ANNOTATED COMBINED CODE FOR MUTUAL INSURERS REPORT ON COMPLIANCE FOR 2007
1. Executive Summary Members of the Association of Mutual Insurers (AMI) and the Association of Friendly Societies (AFS) were invited to complete a detailed questionnaire explaining how they are applying the Annotated Combined Code for Mutual Insurers (ACC). Responses were received from members who collectively represent 99% of AMI/AFS members by premium income. In overall terms, the Boards of AMI and AFS are very satisfied with the increasing level of engagement of their members in the application of the ACC with 52 out of a possible 53 (2006 – 50) organisations completing the questionnaire in time for the report. The overall performance and degree of stated compliance with the ACC as reported by members compares very favourably with similar data from the proprietary sector as per ‘Fifth FTSE 350 Corporate Governance Review 2006’ authored by Grant Thornton. Data for the proprietary sector is, of course, drawn from much larger companies, whereas the ACC reporting encompasses some large and many very small organisations. This report has been prepared primarily for HM Treasury and for the Financial Services Authority in order to monitor the performance of the mutual sector in improving standards of governance. Both organisations were involved in the development of the ACC and have indicated an intention to review the performance of the mutual sector in 2008 following publication of the 2007 performance as was required by the Myners Review. There is, as one would expect, some difference in the level of compliance when comparing the large and small company groups. In part, this is a reflection of the differing governance arrangements, differences in structure and to some extent differing levels of resource. The compliance of large companies as reported by them is very high. This is to be expected as many had already been using the Combined Code to assess their governance processes. The overall stated compliance of small firms with the ACC is very encouraging and continues to improve. Some elements of the ACC are for guidance only. It is however encouraging that many companies are developing their response to these parts of the ACC, notably in terms of a member relations strategy and function and their level of engagement with their members. This was the area where there was significant improvement in compliance compared to last year. This exercise and the report will be repeated in 2009, covering governance arrangements in 2008. From the information submitted for this report, it is clear that companies are continuing to embed the ACC and we would expect to see this reflected in next year’s results. The ACC was updated in February 2008 for compliance in 2008. It has been further updated, following changes to the Combined Code in June 2008, to ensure that it still accurately reflects the Combined Code. This will be sent to members in October 2008 for implementation in 2009. The ACC questionnaire will also be reviewed prior to its issue for the 2008 reporting year.
2. Background The ACC was developed in 2005 following the publication of the Myners Review in December 2004 which made a specific recommendation with regard to the introduction of a version of the Combined Code for the mutual insurance sector. Following discussion with HM Treasury and the Financial Services Authority, it was agreed that AMI and AFS would be responsible for producing the ACC and detailed guidance for their members on its implementation. AMI and AFS appointed a joint steering group both to oversee the development of the ACC and accompanying guidance plus its implementation and subsequent reporting. A list of members of the joint steering group is attached in Appendix 1. Members are responsible for evaluating their compliance with the ACC and for completion of the questionnaire which gives detailed information about their compliance. The joint steering group has relied upon the information provided by members of AMI and AFS and have not attempted to validate or evaluate the submissions. Each member’s reply to the ACC questionnaire has been signed off by its Board or Committee of Management. It is also a requirement of the ACC that individual companies 1
report their compliance with the ACC in their Annual Report and Accounts. Some elements of the ACC are subject to review by the company’s auditors. Small companies for the purpose of the report are defined as having gross premium income of less than £20 million per annum on average over the preceding three financial years and assets of less than £100 million on average at the end of each of the last three years.
3. General Overview A total of 52 (2006 – 50) companies completed the ACC questionnaire representing assets of £82 billion and annual premiums of £5.1 billion. These organisations between them have 15.4 million members and 11,300 employees. The average size of board/ committee of management was 8.9 (2006 – 9.5), of which typically, 81.0% (2006 78.4%) were non-executive and 19% (2006 – 21.6%) executive members. The 21 large companies represented 97% of the annual premiums, 99% of the assets. Large companies had on average 74% (2006 - 70%) of their board as non-executives whereas small companies had an average of 86% (2006 – 86%) non-executive directors. A more detailed report of stated compliance by main principles is given in sections 4 and 5. At a high level, within the 21 large companies in the survey, there was a 94% (2006 - 88%) stated compliance with the main principles. Amongst the 31 small companies there was an 87% (2006 - 83%) stated compliance Amongst large companies, their performance as institutional shareholders was reportedly an area of more consistent non-compliance than other areas of the Code in 2006. This year, we have changed the reporting on the basis that we expect companies who have outsourced their investment management to third parties to carry out their responsibilities as institutional shareholders but believe that companies which invest solely in unitised funds are exempt from these responsibilities. On this basis, there are three large companies in 2007 who are not compliant. In addition, the linking of executive directors’ remuneration to corporate and individual performance has five reported instances of non-compliance this arises mainly from the smaller of the companies in this group, though several reported that they are seeking to develop their remuneration structures in line with the ACC in 2008. For small companies, the more consistent areas of non-compliance also arise from principles B1 and C1 relating to the linking of executive remuneration with performance and disclosure of interim information which collectively account for 35% of the non-compliance. Similar comments apply to those made for larger companies. This report and the appendices are being provided to HM Treasury, the FSA, all members of AMI and AFS and will be available on the member sections of the AMI and AFS websites. Appendix 2 includes a full list of AMI and AFS members and a list of all companies who completed the questionnaire along with details of those companies who were exempted or excluded.
4. Commentary of the results for 2007 The general improvement in compliance from 2006 to 2007 reflects the ongoing programme of work that AMI and AFS members have initiated in response to the ACC. There are encouraging signs that companies have fully embraced the principles and are exploring beyond the base requirements, which suggests that work to date by the trade bodies and members has helped harness cultural change as opposed to purely just basic compliance. For example, there is widespread evidence that the ACC and guidance have created a much clearer understanding of good practice, and has encouraged the formalisation of processes and controls that are consistent with high standards of corporate governance. Further, mutual companies are continuing to actively seeking ways to engage more effectively with their members, and to enable members to participate more actively in the running of the organisation. To illustrate, 44 companies had member relations strategies and functions in place by the end of 2007, with 2
a further six expecting to have done so in 2008, notwithstanding that this guidance was recommended rather than mandatory. As a consequence of the development of the ACC, AMI and AFS have developed a number of initiatives to support their members. This included the creation of a member relations network, NED training and development programmes and sources of support. Some aspects of governance are also included in other work by the Associations, including a TCF seminar and the establishment of a Company Secretaries network. In addition, as friendly societies do not currently have the permissions to enable electronic voting, their trade body has petitioned Treasury to make the necessary legislation. Overall the results, and the appetite for continued improvement, are very encouraging.
5. Overall report analysis Large company summary The 21 large companies reported that they were 94% compliant with the 24 main principles. There were 13 companies that were 100% compliant with the main principles. The big improvements were for section D as a result of many members putting in place member relations strategies and in section E where clarification of questions played a part as well as better compliance. Although the compliance with B1 regarding performance related pay does not show improvement over last year, the accompanying comments did suggest that most companies are putting structures in place to comply in 2008. 2007
2007
2006
2006
Yes
No or n/a
Yes
No or n/a
A.1 The Board
21
0
20
0
A.2 Chairman and Chief Executive
21
0
20
0
A.3 Board balance and Independence
18
3
17
3
A.4 Appointments to the Board
20
1
19
1
A.5 Information in a timely manner
21
0
19
1
A.5 Professional development and induction
20
1
19
1
A.6 Performance evaluation
20
1
18
2
A.7 Re-election
20
1
19
1
A.7 Planned and progressive board
19
2
19
1
B.1 Sufficient remuneration
20
1
20
0
B.1 Performance related pay
16
5
15
5
B.2 Transparent setting procedure
19
2
20
0
B.2 Independent setting of remuneration
21
0
20
0
C.1 Financial reporting – annual report
21
0
19
1
C.1 Financial reporting – interim information
21
0
16
4
C.2 Internal Control
21
0
20
0
C.3 Audit committee and auditors - transparency
21
0
20
0
C.3 Audit committee and auditors – audit relationship
21
0
20
0
D.1 Dialogue with members
20
1
10
10
D.2 Constructive use of AGM – communications
21
0
19
1
D.2 Constructive use of AGM – best practices
19
2
14
6
E.1 Dialogue with companies
18
3
12
8
E.2 Evaluation of governance disclosures
18
3
12
8
E.3 Shareholder voting
17
4
13
7
Total
474
30
420
60
Total as a percentage
94%
6%
87%
13%
Section A – Directors
Section B – Remuneration
Section C – Accountability and Audit
Section D – Relations with members
Section E – Institutional Shareholders
3
Small company summary The 31 small companies reported that they were 87% (2006 - 83%) compliant with their 21 main principles by the end of the year. Of the 87 non-compliant answers 35% of the explanations were from B1 on performance related pay and C1 interim and price sensitive information. In the case of performance related pay many of those that are not compliant do not pay directors for their services so for them it is not applicable. The same is true on C1 where, as most do not issue interim reports and don’t have price sensitive information as such they answer not applicable. Nine small companies were fully compliant throughout the year. 2007
2007
2006
2006
Yes
No or n/a
Yes
No or n/a
A.1 The Board
31
0
30
0
A.2 Chairman and Chief Executive
29
2
29
1
A.3 Board balance and Independence
24
7
22
8
A.4 Appointments to the Board
26
5
27
3
A.5 Information in a timely manner
31
0
29
1
A.5 Professional development and induction
28
3
28
2
A.6 Performance evaluation
24
7
26
4
A.7 Re-election
29
2
27
3
A.7 Planned and progressive board
28
3
26
4
Section A – Directors
Section B – Remuneration B.1 Sufficient remuneration
27
4
25
5
B.1 Performance related pay
12
19
10
20
B.2 Transparent setting procedure
23
8
19
11
B.2 Independent setting of remuneration
28
3
25
5
Section C – Accountability and Audit C.1 Financial reporting – annual report
30
1
30
0
C.1 Financial reporting – interim information
21
10
18
12
C.2 Internal Control
31
0
30
0
C.3 Audit committee and auditors - transparency
28
3
27
3
C.3 Audit committee and auditors – audit relationship
30
1
28
2
D.1 Dialogue with members
25
6
7
23
D.2 Constructive use of AGM – communications
30
1
29
1
D.2 Constructive use of AGM – best practices
29
2
28
2
Total
564
87
520
110
Total as a percentage
87%
13%
83%
17%
Section D – Relations with members
1
All Company Summary Overall the 52 respondents were 90% (2006 - 85%) compliant in 2007 with 22 (2006 – 10) companies being fully compliant. There were a few extra reporting questions from the ACC guidelines in relation to engaging and communicating with members such as ‘has a member relations strategy been developed?’ 17 (2006 – 16) large members had developed a member relations strategy by the year end. Of the smaller members 27 (2006 – 19) had a member relations strategy in place. A few responded to the member relations function saying they would not appoint a dedicated person due to size constraints but had delegated the role to the senior independent director.
4
6. Detailed Analysis of responses to Main Principles Section A: Directors The responses in this section indicate that for the most part mutual insurers state that they are complying fully with the ACC, or are taking active steps to ensure they are. Exceptions tend to be because a number of companies have Boards comprising entirely of non-Executives. MP-A.1 - Is the board satisfied that it has (and can demonstrate that it has) operated effectively and assumed collective responsibility for the success of the company? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
21
31
20
30
No or not applicable
0
0
0
0
The results show that all companies stated that they were in compliance with this Main Principle. MP-A.2 - Is there a clear division of responsibilities at the head of the company between the running of the board and the executive responsibility for the running of the company’s business? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
21
29
20
29
No or not applicable
0
2
0
1
The results summarised above show a high level of stated compliance with this Main Principle with only two small companies not being compliant one of which was compliant by the end of 2008. One company that responded negatively did so on the basis that the small size of the organisation (only one paid member of staff working 7 hours per week) meant that it was unfeasible to have any clear division of responsibilities between the running of the board and the executive responsibility for the running of the company’s business. MP-A.3 - Does the board include a balance of executive and non-executive directors such that no individual or small group of individuals can dominate the board’s decision taking? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
18
24
17
22
No or not applicable
3
7
3
8
The results summarised above show that 86% of larger companies, and 77% of small companies, responding were in compliance with this Main Principle. The main reason for non-compliance is the lack of Executive Directors on the relevant Boards. Of the ten companies responding ‘no’ to compliance with this Main Principle, seven had no Executive Director representation on the Board whilst three had only one Executive Director. Where there is no formal Executive presence on the Board the Chief Executive attends Board Meetings as do other senior management when required.
5
MP A.4: Is there a formal, rigorous and transparent procedure for the appointment of new directors to the board? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
20
26
19
27
No or not applicable
1
5
1
3
The results summarised above show a high level of stated compliance with this Main Principle with all but one of the larger companies, and 84% of small companies, responding that they were in compliance throughout their financial year. Two out of the three smaller companies responding ‘no’ to this issue said it was not applicable to a company of their size. The remaining small company and the large one were both planning to be compliant in 2008. Two small companies did not respond to this principle. MP A5: Is the board satisfied that it is supplied in a timely manner with information in a form and of a quality appropriate to enable it to discharge its duties? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
21
31
19
29
No or not applicable
0
0
1
1
With 100% compliance each company indicated that its Board received information in a timely manner, and in a form that enables the Board to discharge its duties effectively. This is in accordance with the FSA principles in SYSC and Treating Customer Fairly requirements as well as the ACC. MP A5: Do all directors receive induction on joining the board and do they regularly update and refresh their skills and knowledge? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
20
28
19
28
No or not applicable
1
3
1
2
A high rate of stated compliance, with Boards in all but four mutual organisations satisfied they were receiving induction training and regularly updating of skills and knowledge. Two of those that responded ‘no’ did so because they had no new directors in the year for induction to be carried out. Two others did not comply because of the lack of regular training given to existing Board members, though both were in the process of reviewing their training and development programmes. MP - A6: Does the board undertake a formal and rigorous annual evaluation of its own performance and that of its committees and individual directors? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
20
24
18
26
No or not applicable
1
7
2
4
Evaluation is considered of high importance to all the organisations which is reflected in the 85% rate of stated compliance. Of those which answered no, six planned to undertake performance evaluation 6
in 2008 and the other two concluded they should not currently comply with this principle due to their very small size. MP - A7 - Re-election Are all directors submitted for re-election at regular intervals, subject to continued satisfactory performance? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
20
29
19
27
No or not applicable
1
2
1
3
All directors from 49 out of 52 companies were submitted for re-election at regular intervals subject to continued satisfactory performance. One of the non-compliant organisations was working towards compliance in this area for next year, another stated that directors were fit and proper according to their rules. MP – A7 - Does the board ensure planned and progressive refreshing of the board? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
19
28
19
26
No or not applicable
2
3
1
4
The two large companies not compliant both state that they will be working towards compliance during 2008. Two of the three small ones both claim to have “Fit and proper members nominated and elected in accordance with the Registered Rules of the Society”.
Section B: Remuneration MP – B1 - Is the Board satisfied that levels of remuneration are sufficient to attract, retain and motivate directors of the quality required to run the company successfully and that the company is not paying more than is necessary for this purpose? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
20
27
20
25
No or not applicable
1
4
0
5
At 90% this is a high level of stated compliance. The only exceptions are organisations which have no compensation for Board/Committee members. MP – B1 - Is a significant proportion of executive directors’ remuneration structured so as to link rewards to corporate and individual performance? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
16
12
15
10
No or not applicable
5
19
5
20
In overall terms a majority of large companies link rewards to corporate performance. This practice is less prevalent amongst small companies. As with the previous principle, for six companies there is no remuneration for Board/Committee members so the principle is not applicable. Two companies from both the large and the small section are implementing a performance programme in 2008 and a further three have a small proportion of executive directors’ pay that is performance related, though not the significant proportion directed by the main principle. A further seven companies, mostly small, do not consider 7
performance related pay to be appropriate for their business. The remaining four companies made no comment. MP – B2 - Is there a formal and transparent procedure for developing policy on executive remuneration and for fixing the remuneration packages of individual directors? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
19
23
20
19
No or not applicable
2
8
0
11
A good level of compliance by large companies with the two exceptions one being due to the fact that they had no executive directors, the other was being addressed. All the non-compliance by small companies was because they do not remunerate the Board/Committee members. MP – B2 - Can the Board confirm that no director is responsible for fixing his or her own remuneration? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
21
28
20
25
No or not applicable
0
3
0
5
Full stated compliance by the large companies. Those small companies who answered no provide no remuneration for their Board/ Committee members although they do meet out of pocket expenses, the level of which is agreed by the Board.
Section C: Accountability and Audit MP- C1 - Does the board present a balanced and understandable assessment of the company’s position and prospects? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
21
30
19
30
No or not applicable
0
1
1
0
An almost 100% stated compliance indicates that Boards present annual reports to a good standard. MP - C1 - Does this extend to interim and other price sensitive public reports and to other information required for statutory purposes? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
21
21
16
18
No or not applicable
0
10
4
12
For the large companies there was 100% compliance. For the small ones all of the non-compliance answers were because the question was not applicable. Of the ten that answered not applicable, the reason given was that they did not publish sensitive information or interim information so the principle was not relevant.
8
MP - C2: Is the board satisfied that there is in place a sound system of internal control to safeguard members’ interests and the company’s assets? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
21
31
20
30
No or not applicable
0
0
0
0
All companies indicated they had good internal controls in place with a continuation of the 100% stated compliance. MP-C3 Has the board established formal and transparent arrangements for considering how they should apply the financial reporting and internal control principles? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
21
28
20
27
No or not applicable
0
3
0
3
The large companies were 100% compliant as last year with the smaller companies mostly being compliant. One small company planned to be compliant in 2008, one has concluded it should not currently seek to comply with this principle due to its very small size and the other stated it was not applicable. MP – C3 - Has the board established formal and transparent arrangements for maintaining an appropriate relationship with the company’s auditors? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
21
30
20
28
No or not applicable
0
1
0
2
Overall companies were almost 100% compliant. The only no concluded it should not currently seek to comply with this principle due to its very small size.
Section D: Relations with Members Last year’s results were made worse by the confusion in the section title ‘Relations with Shareholders’, this was changed to ‘Relations with Members’ which significantly increased understanding. MP – D.1 - Where the company has (for example) members’ forums or panels and/or a delegate system, or members with significant membership rights, has the board considered the principles of Section E on the basis that these could be equated with significant investors in the company? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
20
25
10
7
No or not applicable
1
6
10
23
This main principle has seen significant improvement in compliance over last year with 26 of last year’s 33 non-compliant content that they now complied. This was due to two reasons, mainly because the area was new in 2006 and companies needed time to embed a member relations strategy and to get it up and running and secondly because the wording last year using ‘institutional shareholders’ instead of ‘members’ was ambiguous and led to a number of not applicable answers.
9
The only large company that was not compliant intends to be in 2008 as do three of the small companies. As a result most companies now have engagement strategies and processes for members. MP-D2 - Does the board use the AGM to communicate with members and encourage their participation and to facilitate accountability? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
21
30
19
29
No or not applicable
0
1
1
1
Compliance is excellent for this main principle with almost 100% being compliant. The one small company that responded no to this question indicated that its Board was actively considering how to change its rules to allow proxy and postal voting as a way to encouraging participation. MP - D2 - Does the company comply with the best practice guidelines contained in the Guidance in relation to the use of the AGM? 2007 Large
2007 Small
2006 Large
2006 Small
Yes
19
29
14
28
No or not applicable
2
2
6
2
Large companies who did not confirm compliance with this principle confirmed that action was being taken during 2008. Small companies that responded no to this question indicated that they are reviewing current arrangements as part of their commitment to treating members fairly or that it is ‘not appropriate for a company of their size’. ACC provisions, in other questions of this section, which focused on proxy voting highlighted that a number of companies (11 out of 52) do not use proxy voting with the reason given that they operate according to a delegate system (applicable to 7 of the 11), or else the rules of the company (and for friendly societies, the legislation) prevented use of proxy voting. With regard to the latter, some indicated they were actively considering or changing rules for the future. For the former group however, the delegate system is designed to ensure member views are represented through the delegate, and proxy voting was not permissible. Those companies are firmly wedded to the current delegate system and see this as a virtue of democratic representation of the mutual model rather than a failing.
Section E: Institutional Shareholders Small mutual insurers were exempted by the guidelines from reporting under this section (whilst still being encouraged to make every effort to comply). Accordingly the responses cover the 21 large companies. Responses indicate a level of stated compliance with the main principles at around 85%, up considerably from last year’s 60%. Some firms who have outsourced their investment management have agreed that their managers should carry out their responsibilities as responsible shareholders as part of the overall investment management services. In some cases where the investment management is outsourced the investment criteria given to the investment company is to invest in general unitised funds. Where this is the case it is not possible to perform as an institutional investor as there is no direct link to the shares invested in. In these cases, and there are five of them, they have been included as being compliant.
10
MP – E.1 - Does the company in its role as an institutional shareholder enter into a dialogue with companies in which it has invested based on the mutual understanding of objectives? 2007 Large
2006 Large
Yes
18
12
No or not applicable
3
8
Of the three organisations who are not compliant they all responded that this was not applicable to them. MP - E2 - Does the company in its role as an institutional shareholder evaluate the governance arrangements of companies in which it has invested particularly those relating to board structure and composition and does it give due weight to all relevant factors drawn to its attention? 2007 Large
2006 Large
Yes
18
12
No or not applicable
3
8
Responses and supplementary comments to this question and its supporting principles were identical to main principle E1 above and in the introductory paragraph to section E. MP - E3 - Is the board satisfied that the company in its role as an institutional shareholder makes considered use of its votes? 2007 Large
2006 Large
Yes
17
13
No or not applicable
4
7
Responses and supplementary comments to this question and its supporting principles were generally consistent with the main principles above.
11
Appendix 1 Joint AMI/AFS ACC steering group Graham Berville, Police Mutual, Chair Jonathan Dick, NFU Mutual Gareth Evans, Royal London Derek Fickling, The Children’s Mutual Alan Goddard, Cornish Mutual Rachel Griffiths, AMI Andrew Horsley, Engage Mutual Fiona McBain, Scottish Friendly Colin Paskell, Druids Friendly Society Matthew Rodhouse, Wesleyan Martin Shaw, AFS Shaun Tarbuck, AMI
Appendix 2 AMI members at 31 December 2007 (32 members) Benenden Healthcare Society British Benefits FS * Children’s Mutual, The * Cirencester FS * Civil Service Healthcare FS * Communication Workers FS * Cornish Mutual Dentists Provident Society * Druids Sheffield FS * Ecclesiastical Insurance Group plc Engage Mutual Assurance * Equitable life Family Investments * Health Shield FS * Healthy Investment * Housing Association Mutual Insurance Association Kingston Unity Independent Order of Oddfellows FS * Liverpool Victoria FS * MGM Assurance National Deposit FS * National Farmers Union Mutual Pioneer FS * Police Mutual Assurance Society * Reliance Mutual Royal Liver Assurance * Royal London Mutual Scottish Friendly Assurance Society * Shepherds FS * Sunderland Marine Mutual Insurance Teachers Provident Society UIA Wesleyan Assurance Society * = Also a member of AFS (19 in total)
12
AFS members at 31 December 2007 (48 members) Ancient Order of Foresters Anglo Saxons FS Bacon & Woodrow FS British Benefits FS Bus Employees FS Cambridge Council Carolgate FS Children’s Mutual, The Cirencester FS Civil Service Healthcare Society Communication Workers FS Compass FS Coventry Assurance Society Dentists & General Mutual Benefit Soc Dentists Provident Society Druids Sheffield FS Engage Mutual Assurance Family Investments Grand United Order of Oddfellows FS Health Shield FS Healthy Investment Independent Order of Oddfellows Manchester Unity Kensington Friendly Collecting Society Kingston Unity Independent Order of Oddfellows FS Leeds Council Liverpool Victoria FS Metropolitan Police FS Midland Counties Colliery officials and staff FS National Deposit FS National Independent Order of Oddfellows Newbridge Road Assurance Society Nottingham FS Original Holloway FS Pharmaceutical & General Provident Society Pioneer FS Police Mutual Assurance Society Railway Enginemen’s Assurance Society Railway FS Red Rose FS Royal Liver Assurance Royal Standard FS Schoolteachers FS Scottish Friendly Assurance Society Sheffield Mutual FS Shepherds FS Sons of Temperance FS Transport FS Wiltshire FS
AMI and AFS members completing their ACC Questionnaire (52 members) Ancient Order of Foresters Anglo Saxons FS
Large Small
1 2
Bacon & Woodrow FS
Small
3
Benenden Healthcare Society
Large
4
British Benefits FS
Small
5
Bus Employees FS
Small
6
Children’s Mutual, The
Large
7
Cirencester FS
Small
8
Civil Service Healthcare Society
Small
9
Communication Workers FS
Large
10
Compass FS
Small
11
Cornish Mutual
Small
12
Coventry Assurance Society
Small
13
Dentists & General Mutual Benefit Soc
Small
14
Dentists Provident Society
Large
15
Druids Sheffield FS
Small
16
Engage Mutual Assurance
Large
17
Equitable life
Large
18
Family Investments
Large
19
Grand United Order of Oddfellows FS
Small
20
Health Shield FS
Small
21
Healthy Investment
Small
22
Housing Association Mutual Insurance Association
Small
23
Independent Order of Oddfellows Manchester Unity
Large
24
Kensington Friendly Collecting Society
Small
25
Kingston Unity Independent Order of Oddfellows FS
Small
26
Liverpool Victoria FS
Large
27
Metropolitan Police FS
Small
28
MGM Advantage
Large
29
National Deposit FS
Large
30
National Farmers Union Mutual
Large
31
National Independent Order of Oddfellows
Small
32
Nottingham FS
Small
33
Original Holloway FS
Small
34
Pharmaceutical & General Provident Society
Small
35
Pioneer FS
Small
36
Police Mutual Assurance Society
Large
37
Railway Enginemen’s Assurance Society
Small
38
Red Rose FS
Small
39
Reliance Mutual
Large
40
Royal Liver Assurance
Large
41
Royal London Mutual
Large
42
Royal Standard FS
Small
43
Schoolteachers FS
Small
44
Scottish Friendly Assurance Society
Large
45
Sheffield Mutual FS
Small
46
Shepherds FS
Small
47
Sunderland Marine Mutual Insurance
Large
48
Teachers Provident Society
Large
49
Transport FS
Small
50
Wesleyan Assurance Society
Large
51
Wiltshire FS
Small
52
AMI and AFS members to whom the ACC does not apply Ecclesiastical Insurance Group Already applies the Combined Code for listed companies Sons of Temperance FS In the process of transferring engagements Cambridge Council Not an insurer Leeds Council Not an insurer AFS members exempted from inclusion due to size Newbridge Road Assurance Society Carolgate FS Midland Counties Colliery officials and staff FS Railway FS AMI member not completing questionnaire or completing after the cut-off date for the report UIA
13
Association of Mutual Insurers (AMI) PO Box 21, Altrincham, Cheshire, WA14 4PD, United Kingdom tel: 0161-952 5092 fax: 0161-929 5163 www.mutualinsurers.org Association of Friendly Societies (AFS) PO Box 21, Altrincham, Cheshire, WA14 4PD, United Kingdom tel: 0161 952 5051 fax: 0161-929 5163 www.afs.org.uk
