Our International Businesses.
We appreciate that as our international subsidiary businesses in the US, France
and Holland contribute to our profits, we must effectively disclose
the way that we do business responsibly in those countries.
What we know
We also appreciate that there is a need to disclose more when we set
up new business ventures overseas or operate in what may be considered Higher
Risk Countries from organisations such as EIRIS and FTSE 4 Good.
In 2009 88% of IFRS profits were generated through the UK and 12% overseas. In 2010
the overseas profit mix has dropped slightly to 10%.
These businesses are responsible for the financial services of just over a million
customer policies compared to over eight million in the UK.
What we are doing
Progress has been made in many areas to reflect that the business profit mix is
changing.
Governance
- We have appointed representatives from International on our CSR Governance
Structures (Group CSR Committee, Ethics Committee, Bribery Act Working Group)
- The Ethics Committee performed a review of material issues relating to overseas
businesses in the areas of Human Rights, Bribery and Corruption, Market Inclusivity,
Supply Chain Standards, Customer Standards, Responsible Investment Policy, Environmental
Standards (HSE) Community Investment has taken place in the Group Ethics Committee.
From this we have identified key external partners to advice and validate our approach
when doing business responsibly.
- Integrated Environmental Data into our annual reporting to be more inclusive
of overseas activities.
Benchmarking
- In 2010 we have had independent audits from Bureau Veritas on our Health Safety
and Environmental performance in our subsidiaries against local and international
regulations.
- A full private benchmarking of the Business in the Community Corporate Responsibility
Index has taken place in 2010. This was designed to act as a proxy to understand
what our businesses do naturally in this area and lay out priorities for investment
in 2011 / 2010 in line with profit mix changes. The average scores came out as follows:
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- Our Bribery and Corruption Policy in line with the UK Bribery Act has involved
all subsidiaries and JV’s in its development and has been rolled out across
the Group.
People
- Common People Standards – Work has started to carry out audits of our US employee
handbook to satisfy ourselves that our US operation complies with the overall principles
of equality and diversity in line with our Equalities committee. The audit was satisfactory.
We also measured Employee engagement for the first time overseas with our US business
scoring an engagement level of 81 against UK engagement levels of 74.
- Invested in key community projects with our Joint Venture Partners on relevant local
issues such as the Mumbai Medicare Van work with Help the Aged through IndiaFirst.
- Extended reporting on Community and Non for Profit contributions by employees UK
and Overseas.
Looking Forward
For 2011 we have committed in our International Business to further improve our
disclosure in our yearly reporting cycle and improve BITC ratings
for these businesses by 2012 from the current average score of 30%.
We must continually balance the need to encourage local custom and best practice but
also to drive higher standards of doing business wherever we trade and employ people.