Customer, Conduct and Reputation committee


Assisting the Board in its oversight of culture, conduct and reputation issues.

The main purpose of the Committee is to assist the Board in overseeing our customer and conduct obligations, the development of our reputation, our regulatory engagement on conduct matters, shaping the culture and ethical values of the Group and our approach to corporate responsibility.

The committee comprises independent Non-Executive Directors.


Jim McConville (Chair) (appointed 01 December 2020)
Belén Romana García (appointed 26 June 2015)
Michael Mire (appointed 12 September 2013)
Pippa Lambert (appointed 1 January 2021)

The following officers normally attend, by invitation, all meetings of the committee:

  • Group Chair
  • Group CEO

Other members of senior management attended meetings by invitation, where appropriate, or to present reports.

Role and responsibilities

The key responsibilities of the committee are to:

  • review and provide oversight of the Group’s conduct frameworks, conduct governance and reporting of conducts risks;
  • review and provide oversight of material operational risks related to customer and conduct, including regulatory conduct risk, reputational risk and customer data risk arising from the Operational Risk & Control Management Framework (ORCM) and within the overall operational risk appetite set by the Risk Committee;
  • review and provide oversight of the implementation of the Group’s customer strategy;
  • monitor regulatory requirements in relation to customers and conduct;
  • oversee the Group’s brand and reputation and assess the Group’s brand and reputational risks and profile;
  • review the design and effectiveness of Group policies for the use of customer data;
  • oversee the Group’s corporate and societal obligations, including setting the guidance, direction and policies for the Group’s corporate responsibility (CR) agenda and related activities; and
  • monitor the Group’s culture and purpose and the development of associated culture metrics.

Read the full terms of reference for our Customer, Conduct and Reputation Committee (PDF 43 KB).

2020 activities

A summary of the committee’s activities during 2020 is shown below, full details can be found in the committee’s report in the 2020 Annual Report and Accounts.

  • Focused on the customer agenda and received regular updates and monitored progress on customer metrics relating to customer complaints and the conduct agenda, sales, retention and claims experience

  • Continued to drive the corporate responsibility agenda and monitored compliance with the Group’s corporate responsibility strategy

  • Reviewed the ‘Better Tomorrow’ corporate responsibility strategy for 2020-2025

  • Reviewed the Group’s Modern Slavery statement, annual corporate responsibility reporting and the Group’s Financial Crime, Regulatory Business and Corporate Responsibility, Environment and Climate Change Business Standards

  •  Reviewed and where appropriate approved changes to the composition of the material subsidiary board
  • Regularly reviewed updates from the Group Compliance and Operational Risk Director

  • Reviewed the Group’s relationship and interaction with regulatory bodies and actions taken in respect of regulatory developments
  • Reviewed potential financial crime risks and any actions required in response

  • Reviewed the implementation of the data governance and data privacy framework