In addition to obeying the rule of law, our business ethics principles are based on a commitment to fair, transparent and honest business practices.

Our aim is to align our processes to the Financial Services Authority (FSA) Treating Customers Fairly initiative. The FSA intends Treating Customers Fairly to achieve six outcomes:

• Consumers can be confident they are dealing with firms where the fair treatment of customers is central to the corporate culture.
• Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.
• Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
• Where consumers receive advice, the advice is suitable and takes account of their circumstances.
• Consumers are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and as they have been led to expect.
• Consumers do not face unreasonable barriers after a sale imposed by firms to change product, switch provider, submit a claim or make a complaint.

Aligning our processes to Treating Customers Fairly, is reflected, for instance, in Norwich Union initiatives that have:

• sought to identify and return £40 million worth of unclaimed assets to 40,000 policy holders
• traced 6,000 fishermen with unclaimed pension schemes through the ‘Find the Fishermen’ campaign
• helped to educate consumers about the importance of full medical disclosure on applications for protection products, leading to an 11% improvement in claims paid since 2005.

Respect for customer confidentiality

We respect the confidentiality of the information entrusted to us and have anti-fraud procedures in place.

Although these procedures help us to maintain the confidentiality of the information entrusted to us, the FSA fined Norwich Union Life £1.26 million in 2007 for 74 policies being fraudulently surrendered the previous year. Obviously, we regard any such breach of customers’ confidentiality as completely unacceptable and cooperated fully with the FSA’s investigations. The number of cases was a very small proportion of the 7 million policies we hold and no customers suffered financially, but given the serious nature of the matter, we have since improved our fraud prevention processes and continue to monitor these controls.