STRATEGIC REPORT
51
non-financial information statement This statement sets out how we comply with the non-financial reporting requirements set out in sections 414CA to 414CB of the Companies Act 2006 and where you can find further information on those matters in the Annual Report.
OUR BUSINESS MODEL The business model remains largely unchanged with the key focus being to make the Group more capital efficient and to ensure we deliver long-term value for shareholders and great value for customers. Our business model on pages 14 to 15 sets out our strengths and how they are the foundation of our sustainable success. Our business model impacts on our colleagues and our customers as well as having wider impacts on the environment and society.
OUR NON-FINANCIAL POLICIES We have non-financial policies which govern how we do business and how we interact with each other and with the community to help ensure that we have a positive impact and fulfil our purpose. Our policies reflect our commitment to acting ethically and with integrity in all of our business relationships. We are also mindful and focused on our financial and capital position. This in turn also enables us to protect our policyholders, customers and colleagues by growing the business sustainably.
NON-FINANCIAL KEY PERFORMANCE INDICATORS The Board does not currently monitor any non-financial performance indicators, but it receives reports and management information regarding key non-financial matters such as colleagues’ wellbeing and job satisfaction. The discretionary bonus plan for employees uses non-financial metrics to decide part of the bonus pool which the Board and Remuneration Committee review.
MATERIAL AREA OF IMPACT
POLICIES
POLICY DESCRIPTIONS
• Carbon footprint • Use of resources • Investments (responsible investing) • Impact of the operations of our suppliers
• Sustainable
• Sustainable Investment Framework: see the report on sustainable investment strategy on page 18. • Group procurement and outsourcing policy – ensures that high standards of honesty, impartiality and integrity are maintained in our business relationships. It ensures that contractual arrangements with third parties are undertaken with due regard for the associated risks. • Group charity and community policy: see “social” below. • Board diversity policy: see the Nomination Committee Report on page 68. • Flexible working policy: provides support and advice to employees regarding our approach to flexible working requests. • Group training and competence policy: sets out the standards and requirements to ensure the training and competency framework is effective in mitigating the risk of colleagues lacking the expertise and knowledge required for their role and potentially resulting in poor customer outcomes. • Group fitness and propriety policy: sets out a framework for appropriate processes and procedures to ensure compliance with the Senior Managers and Certification Regime. • Group operational risk policy: sets out the Group’s framework for managing operational risk. • Group conduct risk policy: sets out the framework of principles, systems and controls around the management of conduct risk by the Group and encompasses regulatory requirements such as integrity, market conduct, customer interests, skill, care and diligence, and conflicts of interest. • Group charity and community policy: defines the minimum standards for managing opportunities and risks relating to the conduct of charitable and community activities as part of the Group’s overall approach to corporate social responsibility to support the achievement of our purpose. • Group procurement and outsourcing policy: see “environmental” above. • Modern Slavery Statement: sets out our policies and processes to combat modern slavery in all its forms. • Group data protection policy: sets out a framework of high level controls and processes to enable the Group to safeguard personal data and manage the risks of processing individuals’ personal data to comply with regulatory requirements. • Group vulnerable customer policy: defines our approach to ensure vulnerable customers receive consistently fair treatment across our Group and experience outcomes as good as those of other customers. • Financial crime policy: sets standards for the Group and colleagues to meet to manage the risks from financial crime. All colleagues are trained to understand what constitutes financial crime, the regulatory requirements and their obligations. • Group compliance policy: sets out the Group’s approach to ensuring that it operates in compliance with the relevant laws and regulations. • Group whistleblowing policy: sets out the framework to encourage colleagues to feel safe in raising any suspicions of wrongdoing to the attention of the Board and senior management.
1. ENVIRONMENTAL
Investment Framework (a framework used by our Investment team)
• Group procurement
and outsourcing policy
• Wellbeing of colleagues, including mental health,
• Group charity and community policy • Board diversity policy • Flexible working policy • Group training and competence policy • Group fitness and propriety policy • Group operational risk policy • Group conduct risk policy
2. COLLEAGUES
fulfilment, work-life balance, career and
development opportunities • Ensuring our colleagues’ actions do not have a detrimental impact on customers, suppliers or other stakeholders
• Volunteering • Charity partners • Local community engagement
• Group charity and community policy
3. SOCIAL
• Data protection • Modern slavery • Impacts of our products and services on vulnerable customers
• Group procurement
4. HUMAN RIGHTS
and outsourcing policy
• Modern Slavery Statement • Group data protection policy • Group vulnerable customer policy
• Preventing corruption or bribery from happening by or on behalf of Just
• Financial crime policy • Group compliance policy • Group whistleblowing policy
5. ANTI-CORRUPTION AND ANTI-BRIBERY
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