STATEMENT OF COMPLIANCE WITH S172(1) OF THE COMPANIES ACT 2006
The directors have acted in a way that they considered, in good faith to be most likely to promote the success of the Company for the benefit of its members as a whole, and in doing so had regard, amongst other matters, to:
In order to promote the success of the Company, the Board directs and supervises the Company’s affairs within a framework of effective controls which enable risk to be assessed and managed. The directors set the Company’s objectives and policies and standards ensuring that its obligations to the State Street Group, its policyholders and others are understood and complied with and that it operates high standards of business conduct.
The Company has minimal suppliers in the conventional sense as it has outsourced all client facing, investment management and back office services to SSGA. The directors perform regular oversight of these services through review of operational reports, routine meetings with SSGA management and attendance by SSGA representatives at board meetings. A particular focus through the year has been on SSGA’s continued ability to work in a hybrid environment and its return to office plans.
The directors monitor policyholder activity through regular review of financial and other reports on premiums and claims and the performance of the funds in which the policyholders are invested.
The Company has a single shareholder, no employees, and given the outsourced nature of its operations it has no direct impact on the community. Through its emerging risk and material risks reviews the Board has considered its specific climate risk and additionally the Board has considered the broader environmental impacts of its activity. The Company has engaged closely with SSGA to understand its environmental position. The Company does not consider its physical and transitional climate risks to be material.
By order of the board,
Date 04 April 2022