60 | Just Group PLC | Annual Report and Accounts 2023
SECTION 172 STATEMENT – EXAMPLES OF DECISIONS TAKEN DURING THE YEAR continued
AREA OF DECISION
MATTER CONSIDERED
S172 FACTOR/ KEY STAKEHOLDERS High standards of business conduct, suppliers and partners
WHAT WE DID
The Board considered processes for procurement and outsourcing arrangements to prevent modern slavery and human trafficking in our supply chain. The Board considered and approved the first reported results under IFRS 17, the new insurance accounting standard and the
Just takes a zero tolerance approach to modern slavery and implements various measures to prevent modern slavery and human trafficking in our supply chain as covered in more detail in the Modern Slavery Statement approved annually by the Board. The Modern Slavery Statement can be found on the Company’s website www.justgroupplc.co.uk .
PROCUREMENT AND OUTSOURCING
High standards of business conduct, investors
The implementation of IFRS 17, the new insurance accounting standard, has been one of the key focus areas for the Directors during the year to ensure compliance with the new requirements. A key consideration was to ensure stakeholders including investors, regulators and the external auditor understood the changes to financial reporting and the associated impact to the Group. The Group Audit Committee has been responsible for oversight of the implementation and providing comfort to the Board with the progress made. In 2023, the Board considered and approved the first reported results under IFRS 17, which included a modification to a number of the Group’s key performance indicators. Further information on the key performance indicators can be found in the Group Audit Committee report on page 94. The FCA’s rules for a new Consumer Duty sets higher and clearer standards of consumer protection across the financial services and requires firms to put customers’ needs first. Following an initial scope of the business against the requirements of the Duty, the Board approved Implementation Plans for the Retail, HUB and DB businesses in October 2022 which, together with a milestone plan considered by the Board in March 2023, set out a number of programme milestones to complete by 31 July 2023, the Phase 1 deadline set by the FCA for all businesses to be in a place of substantive compliance. The Board received regular updates from the Project team on the progress made against the implementation plan and concluded that they were satisfied the Group was in substantive compliance with the regulation. A further road map was developed for the delivery of Phase 2, which requires all firms to be in full compliance by 31 July 2024. There is continued dialogue with the lead Non-Executive Director responsible for Consumer Duty, Michelle Cracknell, and an updated Conduct and Customer Risk dashboard is presented to the Group Risk and Compliance Committee on a quarterly basis to ensure that the information flow through to the Board remains appropriate. During the year, the Board considered the impact of the interest rate movements to the Group’s Solvency II position. Historically, hedges to protect interest rate exposure in our Solvency II position have created volatility in IFRS profit before tax as interest rates moved. However, a revised hedging strategy during 2022 and 2023, including approval by the Board of a purchase of £2.5bn long dated gilts held at amortised cost under IFRS, has removed the IFRS exposure whilst significantly containing our Solvency II sensitivity to future interest rate movements.
FINANCIAL REPORTING
impact on key stakeholders.
High standards of business conduct, customers, suppliers and partners
CONSUMER DUTY The Board considered the Group’s position in relation to the FCA’s Consumer Duty
requirements and was satisfied that the Group was in a place of substantive compliance by the Phase 1 deadline set by the FCA.
Long term
The Board considered the impact of interest rate movements to the Group’s Solvency II position, and approved the purchase of £2.5bn long-dated gilts.
PURCHASE OF LONG-DATED GILTS
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