ESG

Environment

Insurance companies’ operations have limited direct impact on the environment. The main environmental risks for an insurance company, such as ITIC, relate to underwriting and investment activities.

Flights

• The ITIC team and its board believe that face to face meetings with members, insurance brokers and advisers are invaluable and are a key contributing factor to the successful underwriting and claims handling of the business.
• A survey found that travel to visit insurance brokers, members and potential members was very important and should continue.
• All business trips have to be approved by ITIC’s commercial director to ensure that they are worthwhile.
• All flights are considered against the carbon emission estimates during the booking process.
• The ITIC board believe that it is beneficial to meet in person for their board meetings.  The venues are strategically chosen to be where there are a significant number of assureds, thereby maximising the purpose of any travel.
• It is recognised that flights have a negative environmental impact. However, for the reasons noted above, travel at ITIC continues. Furthermore, it is felt that there are social and governance benefits from having a travel programme.

Members’ insured services

• The world is moving towards becoming more carbon neutral. However, the traditional forms of energy still remain and ITIC will continue to provide insurance services and loss prevention advice to those businesses serving the energy market.

Cycle to work scheme

• Thomas Miller, ITIC’s managers, encourages its employees to make use of a “cycle to work” scheme. This scheme supports a healthier, greener and more cost efficient method of transport.
• The initiative allows employees to purchase a brand new cycle plus safety equipment (i.e. helmets, light, and locks) in a tax efficient manner.

Electric car scheme

• To help decrease greenhouse emissions, Thomas Miller encourages participation in an electric and low emissions vehicle lease scheme.
• Employees can purchase a car in a tax efficient manner.

Paperless office

• ITIC has maintained a paperless office since 2011 through the use of a comprehensive document management system.
• All board meeting agendas are produced in a paperless format, on a board pack portal which allows for electronic circulation.

Greener office

• ITIC’s office utilises motion sensor lights which detect when there is movement, which reduces the usage of electricity.
• Waste is segregated to allow separation of food and mixed recycling.
• Thomas Miller look to sublet excess office space which helps enable more efficient and greener per head use of the facilities.

Social

Key social risk elements of an insurance company, like ITIC, are the reliance on a skilled workforce and also the maintenance of customer trust. In addition, data privacy is crucial.

Charity

• ITIC is proud to support the Sea Cadets, Street Child, High Tide foundation, the RNLI and the OSCAR campaign in aid of Great Ormond Street Hospital.
• Be The Difference, is Thomas Miller’s unique and specifically designed Corporate Social Responsibility programme – see   https://www.thomasmiller.com/about-us/corporate-social-responsibility/
• Thomas Miller's charity partner is Street Child. Activity is currently focussed on Street Child’s programme in Afghanistan and Thomas Miller aims to raise £100,000 over two years to go towards ensuring children in Afghanistan are safe, in school and learning.
• Thomas Miller operates a charitable match funding scheme, for any charity event that employees take part in, whereby £1 raised is matched by £1 from Thomas Miller, up to £350 per person.

Modern slavery

• ITIC recognises that all businesses have an obligation to prevent slavery and human trafficking. As an international company ITIC always works to the highest professional standards and seeks to comply with all laws and regulations applicable to business.
• ITIC’s modern slavery and human trafficking statement can be found at Modern Slavery Act - ITIC (itic-insure.com)

Working from home

• Prior to covid-19 lockdowns, ITIC had been trialling working two days per week from home.
• Currently, the ITIC team work Tuesdays, Wednesdays and Thursdays in the office where they can work alongside each other and communicate quickly whilst also building a strong work environment.
• On Mondays and Fridays the team work at home whilst still being able to meet with colleagues via Teams.

People

• ITIC is managed by 23 full time staff, 5 of whom are qualified lawyers, with an average of 18 years in the insurance / transport industry and an average 13 year service to ITIC.
• ITIC and its manager, Thomas Miller, have as a core principle ensuring fairness, engagement, diversity and inclusion in employment.
• To this end Thomas Miller ensures its recruitment and employment practices are open, fair and inclusive, and designed to encourage opportunity for those currently underrepresented in the transport and insurance sectors.

Gender pay gap

• Organisations in England, Scotland and Wales that have 250 or more employees are required to publish and report specific figures about their UK employees' gender pay gap.
• Thomas Miller’s latest gender pay gap report sets out more details of its gender pay gap as at April 2021 and what the company is doing to address it.
• The report is available at Gender Pay Report

ITIC community

• As a mutual, there is the feel of a community.
• ITIC provides loss prevention advice, contract reviews and guidance and standard terms and conditions.
• ITIC informs its members and brokers at exhibitions and seminars, training events, social events and through publications.
• ITIC protects its members’ interests across the industry.

Equal Opportunities

• Thomas Miller is committed to equal opportunity in all aspects of employment. Thomas Miller opposes all forms of discrimination and will not tolerate discrimination based on age, nationality, ethnic origin, gender, sexual orientation, gender identity or expression, religion, marital status, or disability.
• Thomas Miller strives to provide an inclusive and supportive environment for all its employees.
• Thomas Miller recognises that it is its people that make Thomas Miller what it is and its people enable its businesses to deliver first class service to our clients.

Rewards & benefits

• Thomas Miller provides a fair and competitive reward package in each of its regions around the world, recognising that in such a diverse organisation, a 'one size fits all' approach to reward is neither practical nor possible.
• Whilst Thomas Miller looks at local market practices in each of its regions, it always aims to offer a balance of salary, variable pay, employee benefits and share schemes to ensure that its employees are appropriately incentivised and recognised for their contribution.

Training

• As well as the importance which is placed on training at Thomas Miller, the PRA and FCA also view training as a central role in the organisation.
• The training needs within ITIC have been formalised and those employees directly involved in insurance distribution require a minimum of 15 hours annual continuing professional development.
• All employees will have training during the year including on line refresher courses.
• Training hours are recorded and presented to the board at a summarised level.
• Professional training for the Institute of Chartered Shipbrokers and Chartered Institute of Insurance are encouraged and supported by ITIC.

Volunteering

• Thomas Miller, recognises the importance of allowing employees time off to undertake civic duties and community projects. Consequently, it gives its employees up to three days paid leave per year to undertake such activities.

General Data Protection Regulation (“GDPR”)

• GDPR (General Data Protection Regulation) has a direct effect in the European Union (“EU”) and the UK.
• The GDPR relates to information regarding an identified or identifiable living natural person or individual. Its intention was to strengthen and harmonise EU and UK procedures and protect individuals concerning the collection, storage, processing, access, use, transfer and erasure of personal data.
• ITIC has confirmed to its members (and their insurance brokers) ITIC’s compliance with its obligations under GDPR. Full information is available via the privacy statement: www.itic-insure.com/cookies-privacy

Governance

ITIC is based in the UK, a country that has a strong reputation and rule of law together with strong governance standards and regulatory framework.

Mutuality

• ITIC is incorporated in England and Wales as a company limited by guarantee and not having a share capital.
• ITIC is owned by its members and governed by their representatives.
• The funds accumulated ultimately belong to the members and excess retained funds are regularly returned to members through the continuity credit process.

ITIC’s board of directors

• ITIC is governed in an open and transparent manner.
• ITIC’s board of directors currently comprises nine non-executives who work for current members, two non-member non-executives who have actuarial and mutual experience and two executives who are the CEO and CFO of the business (see Our Board - ITIC).
• Appointments to the board are recommended to the membership for election at the annual general meeting and are done so on the basis that the board should mirror the underlying membership in terms of representation of regions and insured services.
• The non-executive board members’ remuneration is detailed in the annual accounts.

Risk management framework

• ITIC maintains a comprehensive framework of policies, procedures and terms of reference to maintain control over its operations.
• Risk management is an important aspect of the business. ITIC maintains: a risk appetite statement, business risk assessments, fraud risks register, emerging risks register, bribery risk assessment, sanctions risk assessment and criminal finances act assessment.
• Annually, ITIC produces an Own Risk and Solvency Assessment which is filed with the PRA (Prudential Regulation Authority).

Investments

• ITIC and its reinsurer TIMIA hold approximately US$300m of investments to pay claims and expenses.
• The results of the investments are measured against the performance of a hypothetical benchmark portfolio of predominantly ESG rated funds.
• ITIC and TIMIA invest the equity part of the portfolio into ESG screened funds in order to match those of its benchmark funds.

Anti-bribery

• As a mutual insurer for companies within the transport sector ITIC sets great store by equity between members and probity when dealing on their behalf. In support of ITIC’s commitment to maintaining the highest possible standards of business practice ITIC holds a 'zero-tolerance' stance towards bribery. Bribery is illegal and as such has no place in ITIC.
• ITIC’s anti-bribery policy is available here: ITIC Anti-Bribery policy - ITIC (itic-insure.com)

Complaints

• ITIC is dedicated to providing its members with a high quality service and wants to ensure that it maintains this at all times.
• If any member feels that ITIC has not met its expectations then they should first write to their insurance broker or intermediary, if any.
• See: Complaints - ITIC (itic-insure.com) for further information.

Regulation

• International Transport Intermediaries Management Co Ltd is the Appointed Representative of International Transport Intermediaries Club Ltd which is authorised by the Prudential Regulation Authority and Regulated by the Financial Conduct Authority and Prudential Regulation Authority.
• International Transport Intermediaries Club Ltd (Registration number: 2725312) and International Transport Intermediaries Management Co Ltd (Registration number: 2670020) are registered in England.

Solvency II reporting

• The Solvency and Financial Condition Report (“SFCR”) provides the general public with an overview of the company’s solvency and financial condition covering business performance, its system of governance, the adequacy of its risk profile and a description of its capital management.
• ITIC’s latest SFCR is available here

Sanctions screening

• Screening for sanctions is performed with the use of sanctions database lookup software and is set to search individuals and organisations against sanctions lists.
• Sanctions checking takes place prior to quoting on a potential member and this is recorded in the “know your customer” process.
• On a monthly basis, a batch list of members, joint members, brokers, fronters, introducers, lawyers and other advisers is uploaded to the checking software.
• All claims payments and other general expenses are screened against sanctions lists.
• All matches are investigated and either resolved or dealt with accordingly.

Taxation

• The board’s direction is to abide by the relevant tax laws to ensure that ITIC is making the right level of financial contributions to the communities of which it is a part.
• This approach is open and transparent and verified by expert third parties, notably ITIC’s auditors.

Climate change policy and plan

• The PRA requires firms to fully embed the consideration of the financial risks from climate change into their governance framework.
• The PRA also requires the board and the highest level of executive management to identify and allocate responsibility for identifying and managing financial risks from climate change to the relevant existing Senior Management Functions (“SMFs”) most appropriate within the firm’s organisational structure and risk profile, and ensure that these responsibilities are included in the SMFs’ Statement of Responsibilities.
• ITIC has a policy which sets out ITIC’s approach to the financial risks from climate change.
• ITIC has a plan for managing the financial risks from climate change and has considered this from four main perspectives: the impact on ITIC's members, the impact on the running of ITIC, the impact on the investments of ITIC and the macro impact.