplinary Policies and Procedures.

We reserve the right to hold Business Associates responsible should practices occur in their businesses which are not in line with the principles as embodied in this Code.

Our Code is not intended to replace existing esure policies or contractual obligations.

We expect and encourage employees and Business Associates to bring promptly to management’s attention any suspected or actual breaches of our Code. Any person making such information known through the appropriate channels will not face any adverse or unfavourable treatment for such disclosure.
 

Obtaining Advice and Reporting Issues

Any queries, requests for guidance or reports of alleged breaches in relation to the Code can be raised by employees through Line Managers or Human Resources Representatives, or by Business Associates through your Relationship Manager. The esure Whistleblowing Policy sets a process for employees to follow to raise any concerns they have and the Grievance Procedure tells employees how to raise any reasonable grievances they may have.

If Business Associates become aware of any issue that they believe may, or has already caused a breach of this Code, this should be communicated to esure’s General Counsel. Alternatively, our Business Associates are also able to make use of our independently managed whistleblowing helpline for reporting concerns in confidence, 0800 917 3989

All reports are treated confidentially and investigated properly and promptly. We expect all Business Associates to establish and enforce procedures that enable their employees to report any cases of non-compliance with this Code that may come to their attention. In addition, we require that all such reports are investigated appropriately and with due diligence.
 

Governance

The Board of Directors has overall responsibility for the Code. The Audit Committee of the Board of Directors has responsibility for monitoring the implementation of the Code and compliance with the Code’s provisions.