The policies below encompass our approach to Business Ethics. All policies are reviewed annually and colleagues are required to complete regulatory training every year.
Click here to visit our full Corporate Governance section, which includes our Modern Slavery and Gender Pay Gap reports.
You can also find further information on our policies and approach to sustainability in our latest Sustainability Report.
Code of Conduct
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
- Whistleblowing
- 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
Anti-Bribery and Corruption policy
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.
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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.
Anti-Discrimination and Harassment
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.
Board Diversity & Inclusion Policy
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)).
Conflict of Interest
A Conflict of Interest can be a personal or financial interest that is opposed to the business interests and/or customer interests. A Conflict of Interest can arise when an employee has competing interests or loyalties that can impact their impartiality may make it difficult to perform company work objectively and effectively.
All colleagues at all times are required to act honestly and with integrity and declare any conflicts of interest, and the simple rule is ‘disclose always’.
All colleagues are required to complete a Conflicts of Interest course annually. This explains what a Conflict of Interest is and directs colleagues to complete the Conflict of Interest form if they need to make a disclosure. Colleagues must disclose any personal relationships within the business, personal relationships with individuals working for linked or competitor organisations and any link to another company (including 20% or more share ownership, owning, or having a directorship or having a second job). Additionally, bespoke training is provided to colleagues who are in line manager roles which must be completed annually and explains how they should manage Conflict of Interests.
Forms are monitored by Managers as well and the People Governance Team and the appropriate Compliance teams. The information gathered from the completed forms is held securely and centrally by the People Governance team. Line managers will be made aware that a Conflict of Interest has been disclosed and they will be responsible for conducting a risk assessment and putting any appropriate measures in place to protect our employees, customers, and the business, should they need to.
Where any of the above measures cannot sufficiently mitigate the risk of the conflicts, cases are escalated to the Risk Management Committee.
Data Protection policy
Admiral Group is committed to the correct, lawful and transparent handling of the personal data that it processes, in line with both the UK and EU 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. Adherence to this policy is monitored through regular reviews and audit activities carried out by the Data Protection and Privacy Team and the Internal Audit function and reported to Audit and Risk Committees.
We provide annual Data Protection training to all employees, including contractors, to ensure that all staff 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. It applies equally to management, permanent and temporary staff, contractors, partners, and suppliers who have access to personal data for which Admiral Group is responsible.
Due diligence is also conducted on suppliers before we engage in a relationship with them, which includes specific data protection due diligence which may include a Privacy Impact Assessment. We have processes in place to ensure third-party contractual terms are robust and inclusive of required data protection clauses.
Admiral Group has a publicly facing privacy notice that data subjects are presented with to read prior to Admiral Group processing any personal data that they may share. Within that privacy notice, we explain instances where personal data may be shared with select third parties. This notice is available on the Admiral Group Website at: http://www.admiral.com/your-privacy-and-security
Visitors to our websites are presented with Cookie Banners to choose which cookies they wish to accept and the cookie policy is available on our website at the following:
http://www.admiral.com/cookie-policy
Admiral Group has a specialist team dealing with Data Protection Rights such as Subject Access Request and Erasure Requests who customers can contact at the following email address:
InformationRightsTeam@admiralgroup.co.uk
The Group also has a dedicated privacy team overseen by the Head of Group Privacy and DPO for the UK Businesses, that provides specialist advice to the business on its data protection and privacy obligations who can be contacted at the following email address: DPOOffice@admiralgroup.co.uk
Gifts and Gratuities
Our Gifts and Gratuities Policy recognises that sometimes customers, suppliers or business associates offer gifts or gratuities to staff and confirms that all such gifts must be made and received openly and fairly, must not include cash, must be reported and be in line with the policy.
Health & Safety
Admiral Group is committed to provide a healthy and safe working environment and limit or control any and all potential health & safety hazards. Our Group Health & Safety policy covers all employees, contractors, consultants and agency workers and works to ensure all staff are informed and receive appropriate training to perform roles competently and safely. In addition to physical well-being, Admiral Group also offers employees a wide range of mental well-being support arrangements through both our internal people service functions and external agencies.
Information and Cyber Security
Admiral continuously works to protect customer, staff and business data while fulfilling all contractual, regulatory and legal obligations.
Admiral’s Board of Directors has delegated the accountability for information security within each of the Group’s businesses to the Group CEO and local entity CEOs. Within each business responsibility for information and cyber security is allocated to a Chief Information Security Officer or equivalent Head of Cyber Security.
The Group Information Security Policy sets out how Admiral Group protects the confidentiality, integrity and availability of its information and assets while meeting all contractual, regulatory and legal obligations for information and cyber security. The policy is maintained, managed and disseminated by the Group Technology and Information Security Risk Team and reviewed and approved by the Group Risk Committee.
The Group Technology and Information Security Risk team aligns their policies, procedures and controls to the following internationally recognised risk management frameworks and standards:
- National Institute of Standards and Technology Cyber Security Framework
- ISO/ IEC 27001: 2022
- Center for Internet Security’s Critical Security Controls.
Procurement and Outsourcing
Our Group Procurement and Outsourcing policy states that all employees who engage in procurement activity must enhance and protect the standing of the business, maintain the highest standard of integrity in all business relationships, promote the eradication of unethical business practices including modern slavery, and ensure full compliance with laws and regulations whilst continuing to drive the de-carbonisation agenda across Admiral’s critical, strategic and key suppliers. This is enforced through strict controls and monitoring.
Whistleblowing policy
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 (whistle@fca.org.uk) and the PRA (PRAwhistleblowing@bankofengland.co.uk)