How we run our business by practising good governance.
We want to make our industry work better for everyone. That’s why we work hard to practice good governance across the business.
We have chosen to accept the risks inherent in our four core business lines and our risk committee oversees all aspects of risk management in the Group.
We are committed to supporting the human rights and anti-modern slavery agenda both within the organisation through our operations, and outside of it through partnerships and collaboration.
Our human rights policy identifies our main stakeholders and the most salient human rights issues for our business. The scope of this policy is group-wide and sets out the Group’s commitment to respect human rights.
Within our own operations, in 2019 we:
- Completed human rights due diligence in a number of key markets, reviewing their risk approach in areas including governance, employees, customers and investments. To date, 15 markets have completed an impact assessment including the UK, China, Turkey, Vietnam, Italy and India. The assessments allow markets to prioritise the most important actions to enhance Aviva’s work on human rights.
- Engaged key suppliers on the topic of human rights and conducted modern slavery threat assessments on a range of those suppliers who, based on their sector, are at a higher risk of being exposed to modern slavery. Since 2018 we have completed 18 assessments, with no cases of modern slavery being discovered at Aviva or in our supply chain. The assessments provide suppliers with the opportunity to spot any potential risks or control gaps which we then work with them to address. In 2019 we have conducted modern slavery training for key employees in five markets.
We also work with trusted partners to enhance our approach. This includes the Slave Free Alliance, whose insights we use to both improve our strategic approach to modern slavery, and to train our staff across different markets on human rights and modern slavery issues. These workshops have ensured our people understand the complexities of modern slavery and human trafficking, help them to spot the signs of it, and teach them how to respond in the event that a case is identified. We also continue our work with the UN Global Compact as part of the UK Working Group on modern slavery.
Finally, we use our influence and connections to bring others together and enhance the industry’s wider understanding of, and impact on human rights. For example, we worked with the World Benchmarking Alliance (WBA) in 2019 to organise and host the official launch of the third Corporate Human Rights Benchmark (CHRB) 2019 rankings, in our role as funder and founding member.
As a business that’s been around for over 320 years we have learnt to listen hard to our stakeholders, working with them to tackle the big challenges and identify risks and opportunities.
We work hard to make sure our supply chain is responsible and sustainable. We do thorough checks of suppliers before we begin working with them, and ask that they sign our Supplier Code of Behaviour.
We continue to engage them around sustainability issues over time. We also help influence our suppliers to act now around the big issues like climate change.
Our Business Ethics Code outlines our high ethical standards and ensures we operate responsibly and transparently. We require all our people, at every level, to read and sign-up to our code every year (99% of our employees did so in 2019).
The Financial Crime Business Standard, and supporting Minimum Compliance Standards, guide our risk-based financial crime programmes. These seek to prevent, detect and report financial crime, including any instances of bribery and corruption, while complying fully with relevant legislation and regulation. We use risk-based training to ensure employees and others acting on Aviva’s behalf know what is expected of them and how they should manage bribery and corruption risks.
At a Group level, the Chief Risk Officer provides Aviva’s Board Governance Committee1 with regular reporting on financial crime matters. These include Aviva’s anti-bribery and anti-corruption programme.
Our malpractice helpline, Speak Up, makes it easy to report any concerns in confidence, with all reports referred to an independent investigation team. In 2019, 89 cases were reported through Speak Up (2018: 50), with four related to bribery and corruption concerns. 59 cases reached conclusion, and 30 remain under investigation. There has been no material litigation arising from any case reported in 2019.
Our Board-level Customer, Conduct and Reputation Committee oversees our responsible and sustainable business strategy and the policies that underpin it.
As a company we are subject to the UK Corporate Governance Code (the Code), which we aim to comply with fully.