ESG Policy

1.1       The purpose of this code of conduct and ethics (Code) is to:

- Explain Icen Risk's values and how they relate both to our day-to-day work and the key ethical challenges we face.
- Provide information and guidance in relation to:

i. how we should conduct ourselves when carrying out Icen Risk's business; and

 ii. our responsibilities to our regulators, the third parties entrusting us with their underwriting capital and wider stakeholders.

- Set out our responsibilities in relation to the highest standards of corporate behaviour and be transparent and accountable, including how we impact on society and our environment.

2.1          This Code applies to all persons working for Icen Risk Limited or any group company, including employees at all levels, directors, officers, interns and individual temporary or fixed term contractors, wherever they are located.

2.2          This Code does not form part of any contract of employment or contract to provide services and the board of directors may amend it at any time at their discretion.

3.1          The board of directors has overall responsibility for ensuring the Code complies with our legal and ethical obligations, and that all those people to whom it applies comply with it.

3.2          The board of directors has primary and day-to-day responsibility for implementing this Code, monitoring its use and effectiveness, ensuring adequate and regular training in respect of the Code, dealing with any queries about it and auditing internal control systems and procedures to ensure they are effective in managing ethics and conduct on behalf of Icen Risk.

3.3          You are invited to comment on this Code and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the board of directors.

4.1          Diversity, equity and inclusion

It is our people which make Icen Risk; we should enjoy and feel comfortable working with each other.  Mutal respect and support is essential and genuine team work is what is valued. We aim to recruit on the basis of talent and potential contribution to Icen Risk without regard to colour, gender and any disability.  We will not discriminate and will provide equal opportunities.

4.2          Discrimination, harassment and bullying

Icen Risk has zero tolerance on bullying, harassment and discrimination.  Everyone should enjoy being part of Icen Risk and wish to develop and support those around us.

4.3          Health and safety

Our workplace must be safe and we should all play a part in this.

4.4          Workplace violence

Icen Risk has zero tolerance on workplace violence, including verbal abuse.

4.5          Drugs and alcohol

Icen Risk has zero tolerance on drugs and whilst moderate enjoyment of alcohol is permitted in the company of our clients and colleagues, drunkenness is not permitted during working hours or at the workplace.

4.6          Environment

Icen Risk wishes to create an environment where we choose to come to work, make a positive impact and feel rewarded in what we do.

5.1          Conflicts of interest

Transparency is vital and our responsibilities to our regulators and those third parties entrusting us with their underwriting capital mean that we take steps to avoid conflicts of interest and disclose and manage those that may arise.

5.2          Competition

Healthy competition will enable Icen Risk to succeed financially and sustain a market leading, professional organisation.  Nothing should be done that restricts competition to the detriment of our customers.  Succeeding in our competition must always be healthy and ethical, achieved through excellent service provided in a highly professional manner.

5.3          Bribery and corruption

Icen Risk has zero tolerance on bribery and corruption.  

5.4          Gifts and hospitality

When entertaining clients and others we must always be aware of how something may look, act proportionately so that our actions do not influence others and act such that are behaviour is not embarrassing, unethical or illegal (and to ensure it could not be perceived as such).

5.5          Anti-money laundering

Any suspicion of money laundering must be reported to our Money Laundering Officer immediately.  All employees must undertake anti-money laundering training and remain vigilant and cautious of the possibility of money laundering in the environment in which we operate.

5.6          Trade sanctions and import/export controls

Icen Risk must strictly adhere to sanctions laws in the territories in which we operate, primarily those of the United Kingdom, the European Union and the United States of America. All employees must undertake sanctions training and the insurance policies issued by Icen Risk will contain a sanctions exclusion.

5.7          Slavery, human trafficking and child labour

Icen Risk will ensure that it is in compliance with the laws relating to slavery, human trafficking and child labour. Icen Risk will not insure clients where it has as suspicion that such client could be involved in or support slavery, human trafficking or child labour.

5.8          Environmental operational compliance

Icen Risk wishes to be socially responsible in the way it acts on matters impacting our environment.  This includes encouraging behaviours which are environmentally friendly, such as:

- Avoiding non-essential business travel (for example, using video conferencing where possible), particularly where it involves flying. Choosing train journeys over flights wherever possible and practical.

- Encouraging employees to use electric vehicles, trains or bicycles when attending business meetings and travelling to and from work.

- Ethically sourcing supplies to minimise pollution and avoid unsafe or unethical working practices of those supplying Icen Risk.

- Supporting local and small businesses wherever possible and practical when choosing our suppliers and partners.

5.9          Sustainability

Icen Risk wishes to be aware of the environmental impact of its actions and operations and to choose sustainable solutions where practical and possible from the need for travel to the supplies it purchases. Cost is not the only consideration.

5.10       Taxation

Icen Risk will pay all taxes due from it. Icen Risk will not base itself in any harmful tax jurisdiction and wherever possible will engage staff as employees and not through personal service companies. Icen Risk will also seek to prevent the facilitation of tax evasion wherever possible. As part of our tax underwriting strategy, we will not insure tax avoidance schemes.

6.1          INTELLECTUAL PROPERTY

Icen Risk wishes to be proud of its name and identity and part of building this brand and name is to be ethical in everything which we do.  We will not copy any third party intellectual property but be proud of creating our own.

6.2          CONFIDENTIAL INFORMATION

Icen Risk wishes to ensure the absolute confidentiality of its own information and that of its customers.  Employees must treat confidential information as such and the company will continue to invest in secure methods of protection confidential information.

6.3          DATA PROTECTION

Icen Risk is aware that data can be sensitive and will take appropriate steps necessary to protect such personal data.

6.4          USE OF INFORMATION AND COMMUNICATION SYSTEMS

Information and communication systems are valuable business tools to enable Icen Risk to be successful.  Icen Risk has zero tolerance on any abuse of such information and communication systems and the company’s IT security policy sets out the behaviours expected of its employees.

6.5          USE OF DEVICES

Company devices are valuable business tools to enable Icen Risk to be successful.  Icen Risk has zero tolerance on any abuse of such devices and the company’s IT security policy sets out the behaviours expected of its employees.

6.6          RECORDS MANAGEMENT

Icen Risk will retain client records as securely as possible using reputable suppliers such as Microsoft, Salesforce and with additional back up to protect data. Icen Risk aims to be paper free, using electronic records and signatures to avoid the use of inks, paper, transportation and storage.

6.7          CONTRACT AUTHORISATION

The directors of Icen Risk select the parties we contract with to enable us to choose ethical and reliable business partners.  The Company will look for partners with their own appropriate ESG policies and where we feel they treat their employees and clients ethically and to a high professional standard.

6.8          SOCIAL MEDIA

Social media will be used by Icen Risk to advertise our products and expertise. Media usage is monitored and signed off by at least one director of the Company to ensure that messages area appropriate, ethical and professional.

7.1          HUMAN RIGHTS

Icen Risk aims to reward its employees in a fair and equitable way, making it a place where its employees wish to remain.  In part, this is achieved through profit sharing arrangements. Employees will be treated well, in an encouraging and safe environment.  The Company will pay a living wage or above.  Icen Risk will ensure that it employs legally and avoids any involvement with modern day slavery.

7.2          CONFLICT MINERALS AND CONFLICT ZONES

Icen Risk does not trade in conflict zones, nor purchase conflict minerals and ensures compliance with sanctions laws.

7.3          CHARITABLE AND POLITICAL DONATIONS

Icen Risk does not make political donations.The Company provides for an annual budget for registered charities and encourages its employees to nominate charities which they feel are important and relevant to them and the Company.  We aim to support smaller charities where our donations have a direct and meaningful impact.

7.4          VOLUNTEERING

Icen Risk supports volunteering towards local causes in our community and the communities where our employees live.

8.1          You must ensure that you read, understand and comply with this Code.

8.2          You must also:

- Notify one of the Company’s directors as soon as possible if you believe or suspect that a breach of this Code has occurred, or may occur in the future.

- Co-operate with any investigation that Icen Risk undertakes.

- Seek help or advice from a director of Icen Risk if you have questions about any aspects of the Code.

- Understand and comply with specific laws and regulations that apply to your specific role.

- Complete any mandatory training related to this Code that is offered to you.

9.1          Disciplinary action, up to and including termination and/or legal proceedings, may result from any failure to comply with:

- The Code.

- Applicable laws, rules or regulations.

- Any other Icen Risk policy or the staff handbook.

10.1          This Code will be reviewed annually or as required following:

- Any legislative changes or changes to industry guidance that might impact on it.

- Any changes to other associated internal policies, processes or procedures.

- Any breach or other incident relating to the issues addressed in this Code.