Group policies and disclosures

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.

Over the past few years, sustained effort across our business has meant that we’ve been able to reduce our gender pay gap substantially, by almost half on a mean basis since we began reporting in 2017. 

This year, our gender pay gap remains broadly unchanged at 16% on a mean basis and 17.5% on a median basis. So while we’ve come a long way, we know we still have work to do and we remain as fully committed to building a diverse and inclusive environment as ever. 

It’s important to remember that these measurements reflect the higher proportion of men than women in higher-paid, senior roles and should not be confused with ‘equal pay’. We have established structures and processes which ensure that men and women are paid equally for equivalent roles. 

Our efforts are focused on getting more women into senior roles, and we look to achieve this in a number of ways; we have DEI action plans in place across the business that are measured and monitored, looking at everything from recruitment and career development to succession planning. We’ve always been passionate about recruiting based on talent and talent alone. This means striving for gender-balanced shortlists for all of our roles, gender-balanced interview panels, as well as partnering with a breadth of organisations such as The Bright Network, Visionpath and SEO London to reach more diverse early years talent.

Our talent review process is focused on building a strong pipeline of women leaders and mentoring is available to all employees, as we look to improve readiness for leadership roles at mid-manager level. We’ve focused particular attention on building gender diversity into our succession plans, including at Board level. 

Only by looking at diversity in all its forms across our organisation will we truly understand how well Hiscox is working for our people, and I’m pleased that we’re making strides when it comes to building our data capability in this area. We’ve collected data on gender and race/ethnicity on a global basis for some time and this year we published our employee ethnicity metrics in our Annual Report and Accounts for the first time. We’re also encouraging colleagues to ‘self-ID’, where local laws allow, giving employees the opportunity to define themselves across a range of characteristics, including sex, race/ethnicity, and in some countries sexual orientation, disability, as well as gender identity. 

This data will help us make the invisible more visible and build a more complete picture of our workforce (including intersectionality), help us understand our progress against our DEI strategy, and enable us to make smarter, more inclusive policy decisions that support both career and business success. 

I hope you find this report useful, and I can confirm that the data set out in the following pages is accurate. 

Kate Markham 

Chief Executive Officer, Hiscox London Market Executive Sponsor, diversity, equity and inclusion

Gender pay gap report 2023 (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.

Grievance procedure and whistleblowing policy (PDF)

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 People 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 a person will suffer no retaliation or detrimental treatment as a result of raising a genuine concern about mistreatment or malpractice. This policy ensure that both employees and other internal and external stakeholders feel empowered to raise concerns in confidence and without fear of unfair treatment.

Whistleblowing concerns may be raised through a number of different channels; independent third party, line management; senior management; Group Chief Auditor; 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.

Whistleblowing – expressing your concerns 

The Hiscox Whistleblowing policy commits the organisation to ensuring that a person will suffer no retaliation or detrimental treatment as a result of raising a genuine concern about mistreatment or malpractice. This policy ensure that both internal and external stakeholders feel empowered to raise concerns in confidence and without fear of unfair treatment. 

1.1 Who is eligible to report a concern? 

Whistleblowing occurs when a person makes a disclosure of information about a danger, risk, malpractice or wrongdoing or provides certain types of information, usually about illegal or dishonest practices within an organisation. A whistleblower is a person who raises a genuine issue relating to a whistleblowing concern. The Whistleblowing policy will apply to all who acquire information on breaches, which includes (but is not limited to) the persons listed:

• All Hiscox’s current and former employees
• Hiscox job applicants or those whose employment contracts have not started
• Officers
• Contractors, subcontractor, its direction members and their employees
• Volunteers, interns or trainees
• Casual workers
• Suppliers and agency workers
• Shareholders and members of the administrative, management or supervisory non-executive bodies. 

1.2 What can be reported? 

The following is a non-exhaustive list of matters which might be considered as whistleblowing concerns: 

• criminal offences
• fraud or misconduct
• financial mismanagement
• health and safety issues
• failure to investigate allegations of harassment or assault by one employee against another
• failure to comply with legal obligations
• bribery, or corruption or financial crime
• failure to comply with regulatory obligations
• failure to comply with internal policies and procedures
• behaviour that is likely to harm the reputation or financial well-being of Hiscox
• the deliberate concealment of the above
• threat for public interest or a legislation violation 

2. Internal reporting channel and external reporting channel 

Whistleblowing concerns may be raised through a number of different internal channels and externally.

2.1 Reporting through internal channels 

In order to make our internal channel compliant with the above measures, it will remain available for staff members through the channels described in the Policy and Procedures available on the intranet (The Gallery). 

The below channels are extended to all eligible persons via: 

Web, via: https://www.safecall.co.uk/report/ 

Service call: the Safecall service is available 24/7 365 days via the number below and allows you to speak to someone in your preferred language (see following link for international freephone numbers - https://www.safecall.co.uk/en/file-a-report/telephone-numbers/) 

Email address: [email protected] 

Post to the following address: 22 Bishopsgate, London EC2N 4BQ; United Kingdom, attn Roshni Patel 

In person: Concerns can also be reported in person. If this is your preference, please let us know using one of the above channels. 

If you request an in-person meeting, the meeting may, subject to your consent, be documented by (I) recording the conversation in a durable and retrievable form or (II) keeping accurate minutes of the meeting prepared by members who are responsible for handling your report. We also offer you the opportunity to check, correct and approve the minutes of the meeting by signing them. 

Reporting can be done anonymously if preferred, and every effort will be made to preserve the confidentiality of the whistleblower. The identity of the whistleblower or any third parties involved will only be disclosed in circumstances where this becomes unavoidable by law (for example due to the obligation of Hiscox to inform the authorities if the facts are likely to constitute a crime or misdemeanour). 

Measures against retaliation and confidentiality 

Hiscox will not permit any retaliation or harassment against a whistleblower or any connected person who assists in an investigation due to their involvement in a report and/or investigation. This also applies in cases where an investigation does not confirm the allegations made. 

Your information will be treated confidentially. This confidentiality also applies to all other information from which the identity of the reporter can be directly or indirectly derived. We take appropriate measures to handle all information received carefully and to safeguard the interests of all those involved. All data provided will be processed in accordance with applicable data protection regulations and our privacy statement. For more information about our privacy statement please revert to our website: https://www.hiscoxgroup.com/site-tools/privacy 

Follow-up 

When you submit a report, you will receive confirmation of receipt within seven days. We encourage you to provide us a with a contact detail (like your name and/or an email address) when submitting a report. This way we can contact you for any follow-up questions. However, if you prefer to remain anonymous, we will respect your decision and your case will still be investigated. Feedback will be provided within a reasonable timeframe which shall not exceed three months from the acknowledgement of receipt. 

2.2 Reporting through external channel 

Whistleblowing alerts may be reported independently to a relevant regulator; one such example is the UK FCA and PRA’s whistleblowing channels. In addition, whistleblowing alerts may also be reported independently to the Commissariat aux Assurances (CAA) in Luxembourg. External channels are also available with the relevant regulators within the other European countries in which HSA operates. It is recommended that all eligible reporting person to first use our internal alert procedure via the channels described above before contacting the regulator for external report.

At Hiscox we consider human rights to be the fundamental rights and freedoms that belong to everyone, regardless of their nationality, race, ethnicity, religion, gender, sexual orientation, disability, age, or any other status. Human rights are based on the principles of dignity, equality, and respect, and they are enshrined in the Universal Declaration of Human Rights and other international treaties and laws, which have guided our approach. 

As a Group, we are committed to respecting and protecting human rights in every part of our operations, supply chain, and within the communities we serve. We recognise that our activities may have direct or indirect impacts on the human rights of our employees, customers, brokers, suppliers, contractors, business partners, investors, and other stakeholders. 

Equally, we know we have a responsibility to use our influence and leverage to prevent or mitigate any adverse human rights impacts that are linked to our business, and we take these responsibilities seriously. 

We value our employees and their well-being. We ensure fair compensation, embrace diversity and inclusion, provide equal opportunities, and uphold human rights in our interactions and decision-making processes. In the UK, we have been recognised as a Living Wage employer since 2019. We maintain further internal policies that are relevant to human rights and this Policy and there are listed in the Appendix.

Hiscox human rights policy (PDF)

Modern Slavery Statement (PDF)

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (‘The Act’) and constitutes the slavery and human trafficking statement for the financial year beginning 1 January 2023 and ending 31 December 2023 for the entities listed in this statement (the "Hiscox Companies"). Our previous statement can be accessed here - https://www.hiscoxgroup.com/modern-slavery-act.

Our Commitment 

Hiscox is committed to maintaining a culture of integrity, transparency and accountability to ensure compliance with all applicable laws. This includes our ongoing commitment to ensuring that modern slavery and human trafficking do not take place in any part of our business or supply chain. 

This statement sets out the steps that have been taken by the Hiscox Companies during the financial year ended 31 December 2023 to identify and respond to any modern slavery risks that might exist. 

Our values guide our business: to have courage and integrity, to show ownership, to connect with our stakeholders and, above all, to be human. At the heart of our business is a desire to challenge convention and to always do better. This is evidenced in our approach to Modern Slavery and our commitment to continuously improve. These values have been fundamental in building Hiscox’s reputation for upholding ethical behaviour in everything we do, which in turn support the morale of our staff and the results of the business. 

Our business is answerable to all its stakeholders, including but not limited to our investors. The benefits of being a good corporate citizen go far beyond profitability. We strongly believe in the rule of law and we are committed to complying with all relevant international and local laws wherever we operate. We expect the same from our business partners, contractors and agents.

“Hiscox aims to uphold the highest standards of integrity and human rights within our operations and supply chain. We regularly review the risks of modern slavery associated with our business and those we work with and we are committed to partnering with our stakeholders to eradicate it. This year we engaged an independent third party to run an additional audit of our internal processes so that we can build on our existing practice and identify further areas for improvement. Combatting modern slavery takes a collective effort and we are committed to playing our part.” – Aki Hussain, Group Chief Executive Officer 

Our Structure 

The Hiscox Group employs over 3,000 people with customers worldwide. We are headquartered in Bermuda and have offices across 14 countries including: Belgium, Bermuda, France, Germany, Guernsey, Ireland, Luxembourg, Netherlands, Portugal, Singapore, Spain, Thailand, United Kingdom and the USA. Through our insurance businesses in the UK, Europe, Asia and the USA, we offer a range of specialist insurance for professionals and business customers as well as homeowners. Internationally traded, bigger ticket business and reinsurance is underwritten through Hiscox London Market and Hiscox Re & ILS.

The following subsidiaries of Hiscox Ltd, the parent company, are covered by this group statement (the Hiscox Companies):

• Syndicate 33
• Syndicate 3624
• Syndicate 6104
• Hiscox Dedicated Corporate Member Limited
• Hiscox Underwriting Group Services Limited
• Hiscox Syndicates Limited
• Hiscox Insurance Company Limited
• Hiscox Holdings Limited
• Hiscox PLC
• Hiscox Insurance Holdings Company Limited
• Hiscox Société Anonyme

Our Policies 

We have a number of policies that mitigate the risk of slavery and human trafficking, guided by the principles of the UN’s Universal Declaration of Human Rights and the International Labour Organisation’s core labour standards. 

The Hiscox Supplier Code of Conduct is mandatory and requires that our suppliers act in congruence with our values relating to good corporate citizenship. Any breach of the Supplier Code of Conduct is unacceptable and in the rare occasions this occurs we work swiftly with our suppliers to identify and address root issues and enhance our practices to ensure the underlying issues do not reoccur.. Our culture encourages employees to raise any concerns relating to malpractice or wrongdoing, including issues related to slavery and human trafficking, without threat of unfair treatment as a result. If an employee has a serious concern relating to the operation of the business, we have a Whistleblowing Policy and Whistleblowing Procedures that enable that person to confidentially raise their concerns.

During 2023, as part of our annual review cycle, we updated our Whistleblowing Policies and Procedures to align with the latest regulatory guidance and expectations, as well as to incorporate feedback on best practice received from an external provider. We also enhanced our overall whistleblowing framework by engaging an external service provider to give staff and other stakeholders the option to raise concerns outside of the existing internal channels, either through an independent phone line with multi-lingual capabilities, an independent email, or a secure confidential web portal. Employees also have the option to raise their concerns with the Chair of the Hiscox Ltd Audit Committee. In addition, all staff worldwide can access free, confidential advice from an external service provider in relation to any concerns about possible malpractice or wrongdoing in the workplace. 

The following policies underpin our efforts to ensure that we are addressing the risk of modern slavery across the business.

• Our Supplier Code of Conduct
• Grievance Procedure and Whistleblowing Policy
• Diversity, Equity and Inclusivity Policy
• Equality Policy
• Anti Bribery and Corruption Policy
• Responsible Investment Policy
• Financial Crime Policy: covers sanctions put in place by governments and organisations (e.g. United Nations) to restrict trade activity with particular people, companies, territories and/or trade sectors to achieve a particular political aim (such as improving human rights or preventing nuclear weapons development)
• Hiscox Group Outsourcing Policy
• Data protection & Privacy Policy 

Ultimately our Group CEO has responsibility for all the policies listed above, many of which are also signed off and approved by our Group and Subsidiary Board of Directors. Ongoing improvement and embedding sits with the associated Group functions. Adherence to our policies and standards are monitored by our Risk Management and Compliance teams. 

We continue to develop Hiscox’s overall human rights and sustainability strategies which will include provisions to continue to identify and prevent modern slavery. Our Group CEO will sign off on this strategy whilst the responsibility for its development sits with our Group General Counsel & Company Secretary and our Sustainability Manager. In 2024, we plan to publish our Human Rights Policy and roll-out a Group Code of Conduct internally, both of which will support this statement. 

Risk management 

We are committed to ensuring that slavery and human trafficking do not exist within any part of our business or our supply chains. Although we procure services from a wide range of suppliers who support us in the fulfilment of insurance claims and carrying out our business activities, based on our initial risk assessment we consider the exposure to slavery and human trafficking-related supply chain risk to be limited by a low reliance on sectors, countries or regions which are at heightened risk of slavery and human trafficking. We are, however, aware that the risk of modern slavery is higher in some of the countries we operate in, for example Thailand, and we intend to factor this into our risk management system which will be strengthened in the coming year. 

Our procurement process requires that prior to entering contracts with suppliers, our procurement team assesses the services a supplier provides and the associated risk and delivers the appropriate due diligence. During 2023, we began embedding EcoVadis, a global ESG platform within our procurement function starting with all new suppliers in our high spend / risk categories, which will enable us to gather further supplier data and insight, and develop our Key Performance Indicators (KPIs) in this space. To date we have captured 150 of our current suppliers through EcoVadis which all fall into our categorisation of high risk and spend.

Within our business, we are aware of risks associated with outsourced services such as logistics, canteens, cleaning and waste management. All outsourced service providers are subject to our standard procurement process. In addition, our Responsible Investment Policy sets out the high level responsible investment principles implemented within Hiscox’s investment portfolio by our in-house investment team. 

Due diligence 

In keeping with our commitment to ensuring that modern slavery and human trafficking does not take place in any part of our business or supply chain, we continue to mitigate the supply chain risk by strengthening our supply chain practices. We will not support or engage suppliers where we are aware of slavery or human trafficking in either their business or supply chains. In addition to undertaking appropriate due diligence of suppliers as part of the on-boarding process, and at regular intervals thereafter, we have additional controls for contracts with suppliers that represent our most significant expenditure. 

During 2022, we implemented the Financial Services Qualification Scheme (FSQS) operated by Hellios, a market leading supplier due diligence community which is used by over 50 other Financial Services organisations. FSQS provides a standard and simple mechanism for collecting and managing supplier assurance information across the Group and across the wider Financial Services community. FSQS is an integral part of our sourcing process. Our Sourcing Specialists use the system to find pre-qualified suppliers to be considered for new business. Qualified supplier status gives visibility across our Procurement process and, therefore, creates potential new opportunities. 

FSQS is a two-stage process, with Stage 1 assessing the risk of the supplier including access to customers, location of services, access to data, etc. All risk responses are reviewed, including forced labour and modern slavery. If the supplier is deemed to be low risk, the process stops after Stage 1. For all other suppliers that must move on to Stage 2, they must answer a variety of questions linked to risk, including questions relating to modern slavery. 

During 2023 we also implemented EcoVadis, a global ESG platform. At the point of tender, all suppliers are notified that they may be selected and required to complete the EcoVadis assessment. Hiscox reviews the reports of these suppliers which can identify any gaps or incidents of note. No incidents have been found, but if one is identified the relevant risk functions would be notified and the issues would be addressed with a prompt and thorough review. Both of these partnerships enhance our supplier due diligence assessments and incorporate modern slavery. 

We continue to monitor our whistleblowing channels to identify any reported cases of modern slavery or exploitation of workers. In addition, the Board and the Audit Committee – whose Chair also serves as the Group’s whistleblowing champion – have oversight of whistleblowing matters and receive reports arising from its operation. The Company’s whistleblowing policy is designed to ensure that the workforce feel empowered to raise concerns in confidence and without fear of unfair treatment. The structures and processes in place allow for the proportionate and independent investigation of any such matters, and for appropriate follow-up action to be taken where necessary. The policy applies to both our employees, suppliers and agency workers. This policy is communicated to our suppliers through our Supplier Code of Conduct and can also be found on our website. 

Hiscox also has an internal grievance procedure which addresses problems that may arise during the course of employment. This procedure aims to resolve issues quickly to the satisfaction of all concerned. 

Training 

All our employees undertake annual mandatory regulatory training which includes specific content on raising concerns within the business. During 2022, we reviewed the training requirements for the business relating to modern slavery and human trafficking. We contracted with an external company to deliver an enhanced and focused modern slavery training module during 2023, and 155 of our business leaders, risk managers, office managers, and our procurement team completed the training. 

Additionally, our procurement team, of approximately 20 employees, and several super users received training on the use of the EcoVadis system. This training included how to work with suppliers and how to access supplier data and scorecards on their ESG profile, including labour issues, environmental ethics and responsible procurement matters. 

Monitoring and effectiveness 

No instances of non-conformity with the Supplier Code of Conduct were reported through any of our whistleblowing channels in 2023. 

In 2023 there were no suspected cases of Modern Slavery reported through the Whistleblowing channel, however, we remain diligent in monitoring our business and suppliers to ensure slavery and human trafficking do not feature in our business or supply chain. 

Should any such incident occur, our policy prioritises fair and objective investigation so that those who have experienced adverse impacts gain access to appropriate remedy. 

We are committed to transparent reporting of our progress in addressing modern slavery risk. We are in the process of enhancing our KPIs, which will help us ensure compliance with our standards across our value chain and identify any areas that need further work. The KPIs will align with our purpose; we believe in building a clear, fair and inclusive business so that we can build better, together. 

Some of the metrics we currently use are noted in the table below.

Looking forward 

We recognise that tackling modern slavery risk is an ongoing issue and Hiscox will continue to develop and improve our approach to respecting human rights and preventing modern slavery across its operations and supply chains. We have engaged with third party experts Ardea International, specialist consultants focusing on Modern Slavery Risk, to assist us with Human Rights and Modern Slavery best practice and the associated review of our Modern Slavery Statement. Ardea will also assist with a more detailed gap analysis to help us further strengthen our practices in relation to Human Rights and Modern Slavery.

We will seek to collaborate and partner with external experts to share best practices and seek to mitigate the risk of modern slavery. 

During the next reporting year we will: 

• Review and update our policies to ensure they address the risk of modern slavery and human rights
• Continue to mitigate our supply chain risk by strengthening our supply chain practices.
• We have identified the need to carry out a risk assessment across our own operations, supply chain and investment portfolio
• Continue to review and enhance our Whistleblowing Policy and Procedures against best practice and regulatory standards
• Enhance our due diligence processes, including procurement processes to address risk highlighted in a formal risk assessment
• Enhance KPIs to monitor our progress in addressing modern slavery risk
• Ensure that training takes place annually and expand our training to ensure that it is tailored to specific roles and responsibilities
• Undertake a modern slavery gap analysis across our business and supply chain management to identify areas to strengthen 

A statement relating to the previous financial year will be published on an annual basis and published on the Hiscox Group website, www.hiscoxgroup.com. This statement has been approved by the Hiscox Ltd Board of Directors on 27 June 2024 and signed on its behalf by: 

Aki Hussain 

Hiscox Group Chief Executive Officer 

28 June 2024 

Publication date: 28 June 2024

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

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 Insurance Company (Bermuda) Limited – signed W-8BEN-E
• Hiscox Insurance Company (Guernsey) Limited – signed W-8BEN-E
• Hiscox Insurance Company Limited – signed W-8BEN-E
• Hiscox Inc. – signed W-9
• Hiscox SA - signed W-8BEN-E

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. The purpose of our tax strategy is to communicate the policy for the management of tax risk within the Hiscox Group.

Group tax strategy (PDF)

1. Introduction

1.1 Overview of the Group

Hiscox is a global specialist insurer, headquartered in Bermuda and listed on the London Stock Exchange. We can trace our roots in the Lloyd’s market back to
1901 and our adaptability has meant we have evolved organically over time.

Today, Hiscox employs over 3,000 people across 14 jurisdictions with customers and business partners across the globe. As a business we pay taxes in all the jurisdictions in which we operate: including corporate income taxes, payroll and related employment taxes, business property taxes, and sales and other indirect taxes.

We are domiciled in Bermuda for three reasons: its position as a global reinsurance centre, its stable regulatory environment, and its favourable tax environment. The regulatory and strategic rationale for locating in Bermuda are the overwhelming factors in this decision. The Hiscox Group is regulated by the Bermuda Monetary Authority (BMA), under the Bermuda Group Supervisory Framework. The Bermudian reinsurance market is one of the largest in the world with annual gross written premiums in 2022
of $145 billion1. Bermuda’s insurance regime has also been recognised as equivalent to Solvency II.

Hiscox has a UK listing as we believe the London Stock Exchange is a good place for our shares to be traded. It has a strong reputation, deep liquidity and capital market with good insurance expertise.

This tax strategy summarises our approach to ensuring that we pay the correct amount of tax in all the jurisdictions in which we operate.

1 Source: Association of Bermuda Insurers and Reinsurers.

1.2 Review, communication and publication

Ultimate responsibility and ownership of this tax strategy resides with the Board of Hiscox Ltd. It is reviewed and updated annually for approval by the Board.
Board approval is sought in respect of any amendments to this document. Periodic reviews of the tax strategy are undertaken to assess the appropriateness of the strategy
and to ensure tax risk controls and monitoring activities are conducted as documented.
This strategy is effective from 1 January 2024.

1.3 Applicability to UK sub-group

The UK has introduced specific legislation which requires the Group to publish certain information about our tax strategy as it is relevant to the management of UK taxes by our UK subsidiaries. Under paragraph 19(2), Schedule 19, Finance Act 2016, there is a requirement that the UK Sub-Group must prepare and publish a sub-group tax strategy, containing the information required by paragraph 20, in accordance with this paragraph. Hiscox considers that the publication of this tax strategy meets the requirements imposed on its UK subsidiaries by Schedule 19 of Finance Act 2016.

1.4 Risk management

The Group’s core business is to take risk where it is adequately rewarded, guided by a strategy that aims to maximise return on equity within a defined risk appetite. The Group’s success is dependent on how well we understand and manage our exposures to principal risks. The Group’s appetite for risk is set by the Board and is aligned to the strategic objectives of the Group.

The Group takes an enterprise-wide approach to managing risk. The risk management framework provides a controlled system for identifying, measuring, managing, monitoring and reporting risk across the Group.

Exposures are monitored and evaluated both within the business units and at Group level to assess the overall level of risk being taken and the mitigation approaches being used. We consider how different exposures and risk types interact, and whether these may result in correlations, concentrations or dependencies. The objective is to optimise risk-return decision-making while managing total exposure, and in doing so remain within the parameters set by the Board.

The risk management framework is underpinned by a system of internal control, which provides a proportionate and consistent system for designing, implementing, operating
and assessing how we manage our key risks. This framework is regularly reviewed and enhanced to reflect evolving practice on risk management and governance. More information on the Group’s approach to risk management can be found in the annual Report and Accounts.

1.5 Tax objectives and acceptable level of tax risk

The Group is subject to income taxes levied by the various jurisdictions in which we operate. The division of taxing rights between these jurisdictions determines the effective rate of income tax which applies to the Group.

We comply with legal requirements in the taxing jurisdictions in which we operate, in a manner that ensures we pay the right amount of tax while creating sustainable value for the benefit of the shareholders. This approach is underpinned by an open and transparent relationship with the tax authorities in these jurisdictions.

2. Governance of tax and tax risk

2.1 Policy oversight

The Group CFO has responsibility for tax at Board level. This includes communicating and advising the Board on the tax affairs and risks of the Group to ensure:

• the proper control and management of tax risk;
• the Group’s tax position is planned in line with the
  Group’s strategic objectives; and
• the Group’s tax charge is appropriately stated in
  the statutory accounts and tax returns.

2.2 Policy principles

The Board has established that the following principles will form the basis of the tax management philosophy and policy of the Group.

Overall approach to tax
Hiscox strives to act responsibly by being compliant with all relevant legislation, meeting all compliance and reporting obligations in the jurisdictions in which we operate.

Risk and internal control
Hiscox manages tax in line with the Group’s governance framework and procedures (see section 1.4 above for further details). The Group has put in place a network of internal controls designed to respond effectively to emerging and existing tax risks, and to manage risk effectively within the parameters set by the Board. Where such processes and controls are found to be ineffective, remediation steps are taken on a timely basis.

Change management
Hiscox ensures there is a strategy in place that enables the Group to manage tax risks arising from changes in legislation or the business operations.

Planning appetite
The Hiscox Group aims to be efficient in its tax affairs but tax mitigation is not a driver for activity. Tax planning opportunities arising from significant commercial transactions will be considered by the Board to ensure a beneficial post-tax result of any transaction.

2.3 Key controls

Hiscox has established key controls to manage the risk of incorrect tax accounting and reporting in keeping with the overall risk management framework. The fulfilment of these is documented, whether in tax returns, working papers or other internal documents.

This process and control documentation are subject to a program of ongoing improvement, including relevant changes to the underlying processes or when new risks are identified.

The key controls are monitored to ensure that:

• governance processes are such that the Board and Audit Committee have oversight of high risk and material transactions/processes; tax processes and controls operate effectively;
• remediation processes are put in place to address ineffective or inadequate controls.

2.4 Internal audit

The role of Hiscox Internal Audit function is to provide independent assurance that the Group’s risk management, governance and internal control processes, including the
above mentioned key controls, are operating effectively and in line with the Group’s strategic objectives. Internal Audit reports directly to the Group Audit Committee as a means of ensuring their independence and objectivity.

3. Roles and responsibilities

Hiscox ensures it has sufficient resource with the appropriate skills and experience to meet its filing and reporting obligations and manage tax risk appropriately. External advice is sought in respect of significant transactions and material risks or where the required expertise cannot be sourced in-house.

Ultimate responsibility for tax resides with the Board. The Board has delegated this responsibility to the Group CFO who reports to the Board as required. Process owners within the business are nonetheless responsible and accountable for meeting the tax obligations, controls and policies and reporting to the Board for their respective functions.

This segregation of responsibilities enables the Group to operate a three lines of defence model in respect of tax risk:

• individual risk owners – those individuals that manage the tax risk on a day-to-day basis;
• oversight of risk – the Group’s Risk Committee provides challenge and support to those individual risk owners;
• independent assurance – both internal and external audit ensure that tax risks are being managed in line with policy and process in place.

The finance function is the main process owner responsible for all taxes within the Group. With regards to tax, the finance function’s key objectives are:

• ensuring compliance with relevant laws and filing obligations across the Group in the jurisdictions in which we operate;
• ensuring that Hiscox’s reputation is not adversely impacted by the way it manages and monitors its tax risk within the Group;
• maintaining an open and co-operative relationship with tax authorities wherever possible;
• ensuring that taxes (and tax risks) are managed to provide sustainable outcomes, within the parameters of the Group’s strategic and commercial objectives;
• ensuring any tax planning opportunities arise from commercial and economic activity and are undertaken within the remit of the relevant applicable law.

4. Relationship with tax authorities

The Group maintains an open, transparent and co-operative relationship with tax authorities and seeks to work in collaboration with them in relation to its tax affairs:

• in the event of an error arising in a tax return, full and unprompted disclosure, where foreseen by law is made to the relevant tax authority;
• the Group discloses any relevant planning it undertakes to the relevant tax authority in line with the disclosure requirements and criteria set out by the relevant legislation; and
• the Group seeks active co-operation with tax authorities in respect of current, future and retrospective tax risks, events and interpretation of the law across all relevant
  taxes and duties, to facilitate relationships of trust.

5. Tax planning

Timely and accurate consideration of the tax consequences, both risks and opportunities, arising from business transactions is key to effective tax management. The Hiscox Group plans to be efficient with its tax affairs, but tax mitigation is not a driver for activity. 

Tax planning opportunities arising from significant commercial transactions will be considered by the Board.

Any tax planning to be considered by the Board must be supported by an appropriate level of tax analysis. The appropriate level of tax analysis will vary depending on the
level of associated tax risk and materiality to the Group.

In addition to the principles outlined in section 2.2 the following considerations are used to determine the appropriateness of tax planning risk:

• reputational impact;
• strength of tax advisors’ opinion;
• impact on cash flow;
• impact on financial accounts.

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 (PDF)

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

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 (PDF)

Hiscox is a leader in specialist insurance. We seek to provide the best protection and peace of mind for our clients through high-quality insurance products, backed with excellent service. We aspire for a reputation of integrity and quality.

It is our policy to provide, across all Group activities 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, wherever they are undertaken.

This health and safety policy sets out the standards we aim to achieve throughout Hiscox Group activities. We commit to organising these in compliance with relevant health and safety legislation and regulation and other requirements.

We recognise that ultimate responsibility for health and safety management and health and safety performance within Hiscox Group activities rests with the Executive Directors. Their management teams are responsible for organising activities with due regard for health and safety and in doing so, it will be their objective to meet and where possible exceed statutory requirements, especially with regards to those issues most relevant to our employees. Our management teams are committed to introducing and maintaining the necessary organisation and arrangements to achieve this objective.

The health and safety management system comprises a number of documents which explain more fully how Hiscox organises its activities to achieve a high standard of health and safety. Within this framework, we commit to:

• provide appropriate health and safety training, guidance and information to all Hiscox employees;
• develop and maintain fire risk assessment for each Hiscox premises;
• support the creation and maintenance of a building emergency plan for each Hiscox premises;
• organise the provision of and maintenance of safe and compliant furniture and computer equipment;
• monitor, measure, audit and report on health and safety performance, and set objectives and targets with the aim of achieving continual improvement;
• review and revise health and safety documents in light of legislative or organisational changes within Hiscox.

In addition to the health and safety arrangements put in place by Hiscox, all Group employees will have legal responsibilities to take reasonable care of their own health and safety at work and co-operate with Company arrangements. Documents comprising the health and safety management system are accessible on the Hiscox intranet, or as a hard copy on request.

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 (PDF)

Hiscox is committed to protecting the confidentiality, integrity and availability of the data it holds. We have an effective information security management system (ISMS), built on the fundamental pillars of people, processes and technology, as well as robust information security controls which are aligned to globally recognised industry standards.

Our Group-wide cyber security policy sets out the ISMS in operation at Hiscox. All information security policies apply across the Hiscox Group and are accessible to all staff, including any third-party workers with access to our network. These are reviewed and approved on an annual basis to ensure they remain accurate and appropriate.

Hiscox deploys various protective measures to protect its network and systems from threats and utilises third-party security expertise wherever we believe that doing so will enhance our existing security capabilities. Access to our network and systems is well controlled and closely monitored, ensuring the principle of least privilege is applied.

We take staff training seriously and conduct information security-related training and awareness activities throughout the year, including all-staff computer-based training at least twice per year (including any third-party workers with access to our network), regular staff phishing exercises and Group-wide communications on information security matters. In addition, Hiscox Board members and those in higher-risk roles are subject to more focused in-house security training.

We also expect all third parties who deal with Hiscox to operate in line with our data protection standards, and to treat our customer and employee personal data with the highest level of care. We operate a Group-wide privacy and information security third-party assurance framework, to ensure our requirements are being met, which covers both due diligence of third parties at the point of on-boarding and ongoing assurance. This is achieved through periodic reviews and/or audits of third-party processes and controls.

Information security-related audits are conducted by an independent internal audit team operating as the third line of defence within Hiscox’s ‘three lines of defence’ risk management model. The scope of these audits varies in nature and forms part of an annual risk-based audit plan. Audits are also periodically performed by external auditors.

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

Environmental policy (PDF)

Hiscox has a responsible approach to managing the environmental impact of our business activities and those that arise from our ownership and occupation of office premises. We are actively committed to the continuous improvement of our environmental programmes, with the aim to minimise our environmental impacts (due to the resources we consume and amount of waste our activities produce). 

We recognise that ultimate responsibility for our environmental impacts and performance within Hiscox Group activities rests with the Executive Directors. Their management teams are responsible for organising activities with due regard for our environmental impact and in doing so, it will be their objective to meet and, where possible, exceed statutory requirements. Our management teams are committed to introducing and maintaining the necessary organisation and arrangements to achieve this objective. 

Hiscox Group will achieve our aims by:

1. offsetting our unavoidable greenhouse gas emissions through carbon offset projects that have been verified against international standards; 

2. investing in research to better understand the risks associated with climate change and changing weather patterns, and incorporating the results into our insurance products and services; 

3. minimising our climate change impacts by purchasing, where possible and appropriate, energy from renewable sources and sourcing, wherever possible, consumables from sustainable sources; 

4. routinely measuring and recording the amount of energy, water and office consumables used in Hiscox office premises, and setting objectives and targets with the aim to reduce consumption; 

5. operating waste management systems that implement the waste hierarchy (improving resource efficiency first in order to prevent/reduce waste) and promote the recovery and/or recycling of as much waste as possible; 

6. minimising the impact of our business-related travel (domestic and international), wherever practicable; 

7. favouring, where appropriate, the purchase and use of energy-efficient office equipment and communications systems; 

8. encouraging awareness of local and global environmental issues within our business, and individual responsibility amongst our employees, and supporting them in completing appropriate environmental initiatives within their communities; 

9. involving others in the development of our environmental strategy, for example, we expect our asset managers to invest in companies that have sound environmental, social and governance practices; 

10. monitoring, measuring, auditing and reporting on our environmental performance, including setting targets and objectives to drive continual improvement over time and demonstrate good performance on these issues; 

11. providing adequate and appropriate resources to implement this policy and ensuring that all stakeholders are aware of it, as well as their role in achieving the commitments. 

We review this policy on a regular basis to ensure it continues to be relevant and adheres to legal and regulatory obligations.

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

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 (PDF)

At Hiscox, we endeavor to give people and businesses the confidence to realise their ambitions. Our core values that underpin everything we do help us achieve this purpose by connecting us to the business, our customers, our suppliers and each other in an ethical, socially responsible way.

We want to work with like-minded businesses who align with our values and support our goals. This Code of Conduct sets out the behaviours and standards we expect from a) all suppliers providing goods and services to or on behalf of Hiscox and b) any third parties subcontracted by our suppliers. Any supplier that has any commercial dealings with Hiscox, including brokers, coverholders, third-party administrators, outsourced service providers and specialists, and any of their subcontractors must state compliance with this Code of Conduct.

1. Integrity

Integrity is one of Hiscox’s core values. Fundamental to this is honest and fair dealing in all activities throughout the Hiscox Group and our supply chains. Our suppliers must adhere rigorously to applicable legislation and regulations, both in letter and in spirit, in all jurisdictions in which they operate. In particular, we expect them:

• to maintain an anti-bribery and corruption policy and abide by all relevant legislation;
• not to commit any form of fraud, money laundering, tax evasion, market abuse, sanctions violations or terrorist financing; and
• to comply with applicable antitrust and competition laws.

2. Diversity and Inclusiveness

Our sourcing decisions, contracts and management of supplier relationships will reflect and promote the principles of the Hiscox Group DEI Policy (incorporating equal opportunities) in that they will seek to ensure that; Suppliers do not victimize, harass or discriminate against any employee or party to the contract due to 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. Suppliers will be required to:

• meet the requirements of any applicable discrimination legislation
• have a policy regarding providing a work environment that is free of unlawful harassment and discrimination based on any legally protected characteristic.

It is Hiscox’s commitment that diverse business enterprises shall have equal opportunity to compete for all goods and services to become preferred suppliers and/or subcontractor(s) for the organization. Our suppliers will be treated fairly and equally during the tendering and purchasing process, with decisions made on the basis of clear selection criteria.

Hiscox is committed to the development and growth of diverse business enterprises to build a better working world and to expand networks to build trusted and enriched relationships.

3. Conflicts of Interest

Maintaining a culture of transparency and accountability, Hiscox is committed to identifying, assessing and effectively managing the risks relating to conflicts of interest insofar as they relate to the Group. Suppliers must not directly or indirectly offer improper payments or inducements to Hiscox members of staff that may prejudice their ability to act in the best interests of Hiscox or detract from the impartiality that Hiscox demonstrates in its supplier engagements and decision-making process. All actual, potential or perceived conflicts of interest, such as family relation or business relationship, must be disclosed in a transparent manner to our Procurement team. Suppliers should also:

• identify and maintain records of any material conflicts within their business;
• ensure that appropriate controls are in place which are proportionate to the level of risk posed by the particular business they carry out;
• provide their staff with adequate training in identifying conflicts of interest and understanding relevant procedures as well as their individual obligations; and
• ensure that boards and committees are provided with appropriate information to enable them to oversee the management of conflicts of interest.

4. Human Rights and Labour Practices

Hiscox is committed to upholding the human rights of workers and advocating fair employment practices. We expect that all suppliers support the protection of human rights and are not complicit in violations or abuses of such. They shall:

• act pursuant to all applicable anti-slavery and human trafficking laws and regulations, taking a zero-tolerance approach to slavery, forced labour, human trafficking and child labour in any part of their business or supply chains;
• comply with all applicable wage and working regulations;
• respect the rights of workers to freedom of association and collective bargaining in line with local regulations;
• seek to increase procurement with diverse suppliers and diversity of their governing boards.

5. Health and Safety

It is our policy to provide a work environment that ensures the health, safety and welfare of all our workers as well as those affected by our operations. We consider it a moral duty for all employers to do so and therefore expect our suppliers to fulfil this by complying with applicable health and safety legislation and regulations. They shall also have in place business management practices that cover the following elements:

• providing all workers with adequate health and safety training and information;
• carrying out regular risk assessments and maintaining emergency evacuation procedures;
• monitoring and reporting on health and safety performance; and
• enabling workers to meet their responsibilities for maintaining a safe and healthy workplace.

6. Environment

Hiscox has a responsible approach to managing the environmental impact of our business activities and actively seeks to minimise it. In line with our environmental policy, we expect our suppliers to ensure business practices meet all applicable environmental laws and regulations and encourage them to have policies for effective environmental management in support of the following efforts:

• purchasing energy from renewable sources where possible;
• operating effective waste management systems; and
• monitoring and reporting on environmental performance.

7. Risk Management

Suppliers are expected to have robust risk management and assurance processes in place that are proportionate to the size of the organisation and the goods or services provided, covering key risk areas including, but not limited to, information and cyber security, privacy, business continuity, supplier governance, financial crime, and regulatory compliance. This ensures that we work with operationally resilient businesses and thereby safeguards the relationships between us and our suppliers.

8. Compliance

Our suppliers must have management and governance processes in place to maintain the standards set out in this Code of Conduct and be able to demonstrate compliance if required. They must also make reasonable efforts to monitor their supply chains, ensuring their suppliers aspire to the same standards. In line with our procurement procedures, suppliers may be required to acknowledge their adherence to the Code of Conduct in writing. Supplier commitment to this Code of Conduct forms an integral part of our sourcing process and is taken into account when selecting new suppliers or renewing existing contractual relationships.

9. Reporting channels and grievance procedure

If, in dealings with Hiscox, suppliers become aware of any actual or suspected violation of this Code of Conduct or breach of any applicable law that affects us, they should bring it to our attention through appropriate reporting channels. We have a fair and equitable grievance process in place which we take extremely seriously and through which action can be taken where necessary.

Suppliers are encouraged to raise a concern with their Procurement contact at Hiscox in the first instance, who are duty-bound to pass on the information to senior management.

If a supplier feels that this is not an appropriate route, they may bring the matter of concern in confidence to the Head of Group Internal Audit by phone or email (Roshni Patel: [email protected]; +44 (0)20 3321 5644). All Hiscox suppliers worldwide can access free, confidential advice on how best to raise a whistleblowing concern from Protect (www.protect-advice.org.uk; +44 (0)20 3117 2520), an independent charity. It should be noted, however, that this is not an actual means of disclosing a concern.

(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 (PDF)

(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, when we intend to:

• no longer provide new insurance cover to thermal coal-fired power plants, thermal coal mines, Arctic1 energy exploration activities, oil sands or controversial weapons;
• no longer reinsure portfolios where 30% of the premium base derives from thermal coal-fired power plants or thermal coal mines, Arctic1 energy exploration activities, oil sands or controversial weapons;
• not directly invest into securities of companies that generate more than 30% of revenues from thermal coal extraction or power generation, Arctic1 energy exploration activities, oil sands or controversial weapons.

Ultimately our ambition is to phase out (re)insurance of thermal coal-fired power plants and thermal coal mines, Arctic1 energy exploration activities and oil sands by 2030, in line with the 2015 Paris Agreement and UN Sustainable Development Goals.

This policy has been designed to contribute to the insurance industry’s role in supporting the transitioning economy, and aligns to the Lloyd’s ESG ambitions published in December 2020. It supports our wider ESG activity, including our annual cycle of carbon reporting and offsetting, and our emissions reduction programme. For more information, visit www.hiscoxgroup.com/responsibility.

1 Arctic National Wildlife Refuge (ANWR) region.

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 (PDF)

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.

We believe ESG factors can have an impact on risk and returns across asset classes, sectors, geographical regions and companies, and should be integrated into our investment process.

The policy sets out the high-level responsible investment principles implemented within Hiscox’s investment portfolio by our in-house investment team, under the supervision of the Hiscox Investment Group. It also guides our appointed external asset managers and informs other company stakeholders. Day-to-day management of our assets is outsourced to selected asset management firms, with our in-house investment team retaining responsibility for management and oversight of external asset managers, including their approach to ESG issues.

We expect our appointed asset managers to integrate ESG considerations in their investment processes and stewardship activities and, ultimately, to invest in companies that have sound ESG practices. Organisations that understand and successfully manage material ESG factors and associated risks and opportunities tend to create more resilient, higher-quality businesses and assets, and are therefore better positioned to deliver sustainable value over the long term.

In-depth evaluation of external managers’ ESG integration forms a fundamental element of our manager selection and monitoring processes, including:

• adherence to internationally recognised ESG standards such as the Principles for Responsible Investment (PRI), and annual confirmation of continued adherence;
• ESG policies, procedures and resources to integrate ESG issues into decision-making;
• supporting Hiscox with the provision of TCFD-compliant portfolio data;
• engagement on ESG issues with portfolio companies on our behalf;
• ESG disclosure and reporting on ESG issues and engagement.

Where Hiscox has direct control over portfolios investments, exclusions are applied as laid out in our ESG exclusions policy. Where Hiscox invests indirectly via pooled funds and has no direct control over portfolios, desired exclusions are shared with the investment manager and applied if possible.

We also ask our managers to respect human rights, including the avoidance of investments that would contravene the human rights, labour, environment and anti-corruption principles of the United Nations Global Compact.

In addition, we consider allocating capital to impact and sustainable investments, providing they integrate within the overall portfolio risk/return objectives and liquidity guidelines, while incorporating sufficiently high standards of impact definition, measurement and reporting.