Jun 22, 2023 5 min read

Poor Performance on Codes of Ethics by UK Firms

The UK’s leading institute on business ethics has published a survey on codes of ethics – who has them, how good they are and the like. It’s a pretty poor performance by UK plc, with too many firms lacking one, or having one that’s not good enough. So how do insurers compare?

codes of ethics
AI and data issues are building a tailwind around ethics. Does your code capture them?

Every few years, the Institute of Business Ethics (IBE) publishes a survey of firms that have a code of ethics and what those codes contain. Their latest report finds improvements, but also big gaps. The survey covers firms in the FTSE100 and FTSE250, so the UK’s top 350 firms in all. And these are firms across all business sectors.

Here are the main ‘take-aways’ from their survey, which you can find here (registration required).

Of the top 100 firms, 90% have a publicly available code of ethics, up from 81% in 2021. That’s a reasonable improvement, but still, it also highlights that one in ten firms don’t have a code. Frankly, this improvement is not something that UK plc should feel comfortable with, given how much further some firms still have to go.

Open to the Public?

The ‘publicly available’ aspect might be a problem, as I’ve found that some firms see their code of ethics as a document only for internal consumption. I think this fundamentally ignores the purpose of a code of ethics, which is to show stakeholders (both inside and outside a firm) how it seeks to go about its business. Of course, it is executives and employees who apply the code, but the key audiences lies outwith the firm. In short, if your firm has a code of ethics, but doesn’t publish it for external consumption, it effectively does not have a code of ethics.

Of the top 250 firms after that top 100, only 40% of them had a publicly available code of ethics. Firms have been urged to use codes of ethics for a few decades now, so the 60% without a code are in effect saying that how they conduct their business is no one else’s affair. What can I say, other than ask why you would do business with them, why you would even insure them for something like D&O or product liability?

Quality Counts Too

That’s the quantity. What about the quality? The IBE found that only 64% of FTSE100 codes of ethics and 52% of FTSE250 codes could be rated as good. Good was defined by the IBE as covering nature/language/tone, user friendliness, speaking up and leadership. Turn these two percentages around and the UK public finds that 242 of its top 350 firms either don’t have a code or don’t have a good one. That looks like a rather large fail to me.

Some of you may be tempted to say that ESG is where all the action is now. And you’d be right, but only to a limited degree. A firm who purports to ‘do ESG’ but doesn’t have a code of ethics, is not doing ESG. Full stop.

How do Insurers Compare?

So what about the insurance sector? How does it perform on codes of ethics? Unfortunately, the IBE report doesn’t include any form of sectoral breakdown. However, back in the summer of 2018, I undertook a detailed study of the codes of ethics of ten UK insurers. Interestingly, one leading insurer didn't have a code, so that tallies with the current 10% without a code in the FTSE100. My study looked primarily at three things: accessibility, authority and scope. In essence, are these codes of ethics…

  • reaching the right people?
  • given the support to deliver results?
  • framed around the relevant issues?

It was more detailed than the IBE study, largely because it was more specific – just ten insurers. You can download the study below.

What I found was in places sometimes startling, sometimes heartening. Each of the insurers in the review had their own approach, which is absolutely fine and to be expected. Yet several of them missed out on features that a good code of ethics should cover. A personalised approach is fine, but not if quality is the price. I’m going to explore three themes that stood out about these insurer codes.


On the basis that customers are a key audience for insurers’ codes of ethics, the question of how easily the codes could be accessed is important. What I found was very disappointing.

“Only two insurers had their codes easily accessible online. Two more insurers released their code after I approached their contact services. The rest required repeated requests, which in three cases resulted in questions about why I needed to see their code. They released the codes in the end, but not before leaving the impression of being defensive about their ethical commitments.”

Another aspect of accessibility was the narrative style used in it. Most of these insurers adopted a first person narrative, which is more inclusive and conveys ethics as a joint venture. That’s how it should be.

I then considered the level of subordination in how the codes were written. This is an estimate of how often a statement was followed by an explanation. Most of these insurer codes were found to have a strong level of subordination, which was good. It pointed to insurers not only telling people what was expected of them, but why that was expected as well.

Leadership Support

Four of the insurer codes carried a personal statement from the chair or chief executive about why their code was important. And each of those executives provided powerful statements, making clear not just why employees should follow the code, but also why that executive personally saw it as an important thing to do. Yet at the same time, five carried no such statement, leaving employees to wonder how serious their firm was about ethics.


The proof of a code of ethics lies mostly in the issues that it addresses. I found that insurers were...

“...focussing their codes of ethics on a typical range of acknowledged ethical risks, and only extending this when legal developments like new bribery laws come along. In other words, the ethical issues they needed to address, rather than the ethical issues they should be addressing. Few of the insurers in the review appears to have sat down and given serious thought to the ethical risks that their code needed to cover.”

When I published this study in June 2018, it was obvious that dual pricing was a big ethical problem that insurers needed to address. Only two of the insurer codes mentioned pricing in any way, yet a few months later, the loyalty penalty super complaint landed. Sure, most codes mentioned ‘treating customers fairly’, but only in connection with service, not pricing.

So what is the equivalent today of the loyalty penalty in 2018? Discrimination and data ethics are the obvious ones. And by discrimination, I mean in relation to not just employees, but customers as well, across all functions, in both digital and analogue systems.

So what does your firm have to say about these two issues? If it contains little or nothing about them, then that’s a gap you need to fill quickly. If your code does cover them, make sure that it’s saying meaningful things that people can weigh up.

To Sum Up

Every firm should have a code of ethics. Without one, many of the brand promises made, most of the environmental and community initiatives described, and all of the trust statements made will simply not be believed.

A decent code of ethics needs to address accessibility, authority and scope, otherwise it’s just a tick box piece of paper. To get real value from it, it should show employees what is expected of them in relation to the big ethical themes, both present and emerging.

Start with two of the big ethical themes at the moment: data ethics and discrimination in relation to consumers. If your code doesn’t address these (and none did in 2018), then it needs attention now.

If you’re holding an internal workshop about your firm's code of ethics, consider bringing me in as an independent voice. This broadens the perspectives that decisions will be based around. Get in touch here.
Duncan Minty
Duncan Minty
Duncan has been researching and writing about ethics in insurance for over 20 years. As a Chartered Insurance Practitioner, he combines market knowledge with a strong and independent radar on ethics.
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