STRATEGIC REPORT
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communications campaigns to remind staff of the importance of data privacy. We also operate and enforce a clear desk policy. • We are cognisant that some of our customers could be vulnerable and we want to ensure that all of our customers receive the right support, the right outcome and an appropriate level of care. Our policy, captures this approach and is applied throughout our customer facing teams. The GRCC received an in-depth report on our approach to vulnerable customers during the year. 5. Anti-corruption and anti-bribery • We have a Group financial crime policy which is a zero tolerance policy. This policy helps us to prevent and detect financial crime. Our whistleblowing policy, and our whistleblowing hotline, encourages colleagues to report any wrongdoing. All such reports are fully investigated and appropriate remedial actions taken. • We have a comprehensive mandatory compliance training programme which covers the above policies as well as other important areas of compliance which all colleagues must complete on an annual basis. Completion is monitored by the Compliance team and reported to the Board, with repeated failure to complete the training being a disciplinary matter. NON-FINANCIAL RISKS AND RISK MANAGEMENT The risk management report on page 34 sets out our approach to risk management. Our approach helps us make informed business decisions which generate value while delivering appropriate outcomes for our stakeholders. The report sets out our principal risks and uncertainties including non-financial risks and how we mitigate those risks. The GRCC has reviewed environmental risks from climate change. The GRCC and Board also consider reputational risks, for example in relation to ensuring that our colleagues are motivated and engaged and do the right thing. Our Risk team ensures that due diligence is carried out on our Group policies. Each employee and manager are responsible for risk management in their business area. Each policy has a policy owner and an executive level sponsor. The policies are reviewed by the policy owner annually and an attestation is provided. Changes to policies are approved by the GRCC or Board depending on the materiality of the changes. Breaches of policies are monitored and reported on a monthly basis and recorded in our risk management system. The Compliance and Operational Risk Committee review breaches of policies and advise the GCRO. Serious breaches are reported to the GRCC or Board. This on-going management of risks enables the business to take necessary action to remove or mitigate the risk where breaches have occurred. This could be through training or improving a process or policy. In serious or repeated cases, disciplinary action may be taken. The aim is to prevent non-financial risks from materialising and having a detrimental impact on our business (including our reputation), our colleagues, our customers, our suppliers or other stakeholders. APPROVAL The Strategic Report was approved by the Board of Directors on 11 March 2020 and signed on its behalf by:
THE OUTCOME OF OUR POLICIES ON OUR MATERIAL AREAS OF IMPACT 1. Environment • The direct impact of our operations on the environment is relatively low due to the office based nature of our work. The Group is UK based with a small operation in South Africa. We are committed to reducing our environmental impact, including: the amount of travel undertaken by all of our colleagues; the “going paperless” transformation which was reported on in our 2018 report; reducing our office footprint; and introducing environmental standards into our Group procurement and outsourcing policy. • We are committed to promoting good corporate environmental practice and have ISO 14001:2015 certification. • Information on our policies and the ways in which we are reducing our impact on the environment, including the greenhouse gas emissions for which we are responsible, is set out in our Environment report on page 46. • Information about our Investments team and their sustainable investment strategy and framework is included on page 18. 2. Colleagues • Colleague engagement and making Just a great place to work for all of our people is very important to us. We recognise that passionate and engaged colleagues are crucial to delivering our strategy. • The Group is taking positive steps towards building a diverse workforce and inclusive environment. The CEO is our diversity and inclusion champion. We have rolled out unconscious bias training to all employees. We support LGBT rights, gender equality and mental health awareness with topics on our employee intranet and events. • As a result of our policies and initiatives in this area we recently analysed our recruitment, promotion and performance management processes and reported no evidence of gender bias. In recruitment, the data shows that our challenge is to attract higher numbers of female applicants to apply for senior and technical roles with the Group (e.g. actuarial, finance, IT). As a result, we are actively seeking partnerships with organisations and networks who can help us to attract and engage more diverse candidates. • More information regarding our policies in relation to our employees and the impact of those policies is set out in our People and Culture report from page 40. • We also have policies to help ensure that our colleagues act ethically and do the right thing in the performance of their work, to reduce the risk of detrimental impact on other stakeholders through the actions of our colleagues. Our activities to help our colleagues feel proud to work at Just and our compliance policies work together to help mitigate against colleagues acting unethically. 3. Social • We give back to the communities in which we operate and are committed to good corporate citizenship, supporting charity and community initiatives which are relevant to our business, employees, customers and other stakeholders. Our colleagues also benefit from participating in our social activities. The risk to the business from our social impacts is considered to be low. • For further information about our social and volunteering activities and the impacts see our People and Culture report on page 40. Our Just Get Active insight on page 44 provides information about our new community programme. 4. Human rights • While the Board considers that the risk of human rights violations is low, we have implemented effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains or in any part of our business anywhere we operate. Our Modern Slavery Statement available on our Group website provides further information. We conduct due diligence on potential suppliers, impose obligations on those suppliers and monitor their compliance with those obligations. • We have a responsibility to protect our customers’ privacy when processing and using their data. We sometimes handle sensitive data and it is important that this is used appropriately. We have training in place for all of our colleagues, including those who are not customer facing, on data protection as well as internal
Chris Gibson-Smith Chair
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