Our Corporate Responsibility Policy

Executive Summary

1. Policy objective

   1. To provide guidance and direction to all staff on managing risks and opportunities relating to the conduct of corporate social responsibility by the Aviva group.

2. Key features and improvements

   1. Conveys senior management's attitude towards integrity, high ethical values and the conduct of CR by the Aviva group.
   2. Replaces five existing policies: CR, Standards of Business Conduct, Human Rights, Sponsorship and Community Investment and Diversity.

3. Key risks

   1. CR awareness - staff are not sufficiently informed / aware of the group's CR standards and vision.
   2. External profile of CR - failure to promote the group's CR initiatives (eg via annual report and accounts, website) resulting in missed investment opportunities by potential investors.
   3. Human rights / diversity - the group is not able to create a working culture that respects, celebrates and harnesses differences.
   4. Business unit embedding - the group fails to embed CR in the business.
   5. Community investment - reputational risk if the group is not seen to be supporting communities in which it operates.

4. Control standards

   1. Adherence to the code of conduct.
   2. Appointment of CR regional contacts and nominated managers in each business.
   3. Businesses apply CR standards eg fair business practice, community investment.
   4. Businesses undertake risk assessment to identify areas susceptible to social responsibility risk.
   5. Businesses comply with group compliance for policy compliance reporting requirements.
   6. Regions disclose material areas of non compliance.
   7. Businesses maintain CR management system and report progress through CR key performance indicators annually to group CR.

Policy owner:
Louella Eastman
Group Corporate Responsibility Director

Download our Group CR policy PDF (181 Kb)

Executive Summary

1. Policy objective

   1. To limit the impact that businesses have on the environment and to manage environment risk as effectively as possible. The policy sets out how Aviva will engage to meet the various environmental challenges and opportunities in line with its commitment to good environmental practice and innovation.

2. Key features and improvements

   1. New format incorporates greater detail on risk appetite.
   2. Designed to limit the impact that Aviva's businesses have on the environment and to meet the various environmental challenges and opportunities.

3. Key risks

   1. The group's inability to uphold its commitment to reduce its carbon dioxide emissions which may have financial implications for the group's carbon neutral commitment.
   2. Failure to regularly update pricing and capital allocation in respect of the prevailing climate risk.
   3. Non compliance with local environmental legislation / regulation by any part of the group.

4. Control standards

   1. Integration of environmental considerations and opportunities into business decision making and purchasing/supplier management.
   2. Local businesses set targets and monitor performance on significant aspects of climate change and waste management.
   3. Group CR annually review the group's performance worldwide to ensure Aviva is meeting its environmental objectives and targets and will publish reports annually.
   4. CR committee review programme progress, and also authorise changes to list of approved carbon brokers and set criteria for selection of carbon neutral projects.
   5. Completion of actual / planned carbon offsetting investment / activity and comparison with expectations is monitored on a regular basis.
   6. Review and analysis of business environmental / regulatory control breaches and monitoring of remedial action taken to resolve any legislative / regulatory issues.

Policy owner:
Louella Eastman
Group corporate responsibility director

Download our Group Environment policy PDF (154Kb)

Executive summary

1. Policy objective

   1. Aviva's HR purpose is to excite its people to exceptional performance. The objective of the people policy is to provide the processes, systems and minimum standards for managing people related risk within the Aviva group to help achieve that purpose.

2. Key features and improvements

   1. Aviva aims to attract and retain the best talent available as the foundation for becoming a truly customer and employee centric organisation.
   2. The people policy positions the group's HR framework and is designed to support talent acquisition (recruitment), talent engagement and commitment, reward (reward policy) and talent retention (talent development) leading to the achievement of business objectives.

3. Key risks, The policy supports management of the following inherent risks:

   1. Employing the right people - recruitment, selection and retention processes do not select and retain people competent to execute required roles and deliver Aviva's business plan.
   2. Demonstrating the right skills and behaviours - performance management, reward systems, training and development do not develop behaviour in line with Aviva values and a culture of strong individual and team performance.
   3. People deployment - best use is not made of the available talent and the right people are not matched to the right roles.
   4. Engagement and commitment - leadership and organisational culture do not gain adequate engagement and commitment from all staff.
   5. Demonstrating HR compliance - HR related legal and regulatory rules and guidelines are not followed and requirements of other stakeholders are not met.
   6. HR functional capability - the HR function does not have a clearly articulated business related people strategy and the required levels of technical, professional and change management competence to carry out its strategy and perform its role effectively for the organisation.

Policy owner:
John Ainley
Group HR director

Executive summary

1. Policy objective

   1. Put customers at the heart of how we run our business and ensure that we treat our customers fairly.

2. Key features and improvements

   1. Recognises the competitive advantage that comes from putting customers at the heart of the business.
   2. Supports the Financial Services Authority (FSA) principle that we treat our customers fairly.
   3. Customer advocacy /net promoter score are key measures across the group.
   4. Framework to discuss plans and share experiences between different businesses.
   5. Incorporates greater detail on risk appetite and controls.

3. Key risks

   1. Strategy and values - fair treatment of customers is not central to our corporate culture and values.
   2. Product design - products and services that we design, market or sell are not appropriate to meet the needs of targeted customer groups; CR considerations are not taken into account; and products do not perform as customers have been led to expect.
   3. Promotion, sales and marketing - consumers are not provided with clear, fair and balanced information or are not kept appropriately informed, incentives lead to products being targeted to customers for whom they are unlikely to be suitable, we have not agreed with our distributors our respective responsibilities and how these will be monitored.
   4. After sales support - customers are not kept appropriately informed of factors that may materially affect the benefits that they have been led to expect. Customers face unreasonable post-sale barriers and service is of an unacceptable standard. Complaints are not properly investigated or handled fairly.
   5. People - people are not trained to understand their responsibilities to customers and rewards fail to encourage people to treat customers fairly and to win customer advocacy.

4. Control standards

   1. Senior management ensure that customers are at the heart of what we do through regular reviews and monitoring of performance in serving customers, treating them fairly and improving customer advocacy.
   2. Develop products and services which meet the needs of our targeted customers.
   3. Provide customers with clear information and good service when they buy our products.
   4. Maintain appropriate and effective relationships with our customers and provide them with good service after they have bought a product.
   5. All staff understand the priority to place customers at the core of how we do business and this is reinforced through communication, training and performance appraisals.

Policy owner:
Sally Shire
Group brand development director

Executive Summary

1. Policy objective

   1. To provide direction to all staff on the effective management of financial crime for the Aviva group.

2. Key features and improvements

   1. Aviva is committed to minimising financial crime (encompassing money laundering, fraud, malpractice and market abuse). Promoting zero-tolerance to financial crime.
   2. Combines two existing group policies - Fraud Management and Malpractice; Anti-Money Laundering.
   3. Appropriate action is taken to prevent and respond to potential money laundering and financing of terrorism activity.
   4. A positive compliance culture is maintained under which financial crime risks are proactively identified and managed by businesses.
   5. Senior management take appropriate action to prevent and respond to illegal or fraudulent activity, insider dealing and market manipulation.
   6. All employees have a safe and anonymous mechanism through which to communicate suspected breaches of policy and unethical behaviour.

3. Key risks

   1. Money laundering - organisation is a conduit for the proceeds of crime or facilitates the funding of terrorist acts.
   2. Internal / external financial crime - acts of fraud, malpractice, corruption and illegal activities from both internal and external sources.
   3. Market abuse - stakeholders disadvantaged by distortion of price setting mechanism of financial instruments or by dissemination of false or misleading information.

4. Control standards

   1. Documented procedures in each business on anti-money laundering and fraud management.
   2. Risk based business compliance plan and proactive preventative financial crime reviews at business level.
   3. Clear lines of accountability, responsibility and reporting eg each business must appoint a money laundering reporting officer.
   4. Regular review and analysis of financial crime incidents and breaches with monitoring of response plan and remedial action.
   5. All relevant staff trained in 'know your customer', identifying money laundering, suspicious activity and financial crime.

Group policy owner:
Brendan Hawthorne
Director of group financial crime

Download our Group Financial Crime policy PDF (135Kb)

1. Policy Statement

   1. The Group is committed to providing a working environment which is both safe and fit for the intended business purpose. In doing so it will ensure that it complies with health and safety legislation and that health and safety issues are a matter of priority for all business operations.

2. Purpose

   1. The purpose of this policy is to set out clearly the Group's approach to achieving its health and safety objectives, the responsibilities of Group functions and business units and the parameters within which local health and safety policies should be set.

3. Scope

   1. This policy applies to the Group's business operations worldwide.

4. Underlying Philosophy

   1. The Group is committed to providing a consistently safe and effective working environment for all staff, including contractors, customers and members of the public. In doing so it will, as a minimum, comply with local health and safety legislation, but will exceed those requirements should it be necessary to do so in order to deliver the corporate objectives stated below.

5. Corporate Objectives

   1. To ensure that throughout its business operations worldwide the Group provides working conditions for its staff, customers and members of the public which are consistently safe and fit for the intended business purpose.
   2. To meet, as a minimum, local health and safety legislation, or exceed it as required in order to achieve the Group's health and safety corporate objectives.
   3. To ensure that the reputation of the Group is not damaged by failures in health and Safety practice and that the management of health and safety Groupwide contributes to effective corporate governance.

6. Corporate Principles and Practice

   1. The Group is committed to establishing and maintaining an effective health and safety regime throughout its business operations worldwide.
   2. All business units will establish appropriate responsibilities, organisations and processes to enable compliance with this policy.

7. Responsibilities

   1. Overall Group health and safety is the responsibility of the chief executive supported by the group executive directors who are responsible for health and safety within their business operations.
   2. For individual business units, health and safety is the responsibility of the business unit head who will establish an appropriate and effective organisation to achieve the corporate objectives.
   3. The group business protection director is responsible for the Group health and safety policy and for such overall monitoring of health and safety as is required to support the Chief Executive in discharging his responsibilities.
   4. Business unit heads will ensure that the group business protection director is made aware of significant local health and safety issues at an appropriate level of materiality.

Policy owner:
Paul Wood
Group business protection director

Note:

Group business protection has recently assumed responsibility for health and safety and is currently working on a separate statement on this topic. In the mean time, this existing health and safety policy remains in force.

Executive Summary

1. Policy objective

   1. To set out guiding principles on effective mitigation of risks associated with the purchasing and supply management (P&SM) process and define the standards of governance and practice that all Aviva staff engaged in purchasing and supply management activities must adhere to.

2. Key features and improvements

   1. Optimises and sustains commercial advantage of managing purchasing and supply management (knowledge, competency, scale).
   2. Increased focus on risk appetite and measurement of risk and compliance.
   3. Addresses key business objectives around corporate social responsibility in the supply chain.
   4. Adoption and use of standard good practice processes for all purchasing and supply activity.
   5. Ensuring global application rather than being UK centric.

3. Key risks

   1. The inability of the business to fully define objectives, risks and service requirements.
   2. Value opportunities in Aviva's sourcing and supply management activities are not identified, sanctioned and sustained.
   3. Requirements agreed at the time of contract set up are not delivered.
   4. Nature of contract and responsibilities of Aviva staff vs. supplier not clear.
   5. Aviva's inability to respond to internal / external changes.
   6. Contingency planning not in place or robust enough.
   7. Limited / challenging market places or instability in vendor locations making it difficult to achieve full value benefits.
   8. Exposure of Aviva to unmanaged single supplier actions across multiple businesses, resulting in loss of market leverage, increased risk of business exposure or supplier exploitation.
   9. An appropriate exit strategy is not defined and reviewed.

4. Control standards

   1. At the start of a new purchase terms of reference and statement of requirements document outlining the overall business context and requirements statements is developed and signed off.
   2. Purchasing and supply management or recognised locally established purchasing function is engaged by businesses early in the purchasing process.
   3. Practices detailed in the supplier relationship management framework are followed by all businesses.
   4. The engagement of the group legal team early in the sourcing process to ensure that contracts entered into by or on behalf of any group company adequately protect the rights of that company.

Policy owner:
Nick Watson
Director of procurement

Download our Group Purchasing and Supply Management policy PDF (160Kb)