Group policies and disclosures

Employment policies

For us, diversity is ensuring that we have employees with different backgrounds, perspectives and experiences. This brings diversity of thought, which is vital at every level of the business including at Board level.

Hiscox Ltd Board diversity, equity and inclusion policy (PDF)

Purpose

The Board diversity policy (the policy) sets out the approach to diversity of the Board of Directors of Hiscox Ltd (the Board). The purpose of this policy is to commit to equal opportunities in Board activities and throughout the Company, irrespective of their gender, gender reassignment, sexual orientation, disability, age, religion, beliefs, marital status, social class and race including colour, nationality, ethnic or national origin.

Scope of application

The policy applies to the Board of Hiscox Ltd. Linked to the overall responsibilities of the Board, the policy also extends to oversight of workforce diversity, equity and inclusion throughout the Hiscox Group (the Group) as defined and managed via the Group diversity, equity and inclusion policy1.

Diversity, equity and inclusion as part of the Company strategy

Hiscox operates in a global market and the success of our business is dependent on our people. We want to build teams that are as diverse as the customers and communities we serve and create an environment where all our people can thrive. We want to ensure that being successful at Hiscox is purely down to talent, personal values and effort, and consistent with our values. Our belief is that diverse perspectives and different ways of thinking help us anticipate and meet market needs in new ways. This diversity of thought allows us to look at problems differently, and helps make us more innovative and a stronger partner for our customers.

At Hiscox, diversity is ensuring that we have directors and a workforce2 with different backgrounds, perspectives and experiences. Inclusion is fostering a culture that brings the diversity of thought that is vital at every level of the business including at the Board level, where everyone has a ‘voice’ at the table and everyone’s opinion and views are heard and respected. Diversity, equity and inclusion go hand in hand – an inclusive workplace culture allows diverse employees to have an impact on our business.

Goal

We aspire to have a Board that reflects society as a whole. The Board does not feel that it would be appropriate to set quotas as a diverse Board is possible by being mindful of these objectives.

Our commitment (objectives)

The Board will:

1. Ensure a diverse3 and effective Board.

Delivered by
a. At least annually review the structure, size and composition of the Board including the balance of skills, knowledge and experience to assist in the development of a diverse3 pipeline.
b. Annually review Board diversity as part of the Board evaluation process.
c. Ensure the values of the Group promote an open and inclusive environment.

These reviews will normally be facilitated by the Hiscox Ltd Nominations and Governance Committee with recommendations for change made to the Board.

2. Ensure that all appointments and succession plans are considered on merit within the context of strategy requirements and diversity considerations.

Delivered by
a. At least annually review the succession plans for the Board and Senior Management and ensure the talent review process is in place for the wider workforce.
b. Gender and ethnic diversity will be taken into consideration when evaluating the skills, knowledge and experience desirable to fill each role and when considering the methods to attract diverse candidates.
c. A search firm will normally be engaged to assist in the review of the market and they should be committed to addressing gender and/or ethnic diversity.
d. All appointments must be made on merit as aligned to the needs of the Board, the Group, and their strategy and values.
This will normally be facilitated by the Hiscox Ltd Nominations and Governance Committee with recommendations for change made to the Board.

3. Ensure that the overall workforce is diverse and inclusive.

Delivered by
a. Review of the execution of the Group Diversity, Equity and Inclusion Policy4.
This will normally be facilitated by the Hiscox Ltd Nominations and Governance Committee with recommendations for change made to the Board.
b. Ongoing Board and Committee review of matters relating to employee retention, engagement and culture.

Review of the policy

The Nominations and Governance Committee shall review the policy annually. This review will include an assessment of the effectiveness of the policy and recommend any revisions to the Board for approval.

August 2022

1. https://www.hiscoxgroup.com/sites/group/files/documents/2022-08/Group_diversity_equity%20and_inclusion_policy_2022.pdf

2. All Hiscox employees, regardless of position or status, and to contractors and sub-contractors.

3. Diversity of gender, social and ethnic backgrounds, cognitive and personal strengths.

4. https://www.hiscoxgroup.com/sites/group/files/documents/2022-08/Group_diversity_equity%20and_inclusion_policy_2022.pdf

We want to build teams that are as diverse as the customers and communities we serve and create an environment where all our people can thrive.

Group diversity, equity and inclusion policy (PDF)

Overview

  • Purpose of the Policy

The purpose of this policy is to set out Hiscox’s approach to diversity, equity and inclusion (DEI) across the Hiscox Group (“Hiscox”). Consideration has been given in the drafting of this policy where appropriate to law and regulation in all relevant jurisdictions where Hiscox conducts business. It does not form part of any terms and conditions of employment and Hiscox may amend at its sole discretion at any time.

Hiscox will at all times adhere to local law and regulation and in case of conflict, local law shall prevail.

  • Target audience

This policy applies to all Hiscox employees, regardless of position or status. The policy is approved by the Hiscox Ltd Board and adopted by the subsidiary Boards. This policy is for internal use only and should not be shared outside of Hiscox unless express permission has been given by the Policy Owner.

  • Application/Scope

The policy is applicable across all Hiscox business units and companies.

  • Review Process

The annual review of the policy is completed by the Policy Owner. Any material changes are presented to the Policy Approver for approval, with minor changes being approved by the Policy Owner.

Diversity, Equity and Inclusion

  • Diversity, Equity and Inclusion Principles

Hiscox operates in a global market and the success of our business is dependent on our people. Our human capital is our most valuable asset. The collective sum of the individual differences, life experiences, knowledge, innovation, self-expression, unique capabilities and talent that our employees invest in their work represents a significant part of our culture, reputation and achievement.

We want to ensure that being successful at Hiscox is a result of talent, personal values and effort, consistent with our values. Our belief is that diverse and inclusive teams help us anticipate and meet market needs in new ways, improve decision making and develop resilience. We also believe diversity, equity and inclusion enables us to better understand our clients, provide sustainable value, attract the best talent in the market and increase employee engagement, productivity, retention and innovation therefore making Hiscox a stronger partner for our customers.

At Hiscox, diversity is building a workforce that reflects the makeup of our customers, the communities we serve, and the communities in which we live and work and ensuring that we have employees with different backgrounds, perspectives and experiences. Inclusion is fostering a workplace culture where everyone is involved, treated fairly, knows they are respected, heard and valued, feels a deep sense of belonging, and can thrive.  Equality is equal access to opportunity, advancement, support and reward, while employee equity is the removal of the behavioural and structural barriers that allow us to achieve equality. Diversity, equity and inclusion, go hand in hand – without an inclusive and equitable workplace culture, diversity amongst employees will not have the desired positive impact on our business.

At Hiscox, we want to provide equal opportunities to all in employment, irrespective of their sex, gender, gender identity, sexual orientation, ancestry, disability, age, religion, beliefs, marital status, military service, veteran status, genetic information, social class and race including colour, nationality, citizenship status, ethnic and/or national origin.

  • Our commitment  
    • To build a workforce that reflects the diversity of the customers and communities we serve, and the communities in which we live and work.
    • To create an environment where all our people can thrive. 
    • To ensure that being successful at Hiscox is purely down to talent, personal values and effort, consistent with our value of being human: clear, fair and inclusive.
    • To embrace and value individuals’ visible and non-visible differences.
    • To remove behavioural and structural barriers to equality.
    • To create an environment and culture where employees have the support to make decisions, find solutions, take risks and learn, and all take ownership to lead progress in diversity, equity and inclusion.
    • To ensure all employees feel heard, valued, engaged and respected.
    • To build a culture with psychological safety for all.
    • To recognise and invest in the value that a diverse workforce can bring.
    • To challenge and investigate discriminatory behaviour and enforce the disciplinary procedure, when this is considered necessary.
    • To proactively address any inappropriate behaviours.
  • Policy application

    We are committed to promoting equality of opportunity, providing an inclusive workplace and eliminating any unfair or unlawful discrimination in all areas of our business. DEI goals and plans to achieve those goals are set at the local business level. These plans are monitored centrally and also via specific local reports to subsidiary Boards. This approach is supported by an annual report on DEI to the Hiscox Ltd Board. We will continue to review our current systems and processes to seek opportunities to improve our DEI data collection and practices in order to progress and achieve our DEI vision. This includes considerations of our employment policies and practices relating to (but not limited to): 

    • recruitment and selection;
    • terms and conditions of employment;
    • working environment;
    • communications;
    • training and development;
    • promotion and career progression;
    • flexible working;
    • compensation and benefits;
    • grievance and harassment;
    • redundancy and re-deployment;
    • disciplinary.
  • Monitoring

In accordance with applicable privacy regulations and an appropriate lawful basis, Hiscox will regularly collect, monitor and analyse available diversity data on employees and job applicants, and will publicly disclose aggregate data as appropriate, to ensure our employment processes are fair and achieving the aims of this policy. We will also monitor compensation in regard to gender and other under- represented groups, and look to broaden (where legally permitted) and include DEI questions within our annual employee engagement survey.

All the information we collect will be held in the strictest confidence and will only be used to illustrate and promote equality, diversity and inclusion and prevent unlawful discrimination.

  • Governance

We will ensure appropriate governance and oversight to confirm that we are adhering to the provisions of this policy, including internal and external party reviews. While this policy is owned by the Global Head of Diversity, Equity and Inclusion, it is overseen by the Hiscox Ltd Board and aligned to the Board Diversity and Inclusion Policy.

Equality policy statement (PDF)

Hiscox equality policy

The purpose of this policy to provide equal opportunities to all in employment, irrespective of their gender, race, disability, age, sexuality, religion, beliefs, marital status and social class. Hiscox strongly opposes all forms of unlawful and unfair discrimination.

Our commitment

  • Every employee is entitled to a working environment which promotes dignity and respect to all. No form of intimidation, bullying or harassment will be tolerated.
  • The commitment to equal opportunities in the workplace is good management practice and makes sound business sense.
  • Breaches of our equal opportunity policy will be regarded as misconduct under the terms of our disciplinary process. A severe breach could constitute gross misconduct.
  • This policy is fully supported by senior management.
  • The policy will be monitored and reviewed annually.

What is the Equality Act 2010?

From 1 October 2010, the Equality Act came into force which aims to simplify, reform and harmonise the UK’s discrimination regime. The Act supersedes all previous acts and legislation namely the Equal Pay Act 1970, Sex Discrimination Act 1975, Race Relations Act 1976, Disability Discrimination Act 1995, Equality Act 2006, Employment Equality (religion or belief) Regulations Act 2003, Employment Equality (sexual orientation) Regulations 2003, Employment Equality (Age) Regulations 2006 and Equality Act (sexual orientation) Regulations 2007.

The act protects the following groups from discrimination which are known as “protected characteristics”:

  • Age
  • Disability
  • Gender reassignment
  • Marriage and civil partnership
  • Pregnancy and maternity
  • Race including colour, nationality, ethnic or national origin
  • Religion or beliefs
  • Sex
  • Sexual orientation

What is discrimination under the Act?

Discrimination can only take place in connection with the protected characteristics. A particular event could give rise to one or more type of discrimination.

The main types of discrimination are:

Direct discrimination – this happens where someone is treated less favourably than another because they have a protected characteristic or they are perceived to have a protected characteristic.

Associative discrimination – this applies to the following protected characteristics: race, religion or belief, sexual orientation, age, disability, gender reassignment and sex. This happens where someone is treated less favourably because they associate with another person who possesses a protected characteristic.

Perceived discrimination – this applies to the following protected characteristics: race, religion or belief, sexual orientation, age, disability, gender reassignment and sex. This happens where someone is treated less favourably because they are perceived to have a protected characteristic. This applies even if the person does not have the protected characteristic.

Indirect discrimination – this applies to the following protected characteristics: race, religion or belief, sexual orientation, age, disability, gender reassignment and sex. This happens where there is a condition, rule, policy or practice that applies equally to everyone but has the effect of being disadvantageous to a particular group who share a protected characteristic.

Harassment – this is unwanted conduct related to a relevant protected characteristic, which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual. Employees can complain of behaviour they find offensive, humiliating etc even if not directed to them and they need not have a protected characteristic themselves.

Victimisation – this applies to all protected characteristics and happens when an employee is treated less favourably because they have made or supported a complaint or raised a grievance under the Act or they are expected to do so.

What do I do if I feel I have been discriminated against?

Hiscox employees should raise any concerns regarding discrimination of any kind with their manager or a member of the HR Team. Any allegation of discrimination should be made via the company's grievance procedure.

 

We want everyone, both within the company and externally, when they have contact with Hiscox, to feel that they are dealing with a decent organisation which lives its values. Harassment, bullying and discrimination of any kind have no place at Hiscox.

Grievance procedure and whistleblowing policy (PDF)

We want everyone, both within the company and externally, when they have contact with Hiscox, to feel that they are dealing with a decent organisation which lives its values. Harassment, bullying and discrimination of any kind have no place at Hiscox.

We have an employee conduct philosophy to ensure all our staff know what is expected of them, and a harassment and bullying policy that makes clear it is incumbent on all of us to behave in a manner which is not offensive to others. These are supported by local HR policies and handbooks.

Grievance procedure

Where problems arise during the course of employment, our aim is for them to be aired and, where possible, resolved quickly and to the satisfaction of all concerned. If this cannot be achieved using an informal route, which may be by raising it with your line manager in the first instance, then we have a fair and equitable grievance process through which action can be taken if necessary. We take this process very seriously and follow it in every case.

Whistleblowing policy

We also have a whistleblowing policy which commits Hiscox to ensuring that an employee will suffer no retaliation or detrimental treatment as a result of raising a genuine concern about mistreatment or malpractice. This policy ensure that employees feel empowered to raise concerns in confidence and without fear of unfair treatment.

Whistleblowing concerns may be raised through a number of different channels; line management; senior management; Head of Group Internal Audit; whistleblowers’ champions or other Non Executive Directors; and externally.

The structures and processes we have in place allows for the proportionate and independent investigation of any such matters, and for appropriate follow-up action to be taken where necessary. Hiscox is committed to dealing responsibly, openly and professionally with any genuine concern about wrongdoing, malpractice or a safety risk in the workplace. As such, any evidence that an individual has acted to the detriment of a whistleblower will be taken extremely seriously.

The Board and the Audit Committee – whose Chair also who serves as a whistleblowing champion – has oversight of whistleblowing and routinely receives reports arising from its operation.

Independent advice

In addition, all Hiscox employees worldwide can access free, confidential advice from Protect, which as an independent charity can provide impartial advice and help with advice on how to proceed in raising a concern.

Hiscox is committed to ensuring that we comply with the provisions of the Modern Slavery Act. As such, we take a zero-tolerance approach to slavery or human trafficking in our supply chains or in any part of our business.

Modern slavery statement

Our policies differ by country. Here you’ll find our parental leave policies (maternity, paternity, parental leave and adoption leave) across the Group.

Parental leave policies

 

Financial and regulatory

Integrity is one of the Hiscox values, and fundamental to this is honest and fair dealing in all activities throughout the Hiscox Group. Hiscox’s anti-bribery and corruption policy is set out within the broader Hiscox Group financial crime policy, which establishes the approach, principles and requirements to comply with relevant laws and regulations, and to minimise the risk of Hiscox becoming associated with such criminal activities.

Anti-bribery and corruption policy (PDF)

Integrity is one of the Hiscox values, and fundamental to this is honest and fair dealing in all activities throughout the Hiscox Group.

Hiscox’s anti-bribery and corruption policy is set out within the broader Hiscox Group financial crime policy, which establishes the approach, principles and requirements to comply with relevant laws and regulations, and to minimise the risk of Hiscox becoming associated with such criminal activities.

This policy applies to all Hiscox business units and subsidiaries, as well as to all employees, officers, contractors, interns, casual workers and agency workers (‘Hiscox staff’).

All Hiscox staff must ensure that they do not engage in any activity which breaches bribery and corruption laws or regulations. To facilitate understanding this is described broadly as:

  • minimising offering, promising, giving or accepting something in exchange for inducing improper conduct on the part of someone else, either directly or indirectly;
  • abusing a position of trust or power, to gain an improper advantage; and
  • offering or accepting any illegal facilitation payments or ‘kickbacks’.

Hiscox staff must report any concerns of this nature as soon as they become aware of them, and may do so via their line manager or a member of the compliance team. The policy also refers staff to Hiscox’s whistleblowing policy and procedures, which provide alternative means of escalation should staff feel unable to report concerns through the usual channels for any reason.

Hiscox is also committed to ensuring that all staff are appropriately trained on this issue. At a minimum, all Hiscox staff must complete mandatory training, including anti-bribery and corruption training, when they join Hiscox, with further refresher training on the subject completed annually.

Hiscox’s anti-bribery and corruption policy complements, and is supported by, a host of other policies including a conflicts of interest policy, gifts and entertainments policy, and Group broker remuneration policy. For example, the Group’s gifts and entertainments policy confirms that it is the policy of Hiscox Group not to make political donations, which we consider to include any gift, loan or deposit given to a political party.

The Group Risk and Capital Committee is responsible for oversight of the Group’s anti-bribery and corruption risk approach as part of its broader remit over financial crime, and reports up to the Risk Committee of the Board.

The Foreign Account Tax Compliance Act (‘FATCA’) is US law designed to prevent US taxpayers from hiding their taxable income offshore.
Effective 1 July 2014, this new law requires US brokers and other withholding agents to check the status of their counterparties when making certain payments (including certain (re)insurance premium payments), in order to ensure the transaction will not – whether inadvertently or intentionally – result in the payment of undeclared US taxable income. Companies and other non-natural entities are encouraged to use IRS Form W-8BEN-E to provide evidence of their FATCA status.

Hiscox is therefore making these forms available for those of its insurance carriers which may be in receipt of US-sourced insurance premiums.

Should you have any queries, please contact:

In Bermuda: An-Wanae Butterfield
[email protected]
+1 441 278 8386

In the UK: Clare Murray
[email protected]
+44 (0)20 7448 6000

In the US: Ron Lemp
r[email protected]
+1 914 273 7468

Hiscox is committed to maintaining a culture of integrity, transparency and accountability to ensure compliance with all applicable financial crime laws and regulations.

Financial crime statement (PDF)

One of Hiscox’s values is integrity. We are committed to maintaining an open culture which ensures transparency and accountability, and allows us to comply with all applicable laws and regulations designed to combat financial crime. Hiscox has a robust set of systems and controls which have been created to ensure that we manage the risk of financial crime appropriately. These are implemented in-line with the Group’s financial crime policy, which was last approved by the Hiscox Ltd board in July 2020.

The policy covers the following areas:

  • bribery and corruption;
  • sanctions;
  • terrorist financing;
  • money laundering;
  • facilitation of tax evasion; and
  • fraud.

Bribery and corruption

The policy sets out the Group’s zero-tolerance approach to bribery and corruption, including so-called facilitation payments, and describes the implications for broker remuneration, gifts and entertainment, and recruitment. It also includes definitions and examples of both bribery and corruption in order to facilitate understanding.

Sanctions

The policy sets out the different types of sanctions that could apply to the Hiscox Group or its clients, the customer due diligence steps that need to be taken (including enhanced steps for higher-risk jurisdictions), the approach to claims payments, underwriting steps to be taken to ensure sanctions compliance, and controls which need to be exercised over delegated authority underwriting and claims handling.

Terrorist financing, money laundering and tax evasion

The policy highlights the main risks to the business from these types of suspicious activities, and how they can be linked to each other. It also sets out the principal obligations on our people to deal with these risks, and steps to be taken for the reporting of suspicious transactions.

Fraud

The policy describes the different types of fraud (both internal and external) to which the Group is exposed, and steps business areas should take in order to protect both the company’s and its customers’ assets. The policy includes broader obligations for staff on issues such as customer due diligence, and the avoidance of tipping-off, which cut across a number of different financial crime types. Financial crime is embedded in the Group’s wider enterprise risk management framework, with regular risk and control assessments across the business, with reporting to risk committees and boards. The policy is underpinned by an annual training programme on all aspects financial crime, completion of which is mandatory for all staff, along with targeted training for specific higher-risk groups of staff. The financial crime policy complements separate arrangements in place for the avoidance of conflicts of interest, insider trading, and whistleblowing.

Hiscox has a responsible approach to tax. We pay the right amount of tax in every operating location, while creating sustainable value for the benefit of the shareholders. We strive to act responsibly by complying with all relevant legislation, meeting all compliance and reporting obligations. We operate in an open and transparent manner with the tax authorities in every jurisdiction. We plan to be efficient with our tax affairs, but tax mitigation is not a driver for activity.

Group tax strategy

Hiscox is required by the UK’s Prudential Regulation Authority (PRA) to submit a Solvency and Financial Condition Report (SFCR) in accordance with the Solvency II Directive. This provides stakeholders with additional information over and above that contained in our annual financial statements.

Hiscox Insurance Company Solvency and Financial Condition Report

The Bermuda Monetary Authority (BMA) requires Bermudian insurers to publish annually a Financial Condition Report (FCR). The purpose of the FCR is to provide stakeholders, including policyholders, regulators and shareholders with additional information on the financial condition of the insurer over and above that contained in the annual financial statements.

Hiscox Ltd Financial Condition Report

The legal process for the proposed merger of Hiscox Europe Underwriting Limited (HEUL) into Hiscox SA (HSA), both of which are part of the Hiscox Group, is underway and as such we have published the HEUL Directors’ Report concerning the merger:

HEUL Directors’ report
Joint merger terms

Health, safety, security and environment

Our health and safety policy is to provide across all Hiscox Group activities and locations, and in as far as is reasonably practicable, a work environment and work activities that together ensure the health, safety and welfare of all our employees and those who are affected by our operations.

Group health and safety policy

Hiscox is committed to protecting the confidentiality, integrity and availability of the data it holds, with an effective Information Security Management System (ISMS) and robust information security controls.

Information security statement

Our environmental policy sets out the standards we aim to achieve throughout Hiscox Group activities.

Environmental policy

Hiscox is committed to protecting your privacy and we set out clearly the information that we may collect from you and how we may use that information.

Privacy policy

Investment and ESG policies

At Hiscox, we have a clear and defined set of values which underpin everything we do and serves to highlight our commitment to conducting business in a socially-responsible way. This approach extends to our supplier relationships, which is why we have put in place a code of conduct for our suppliers.

Supplier Code of Conduct

Our approach to climate issues and the changes taking place in the global risk landscape.

(Re)insurers have a role in ensuring an orderly transition to a low carbon economy and we want to play our part. Hiscox has a Group-wide exclusions policy, effective from 1 January 2022.

ESG exclusions policy

This statement sets down the principles governing investment decisions for the Hiscox Pension Scheme in order to meet the requirements of the Pensions Act 1995, the Pensions Act 2004 and subsequent relevant legislation.

Statement of Investment Principles

Statement of Investment Principles Implementation Statement

Being a responsible business matters to us, and our Group-wide responsible investment policy sets out our position and vision regarding investments as part of the Group’s ESG strategy. Our responsible investment policy is applicable across all Hiscox subsidiaries.

Responsible investment policy statement