Hastings stands out because we focus on getting it right for our 4Cs. It is our belief that ethical conduct is an integral component of running a business successfully and it is an expectation we have of both our colleagues and our suppliers. We continually look at ways to make improvements so we can continue to serve our communities and be a good neighbour.
Section 172 Statement (“Statement”)
As required by the Companies (Miscellaneous Reporting) Regulations 2018 the Company has published its Statement within its Annual Report for the financial year ended 31 December 2019. The Annual Report and the Statement can be found here.
Environment, Social and Governance ("ESG")
The Company’s approach to ESG is based on its 4Cs ways of working. The 4Cs principles are simple: by creating the right culture for colleagues, and giving them the right tools to do their job, they will do more for customers, enabling the company to grow profitably and sustainably, and allowing it to invest in the communities it serves.
Ethical conduct and strong governance is integral to meeting the needs of colleagues and customers and running a successful business, and a broader focus on the environmental and social impacts of the Company’s activities underpins that philosophy.
The Company continues to develop and enhance its ESG strategy, to include specific metrics and targets across those areas that most impact on the Company’s sustainability for the long term, with full consideration of the impacts of climate change on and from the Company’s operations. Certain factors are already well developed with relevant metrics and targets, for example gender diversity, gender pay-gap reporting, and certain environmental matters.
Each colleague is responsible for delivering our everyday activities in a way that reflects ethical principles. We play our part by:
- invite our customers to receive all their documentation electronically;
- support local businesses by incentivising colleagues with a range of unique offers to encourage and incentivise them to buy from local retailers and suppliers;
- promote a Travel Green scheme that supports our colleagues to make greener journeys to work through car sharing, increased cycle use, and discounted rail travel;
- provide dedicated recycling and confidential waste stations within our offices;
- promote re-usable cups for coffee and tea to reduce the c.20,000 plastic-lined cups previously used every month alongside the use of dedicated coffee cup recycling stations;
- protect the environment, and contribute to measures to combat the adverse effects of climate change, by banning all single use plastic cups from all of our sites in 2019, removing c.350,000 disposable plastic cups from the environment, and introducing compostable packaging and cutlery in our in-house restaurants;
- use reduced energy electric light bulbs and motion sensitive lighting where possible and practical; and
- recycle unwanted furniture and computer equipment by donating it to local charities and organisation.
The Group’s Conduct Policy provides guidance on the appropriate and responsible conduct of colleagues and the ethical standards they are required to uphold. The Group strives to maintain the highest standards of governance, personal and corporate ethics, and compliance with laws and regulations. It values integrity and honesty in dealings with all stakeholders to ensure that financial and reputational damage is minimised. The policy provides guidance on the Group’s expectations in relation to: conduct with customers, anti-corruption and anti-bribery, conflicts of interest, gifts and hospitality, colleague engagement and wellbeing, and the community within which the Group operates. Regular training is provided to colleagues on conduct matters and is monitored through regular assessment and half yearly personal development reviews.
Business ethics risks are reviewed by management and overseen by the individual governance forums on a regular basis. The Group's broker, Hastings Insurance Services Limited ("HISL"), has established a Board Conduct Committee which provides assurance to the HISL Board that the fair treatment of customers remains at the heart of the business model and monitors all aspects of HISL's operational performance that reflect whether the Company pays due regard to the interests of its customers, treats them fairly and is effectively mitigating conduct risk.
The Group has in place risk and compliance functions that oversee and monitor risk and regulatory matters at a Company level and within HISL and the Group's insurance company, Advantage Insurance Company Limited ("AICL"). A Chief Risk Officer has been appointed by the Group and he is assisted by respective heads of risk and compliance within the Company’s trading subsidiaries who have responsibility for risk and compliance matters. Compliance functions monitor their respective company’s compliance with local regulation and legislation and provide advice and guidance on all compliance matters. Compliance assurance monitoring is also undertaken across business operations to ensure the Group’s operating subsidiaries comply with their regulatory obligations and that processes and procedures are in place and are adhered to. This monitoring complements the reviews undertaken by the independent internal auditor. Further information on internal controls and risk management can be found within the Managing Our Risks section and the Risk and Audit Committee reports within the Company's latest Annual Report.
As the ultimate parent entity, the Company establishes the overarching principles and approach to governance within the Group. As a listed company the Company is required to comply, or explain any non-compliance, with the Code as well as adhere to various other requirements such as the Listing Rules and the Disclosure and Transparency Rules. The Group’s trading entities, HISL and AICL, are private companies and whilst they are not obliged to apply the Code where practical and appropriate, they adhere to the spirit of the Code; HISL has adopted the Wates Principles as its primary governance code.
The Company and its subsidiaries have unitary boards in common with best practice within the UK. The respective boards of HISL and AICL each has a majority of independent non-executive directors. To ensure effective communication with, and oversight by, the Company of the subsidiary companies, each of the subsidiary boards has one independent non-executive director who also serves in that capacity on the Company Board. HISL and AICL also comply with other regulatory obligations that apply to financially regulated firms in the UK and Gibraltar respectively, for example the FCA Handbook and Solvency II.
Supplier due diligence
Strong and productive supplier relationships are key to the Group’s continued success. We work closely with our local and national suppliers to communicate our standards, values, principles and sustainability goals to them and ensure they are aligned in helping us offer the best price, product and service solutions to benefit our customers and colleagues.
Suppliers of key services to the Group are subject to a robust due diligence process under a Supplier Relationship Management Framework in order to enhance relationship and risk management. Critical suppliers are subject to ongoing reviews throughout the year at which service levels and adherence to processes and procedures are discussed and improvements made as appropriate.
Whistleblowing, fraud and anti-bribery and corruption
A whistleblowing policy is in force across the Group to enable colleagues to raise potential or actual serious matters of misconduct which they believe would damage the performance or reputation of the Group. A confidential, externally serviced hotline and web reporting tool that is open 24 hours-a-day, every day, is provided for all colleagues to raise matters of potential or actual misconduct. Colleagues are encouraged to disclose, in good faith, the actual or suspected activity where they believe that at least one relevant failure is currently occurring, has taken place in the past, or is likely to happen in the future. Colleagues can make a report anonymously should they so choose. Any colleague that makes a report will be accorded protection under legislation and any colleague who makes a disclosure in good faith will not suffer reprisals, victimisation or discrimination.
An internal framework is in place to process all reports received and ensure that the details of the report remain confidential at all times. The Group’s Company Secretary, Chief Risk Officer and Group HR Director are notified by the whistleblowing service provider once a report has been made. They decide if the matter warrants investigation and will appoint an investigator if warranted. No manager is involved in an investigation that relates to his/her own department or where they are the subject of that report. The investigator is instructed not to disseminate any further information than is required to undertake the investigation.
All colleagues are expected to co-operate fully, openly and honestly with all investigations during which colleagues will be appropriately accompanied or represented. Once the investigator has completed his/her report, then the details are reviewed by the Company Secretary, Chief Risk Officer and/or the Group HR Director who will decide if action is to be taken or the matter is deemed to be closed and no further action required. The colleague who made the initial report will be notified of the outcome via the whistleblowing portal and not contacted directly. The details and outcome of the investigation are saved within the confidential reporting system.
Financial crime, for example money laundering and/or terrorist financing, is a serious matter for all companies and more so for those that operate within the financial services sector. The Group has policies in place in relation to combatting money laundering, terrorist funding, fraud, bribery, corruption and tax evasion. Colleagues are required to undertake regular awareness training on all types of financial crime and must follow policies, procedures and guidelines in relation to all financial operations. Background checks on prospective and existing colleagues are undertaken throughout the year to help combat internal fraud.
The Group also ensures that unethical practices do not take place relating to bribery and/or corruption and it is committed to prohibiting such activities within its operations and dealing with suppliers and service providers. This prohibition also extends to facilitation payments that may be used in certain industries and/or countries where payment of cash or gifts to an official are used to enable transactions to be accelerated, by-passing usual bureaucratic processes. All colleagues are required to disclose gifts or hospitality that may be offered by any external party over £100, either as a single or multiple gifts in a rolling year, whether accepted or declined. Routine audits of expense claims and/or gifts received are undertaken throughout the year. HISL and AICL's Money Laundering Reporting Officers are responsible for the application of anti-bribery and anti-corruption measures and reporting, ensuring the business undertakes bribery and corruption risk assessments and that regular training is provided to all colleagues. The Group has zero appetite for bribery and corruption whether offered to, or given by, any colleague and uses the definition of bribery contained within the UK Bribery Act 2010.
Colleagues are made aware of the whistleblowing hotline, and the Group’s anti-fraud, anti-bribery and anti-corruption measures via the intranet, mandatory training, and posters displayed in prominent areas.
During 2019 no significant matters relating to financial crime, either internally or externally, with the exception of external fraudulent claims and ghost broking identified as part of normal business operations, were reported. Also no matters of significant misconduct were raised through the whistleblowing hotline.
Grievance/disciplinary procedures and colleague’s freedom of association
The Group promotes a safe, diverse and inclusive environment, free from bullying, harassment and discrimination, within which all colleagues should be treated fairly and with respect. The Group is committed to eradicating all types of discrimination, whether based on disability, religious beliefs, gender, sexual orientation, age, or other factors.
It is hoped that no colleague will need to raise a grievance against the Company and/or one of its colleagues. If a colleague wishes to raise a grievance this is resolved informally and as quickly as is possible. Where it is not possible to resolve a grievance informally a formal procedure is instigated.
Disciplinary procedures against colleagues are used as a last resort where a breach of the standards and/or performance expected from colleagues’ falls significantly short or where fraud or other criminal activity is proven. Treating colleagues fairly and consistently is key to maintaining the correct level of conduct. When a colleague fails to meet the required standards expected of them, other than in case of gross misconduct, they are coached and provided with development and training to improve. Referral to counselling or wellbeing services may also be offered. In the event that standards of conduct and/or performance do not improve over a period of time, then disciplinary measures may be required. Acts of gross misconduct by colleagues, such a serious breach of the contractual relationship between the colleague and the company, will usually result in dismissal with or without notice.
Colleagues are free to be appropriately accompanied in relation to a grievance or disciplinary matter. In the event that a grievance is not upheld, or a disciplinary matter is not dealt with to the satisfaction of the colleague, they have the right to appeal. In addition should colleagues feel the need for additional support, the Company provides a colleague assistance programme, free of charge, so that colleagues can obtain free and independent external advice.
The Company does not formally recognise a trade union, preferring to communicate and engage with colleagues directly either through the Hastings Colleague Forum, the YourVoice colleague survey, via email and intranet, and/or directly with individual colleagues as appropriate. Trade union membership is not, however, prohibited and the Company does not restrict union representation at a grievance or disciplinary meeting should any colleague request such.
Data and cyber security and privacy rights
The Group takes the protection and integrity of personal data very seriously. Management continually works on developing and enhancing the Group’s information security framework which is designed to identify and understand potential threats as well as manage and mitigate potential risks. By investing in IT security and cyber resilience the Group is introducing and refining controls to protect data it retains as well as detect, prevent and respond to cyber-attacks.
Management maintain a focus to ensure customer statutory privacy rights are upheld, including a commitment to process personal data securely by means of appropriate technical and organisational measures. During 2019 the Group attained Cyber Essentials certification and successfully completed assessments for PCI DSS compliance for both e-commerce and mail order and telephone. Information security, cyber security and data protection and data privacy policies are in place and sit alongside the technical and procedural controls to combat financial crime, bribery and corruption. Mandatory training on these matters is conducted across the Group for all colleagues and supplementary training is also provided where required.
The Group’s cyber, data and privacy governance links security and data activities to the Group’s goals and strategy, engages and empowers colleagues who are responsible for making security and data decisions, and promotes effective management of cyber and data risks including building an adequate response to cyber-security threats. This governance framework seeks to address process and human vulnerabilities, reduce the complexity of the Group’s technology and data estate, and embed cyber security consideration in all business decision making. Operational measures are in place to monitor and respond to data breaches and cyber-attacks. These measures are routinely and independently validated and tested, through vulnerability assessments and penetration testing.
In May 2018 the General Data Protection Regulations ("GDPR") came into force replacing the Data Protection Act 1998. The Group has a dedicated Data Protection Officer in line with the requirements of GDPR and a data protection team that administers colleague and customer subject access requests. A breach management process has been established and colleagues are encouraged to seek advice if in any doubt in relation to data protection. The Group’s data, information and security framework is supported by a communications strategy to enhance existing privacy culture and awareness on all aspects of colleague interaction with personal information.
The Group is committed to data subject privacy and protecting all data that it is responsible for and retains. It has implemented a number of measures to ensure that user data is obtained through authorised, lawful and transparent means with the explicit consent of the data subject; that data is collected and processed for limited and stated purposes; and, if transferred to third parties, that these parties have robust policies in place to ensure that data is protected at all times and only processed for the intended and stated purpose. The Group ensures that its approach to the collection, use, sharing and retention of user data is clearly stated and available to all data subjects. A formal data protection policy is in place that applies to all of the Group’s operations, whether that data relates to existing or potential customers or colleagues. Should privacy notices and other data policies that apply to data subjects be amended, the Group is committed to notifying those data subjects affected in a timely and appropriate manner.
The Group believes that sustainable, medium to long term, investing extends beyond the evaluation of quantitative factors and traditional fundamental analysis of financial metrics, and should consider an entity’s impact on stakeholders, the environment and society. Furthermore, ESG factors can affect investment performance, expose potential investment risks, and provide an indication of management excellence.
During the year, the AICL Board agreed to incorporate ESG considerations into its investment strategy and decision making, seeking to achieve a high average ESG investment rating, while maintaining its conservative investment strategy that focuses on capital preservation and alignment to underlying insurance liabilities. AICL's independent investment advisor and asset manager, both signatories to the UN Principles of Responsible Investment (www.unpri.org/), are providing support and expertise in this area.
AICL's independent investment advisor also undertakes evaluations of our third party investment managers’ approach to ESG and compliance with industry standards, for example the UK Stewardship Code. The integration of ESG criteria looks beyond the existence of policies and procedures and also investigates underlying ownership and holdings. In addition, a ‘comply or explain’ approach is taken over a range of ESG factors, when initially screening managers, and on an ongoing basis, providing a framework to evaluate investment manager behaviour. Our advisers continually develop their research process, investment strategy modelling tools and reporting by incorporating innovative thinking on ESG matters.
The 2019 Gender Pay Gap Report for HISL, the main employer and only entity with more than 250 employees in the Hastings Group, can also be found here.
The Group's Greenhouse Gas Report can be found in the Company's latest Annual Report, an extract is provided below.