Codes of Ethics in Insurance

A good code of ethics should support the business in building trust with its key audiences. It needs to balance a recognition of where the firm is now, and where the firm wants to get to. Here are some key ingredients that every good code should have…

  • be accessible, relevant and speak to the right audiences
  • demonstrate how the firm’s leadership is giving their active support
  • be up-to-date and not too long
  • recognise the right issues and have something meaning to say about them
  • help people to come forward with their ethical concerns.

You’d be surprised how few insurers deliver on each of these key ingredients.


What most surprised me from my 2018 review of the codes of ethics at ten insurers was just how marginalised these documents seemed to be. Many were old, tired looking, unappealing and difficult to find. One of the ten insurers had made a real effort and their code ticked a lot of boxes, except on length – it was very long, which raises questions about accessibility. Another of the ten didn’t even have a code of ethics, something I hadn’t expected to find when starting the survey.

Yet why should this be, with insurers that have well organised governance and process arrangements? It could be down to codes of ethics being thought of as different from other policy documents and position statements. As a result, there’s less clear ownership of them and they’re left to wither while the business pushes forward with big initiatives like digital and counter fraud.

Let’s be clear – if there is less clear ownership of codes of ethics within some insurers, then that points to ethics itself being less clearly organised and supported. And that would count as a red flag to a conduct regulator.

So how should a typical insurer respond? Start by asking what the code of ethics is there to achieve. From that cascade all sorts of follow-on questions, about which you’ll find a lot of suggestion in the articles linked to on this page. And remember to use my 2018 survey (see opposite) as a benchmark for your review.

Benchmarking Data

This 2018 review was built around a detailed analysis of the codes of ethics of ten insurers active in some way in the UK insurance market. It should just how varied, in both content and quality, codes of ethics are in insurance. 

It's free to download and forms a useful benchmark against which your current code of ethics can be assessed. All ten insurers are anonymised. 


The Case for Reviewing your Code of Ethics  

What I often find when working with an insurer on a review of their code of ethics, is just how many people want to have a say in what and how it is done. Managing those interests means putting together a convincing case, and robust structure, for your review. These two articles will help with that...

Is your code of ethics good enough?

11 reasons why you should review your code of ethics

Codes of Ethics have to be relevant and practical. They need to speak to a wide range of people, and pitched at just the right level between 'commitment' and 'detail'. Too little commitment and people will wonder what your code is trying to achieve. Too much detail puts people off reading it. 


Key Questions a Code of Ethics Review has to Address  

Who is your code of ethics for? This was something that most of the ten insurers reviewed failed to address. I explore this in this article...

An important lesson for insurers to learn about their codes of ethics  

And when you know your key audiences, how do you get them to engage? 

How can insurers get people to open and read their code of ethics?

Finally, does your code speak to those people about what they're interested in? 

Insurer codes of ethics are not addressing the big trust issues


Digital Companion to the Code of Ethics of the Chartered Insurance Institute 

In 2019, I was a member of the CII's Digital Ethics Forum, tasked with exploring how data ethics could be reflected in their existing code of ethics. I became the lead author for the Digital Companion and its accompanying practical guide, which you can read by clicking on the links below...

CII Code of Ethics: Digital Companion

CII Code of Ethics: Digital Companion Practical Guide

Evolving your firm's commitments to reflect changing market realities is an important part of keeping codes of ethics relevant and of interest to key audiences. 


Delivering on Commitments

I support insurers seeking to frame their commitments and craft them into accompany policies and plans. I do so with insight relating to scope, significance and expectations. 

Example - This top 20 UK insurer had drafted a policy commitment on data ethics and brought me in to finalise it in line with the expectations of key audiences. I then developed a detailed implementation plan on data ethics and presented both to the board.

Client quote - “Informed, compelling & practical as always”

Jump to other 'Purpose, Risks and Codes' themes...

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