Admiral Group is committed to engaging in ethical and transparent business conduct across its operations. The Group makes available to all colleagues its policies and procedures to be followed as a condition of their employment and to ensure we maintain our reputation as a trusted brand, and act in accordance with the highest legal and professional standards.
All Admiral Group colleagues are expected to abide by these policies and act with integrity, due skill, care and diligence in accordance with these policies and processes. Regular compliance training is offered to all employees to ensure topics outlined are appropriately covered and any breaches are appropriately managed. In addition, Admiral Group expects its suppliers and any other business partners to comply with these principles throughout their own operations too.
Our Code of Conduct also includes our policies on the following:
- Anti-Bribery and Corruption
- Data Protection
- Information Security
- Anti-Discrimination and Harassment
- Board Diversity & Inclusion Policy
- Environment, health and safety
- Conflicts of interest
- Antitrust/anti-competitive practices
- Money laundering and/or insider trading
Admiral Group has an established Financial Crime policy which ensures that robust systems and controls are in place to detect, prevent and deter financial crime across the Group and that we remain compliant with applicable laws and regulations in our operational jurisdictions, in accordance with the Group’s purpose to ‘help more people look after their future’ and ‘always striving for better together’. All areas of financial crime are captured by this policy, including money laundering, market abuse and insider trading, sanctions regime, modern slavery, tax evasion and Bribery and Corruption.
Admiral Group operates a zero-tolerance approach to bribery and corruption, and expects its employees, suppliers, contractors and any other business partner associated with the Group to have the same view.
The Group’s Anti-Bribery Policy works in tandem with our Financial Crime Policy and sets out clear guidelines under which the solicitation or acceptance of any bribe, to or from any person or company, by an individual employee, Board member, agent or other person or body on Admiral’s behalf, in order to gain any commercial, contractual, or regulatory advantage for Admiral in an unethical way or to gain any personal advantage for the individual or anyone connected with the individual is strictly prohibited.
Each respective Group entity is expected to implement financial controls which ensure appropriate measures are in place to comply with regulation and mitigate any risks of corruption and bribery. Third party due diligence must be performed in advance of entering a business relationship and on an ongoing basis in proportion to the level of risk posed by the third party.
Our Anti-Bribery policy is made available to all employees, all of whom are required to undergo training as part of their induction and on a periodic basis relevant to the risks faced in their particular role. Any actual or suspected breach of this policy will be thoroughly investigated by the Group.
Admiral Group’s Whistleblowing Policy encourages and enables employees to raise any concerns they have about serious malpractice or wrongdoing. It applies to all entities within the Group and is designed to ensure that an employee can raise their concerns about serious wrongdoing or malpractice within the Group without fear of victimisation, subsequent discrimination, disadvantage or dismissal.
Any employee, whether full-time, part-time, employed through an agency or other, as well as contractors working within the organisation, can use this policy to raise their concerns. All whistleblowing notifications are investigated promptly, and each individual entity is required to maintain a record of all reportable concerns, how these have been treated, as well as the outcomes. Whistleblowing notifications reported through Admiral Group’s subsidiaries are reported to the parent company, Admiral Group, via regular compliance reporting.
Any whistleblowing notifications can be raised by employees internally via our appointed whistleblowing champion or externally, directly to the regulatory bodies such as the FCA (email@example.com) and the PRA (PRAwhistleblowing@bankofengland.co.uk)
Admiral Group is committed to the correct, lawful and transparent handling of the personal data that it processes, in line with the General Data Protection Regulation (GDPR). Our approach to data protection is communicated to all staff through our Group Data Protection Policy which outlines the Group’s obligations regarding the processing of personal data. Continued compliance of this policy is monitored through regular reviews and audit activities carried out by the Data Protection and Privacy Team and the Internal Audit function.
We provide annual GDPR training to all employees, including contractors to ensure that all employees that process personal data are aware of their obligations surrounding data.
Admiral Group’s Data Protection Policy applies to all Admiral Group users that have access to personal data and data processing systems, and applies equally to management, permanent and temporary staff, contractors, partners, and suppliers. We have a publicly facing privacy notice which data subjects are presented with, to read and agree to prior to Admiral Group processing any personal data. Within that privacy notice, we explain instances where personal data may be shared with select third parties. Due diligence is also conducted on suppliers before we engage in a relationship with them, which includes specific data protection due diligence. We consistently strive to ensure third-party contracts are robust and inclusive of data protection clauses
Admiral continuously works to protect customer, staff and business data while fulfilling all contractual, regulatory and legal obligations.
Admiral’s Group information security aligns its practices to internationally recognised information security and cyber risk management frameworks. Information security risk is managed in line with the Group Enterprise Risk Management Policy. Additional Information security policies are in place to ensure that all employees understand their responsibilities when it comes to information security and we provide all employees and contractors with regular information security training. Information security risk assessments are carried out regularly by the Information Security Teams across the Group and the results are monitored, managed and reported via the appropriate governance fora, based upon the materiality of the risk.
Admiral Group does not tolerate any kind of discrimination, bullying or harassment. Our Equality, Diversity and Dignity at Work Policy is in place for employees across the Group and outlines the standards of behaviour that are expected to ensure that everyone at Admiral is treated with dignity and respect.
All employees are expected to comply with the policy and defined escalation processes are provided to staff as part of their induction training. Any person found to have discriminated against or harassed another for any reason will face appropriate disciplinary action, up to and including dismissal from employment. Managers have a responsibility to fully understand the policy, be alert to any potential risks of harassment, communicate this policy to staff and be responsive and supportive to anyone who makes a complaint.
In addition to our Equality, Diversity and Dignity at Work Policy, Admiral Group also has in place a Sexual Harassment policy which outlines our commitment to providing employees with a safe environment free from discrimination on any grounds, including sexual harassment.
The Group supports the principle of boardroom diversity and inclusion and the promotion of a diverse board composition. Board diversity is important to maintain the ability of the board, to provide effective challenge across the full range of the Group’s business and to maintain the capacity to explore key business issues rigorously.
This directly supports the Admiral Group purpose as diversity in key decision making forums is necessary to embrace a broader perspective and understand the needs of 'more people' as we strive to help them ‘look after their future’.
The Group recognises the importance of diversity of thought, experience and approach and each new Board appointment should be complementary to the existing Board’s skills and experience. Board appointments will always be made on merit against objective criteria, including diversity.
In respect of gender diversity, the Group Board will aim to maintain a minimum of 40% of its members as women and will aspire to achieve this ratio, in aggregate, in subsidiary boards by the end of 2024.
The Group Board will also aim to maintain the following situation:
- At least one of the senior board positions (Chair, Chief Executive Officer (CEO), Senior Independent Director (SID) or Chief Financial Officer (CFO)) is a woman
- At least one member of the board is from an ethnic minority background (as referenced in categories recommended by the Office for National Statistics (ONS)).