Zurich Assurance Ltd Principles and Practices of Financial Management 2014 Annual Compliance Report to 90:10 With-Profits Fund Policyholders 22 April 2015
Contents 1. INTRODUCTION 3 2. WITH-PROFITS GOVERNANCE 3 3. BONUS RATES 3 4. INVESTMENT STRATEGY 4 5. SURRENDER VALUES 5 6. EXPENSES AND CHARGES 5 7. CHANGES TO THE PPFM 5 8. COMMUNICATION WITH POLICYHOLDERS 6 9. COMPETING OR CONFLICTING RIGHTS, INTERESTS OR EXPECTATIONS 6 APPENDIX WITH-PROFITS ACTUARY S REPORT TO POLICYHOLDERS 7 2
1. INTRODUCTION Zurich Assurance Ltd (ZAL) first published its Principles and Practices of Financial Management (PPFM) on 30 April 2004. The PPFM describes how we manage the with-profits business in the 90:10 Fund either originally written when ZAL was called Eagle Star Life Assurance Company Limited or prior to 1991 by Eagle Star Insurance Company Limited (ESI). The PPFM plays an important role in the governance of with-profits business and in ensuring that customers are treated fairly. The document covers the principles and practices relating to the main classes of UK-type policies, certain overseas-type policies and the small number of policies written under the Eagle/Midland banner. No changes were made to the PPFM during 2014. This report covers how we complied with the PPFMs which applied during 2014. You can view the current PPFM on our website at www.zurich.co.uk/withprofits The fund is effectively closed to new with-profits business. However, it still accepts small amounts of new with-profits business from contractual increases, switches and other options which it is obliged to accept under the terms of existing policies. ZAL has to tell its with profits policyholders every year whether it has complied with its obligations in the PPFM. This report covers the period 1 January 2014 to 31 December 2014 inclusive. It is the opinion of the ZAL Board of Directors that during 2014: the company has complied with its obligations in the PPFM the way it exercised discretion was appropriate it has addressed any competing or conflicting rights, interests or expectations of its policyholders and shareholders in a reasonable and proportionate manner. In particular this concerns the following areas which we describe in this report: bonus rates investment strategy surrender values expense incurred and charges made changes to the PPFM communications with policyholders. In preparing this report, we sought advice from the With-Profits Actuary (WPA) and the Independent Reviewer. A separate report from the WPA giving his opinion on whether the company has applied its discretion in a reasonable and proportionate manner is attached as an appendix. When reading this report, you may wish to refer to the PPFM for definitions of technical terms. 2. WITH-PROFITS GOVERNANCE The Board of ZAL is responsible for managing the with-profits business including setting bonus rates. You can find a broad description of the Board s governance role in Section 11 of the PPFM. ZAL has set up procedures so the Board can satisfy itself regularly that the with-profits business is being managed in line with the PPFM. Since 31 December 2004 there has been the specific role of With-Profits Actuary, whose responsibilities include advising the Board on the exercise of its powers of discretion in managing the with-profits business. The Board may also call upon advice from other senior managers in the Company with knowledge and experience of the with-profits business. The Board has appointed Martin Godwin as With-Profits Actuary. In addition the governance arrangements must involve some independent assessment of compliance with PPFM and how any competing or conflicting rights and interests of policyholders and shareholders have been addressed. The Board has appointed Steve Dixon to provide this independent assessment. 3. BONUS RATES Maturity and death claims before 13 January 2014 were based on the rates of bonus which we had declared on 14 January 2013. On 13 January 2014 we declared Regular Bonuses in respect of the year 2013 and revised Final Bonuses. These rates applied until the next declaration on 12 January 2015. At these declarations we have set Final Bonus rates to target an average of 100% of asset share on maturity (except for Section 32 Esitran policies and Unitised Fund Series 1 see PPFM for further details). Appendix B of the PPFM describes the calculation of asset shares. All ZAL asset shares are unsmoothed as any smoothing is applied in the calculation of the amount paid. We used representative policies to set bonus rates based on the asset shares for each group of policies. For certain policy types the guaranteed minimum benefits exceed the asset share and as a result no final bonus has been declared. 3
During 2014 we continued to distribute the Estate (described in Section 10.2.1 of the PPFM) to customers using the final bonus mechanism. Any distribution is achieved by considering whether to include an enhancement within asset shares at the time of claim as described in Section 10.2.2 of the PPFM. The enhancement, which applies to all types of claims, is reviewed at each bonus declaration. An enhancement of 2% of asset share at the time of claim was applied to claims in 2014 before 13 January 2014. For all other claims during 2014 this enhancement was increased to 4%. We also target that at least 90% of maturity payments will be within the range 80% to 120% of unsmoothed asset share. During 2014 we met this target. Maturity payments where a guaranteed amount is paid, causing the maturity payment to fall outside the target range, are excluded from this assessment. The ZAL Board was given supporting information to determine that the bonus declaration and smoothing applied in 2014 were consistent with the obligations in the PPFM. The declaration was reviewed and supported by the With-Profits Actuary and the Independent Reviewer. 4. INVESTMENT STRATEGY Investment policy for the 90:10 Fund is the responsibility of the Asset/Liability Management Investment Committee (ALMIC), subject to the powers reserved by the ZAL Board in respect of setting of investment strategy and approval of fund strategies. The ALMIC takes account of advice from the Investment Managers, the Chief Financial Officer, the Head of the Actuarial Function and the With-Profits Actuary. The ALMIC refers any major proposals on investment strategy to the Board for approval. For determining the investment return on the fund, Hong Kong and Isle of Man administered business have separate asset pools and are allocated the investment return on these asset pools. The majority of the fund, including all UK business, also has its own asset pools. During 2014 the company continued to maintain two separate asset mixes: one asset mix for life business, unitised pensions business and conventional Esitran business and a different asset mix for conventional pensions business (excluding Esitran) and assets backing guarantees and the Estate. Details of the investment performance and strategy for these two asset mixes are shown separately opposite: Life Business, Unitised Pensions Business and Conventional Esitran Business For the assets backing this group of business the total investment return was 7.6% before deducting tax and charges. This return was applicable to pension plans but was reduced for life and savings plans to 6.4% before charges because of the tax we have to pay. This performance applied to asset shares, reflecting good returns from fixed interest securities and property investments. We continue to make sure the mix of investments is appropriate to protect the benefits already added to plans. During 2014 the percentage invested in equities (shares) and property ranged between 25% and 29% and we expect the percentage invested in equities and properties to remain between 25% and 29% for the time being. The rest of the assets backing this group are invested in fixed interest and variable yield securities and cash. During 2014 the assets backing this group of business included a series of derivatives to protect the fund from significant falls in equity values (see Section 7.2.8 in the PPFM for details). At the start of the year the fund held 12 separate collars, one of which expires each month. A collar is a combination of a purchased put option and a sold call option. On each expiry up to and including April 2014 a replacement collar was purchased. For expiries from May to December 2014 inclusive a replacement put only was purchased. ZAL continues to monitor the price of call options and may sell call options again in future. During 2014 the derivatives reduced the return to the fund. The investment return would have been 7.7% before tax and charges (and 6.5% after tax for life and savings plans) if no derivatives had been held. Conventional Pensions Business and Assets Backing Guarantees and the Estate From 30 June 2009 we are investing the assets notionally allocated to these plans entirely in fixed and variable interest rate securities. As compensation for the lower anticipated long term returns on fixed and variable interest rate securities the company may enhance the investment return credited to asset shares for these plans. Currently this enhancement is 1% per annum from 30 June 2009 but this enhancement may be revised or removed at any time depending on the experience of the fund. The cost of this enhancement, if any, will be borne by the Estate. 4
For this pool of assets the total investment return was 22.4% before deducting charges and this is the return applicable to pension plans. This return has been enhanced by 1.0% to 23.4% as described above before application to asset shares of these plans. During 2014 the assets backing this group of business included a series of swaptions to protect the fund from significant increases in interest rates. The swaption contracts purchased are options to swap fixed interest payments for variable interest if interest rates are higher than the strike price on certain future dates. During 2014 these derivatives impacted the return to the fund by less than 0.1%. 5. SURRENDER VALUES Until 13 January 2014 surrender values were based upon bonus rates and which we had declared on 14 January 2013. On 13 January 2014 we implemented updated surrender values based on revised bonus rates. In both declarations we targeted a payment of 100% of asset share on average for surrender payments on all life contracts and unitised pension contracts. We regularly review surrender values to ensure they are consistent with this objective. Reviews are also undertaken at each bonus declaration. No Market Value Reduction factors (MVRs) applied during 2014. During 2014 we continued our approach of distributing the Estate to customers. An enhancement of 2% of asset share at the time of claim was applied to claims before 13 January 2014. For all other claims during 2014 this enhancement was increased to 4%. This enhancement is described in Section 3. During 2014 we continued our established practice of deriving surrender values for most conventional with-profits pensions policies by recalculating the policy benefits from inception. This calculation assumes that the policy has been written originally for the term at which the surrender is being requested. This approach gives some value for the guarantees present within the policy. This surrender value method, which is still used, has resulted in payments on these policies which are higher than 100% of asset share on average. We also target that at least 90% of surrender payments will be within the range 80% to 130% of unsmoothed asset share. During 2014 we met this target. Surrender payments on most conventional pension contracts which include an allowance for guarantees are excluded from this assessment as a higher amount may be paid in line with established practice. 6. EXPENSES AND CHARGES For policies in the 90:10 Fund, costs of administration and investment management are generally not applied as specific charges defined in the policy structures. Instead these costs are deducted from the accumulating asset shares and so affect each policy s ultimate benefits to the extent that asset shares are used to calculate such benefits. The costs of providing risk benefits, such as life cover and critical illness cover, are charged to asset shares based on the estimated average cost over groups of similar policies. On-going expenses are charged to asset shares in line with any charges identified in the contract. For Unitised With-Profits business any remaining expenses and commission are charged as a proportion of asset shares subject to a maximum of 2% per annum. For Conventional With-Profits business claims expenses are charged to the asset shares of policies becoming claims in the year, other remaining expenses are charged as a proportion of sums assured. During 2014 we met the costs of certain other guaranteed benefits from the resources in excess of asset shares of the 90:10 Fund. Examples of guaranteed benefits are guaranteed annuity options and guaranteed maturity values. As a result of a scheme of arrangement effective 1 January 2005, investment management fees for all business together with administration expenses for Group business continue to be charged to the fund as incurred. Charges to cover administration expenses for all other business are on a fixed rate basis, increasing each year in line with the Average Weekly Earnings Index for June. This resulted in an increase of 0.6% for 2014. The charges allocated to the fund are deducted from asset shares. This arrangement protects the fund from increases which may result from diseconomies of scale that can sometimes occur in a closed fund situation. The scheme of arrangement also includes a requirement to compare the expenses incurred by the company in operating the fund in calendar year 2014 to the charges to the fund for that year and to change the charges for future years if the charges are less than 80% or more than 120% of the expenses. This formal comparison will be completed later in 2015. 5
7. CHANGES TO THE PPFM No changes were made to the PPFM during 2014. 8. COMMUNICATION WITH POLICYHOLDERS Policyholders have received the following with-profits communications during 2014: March 2014 Following the bonus declaration on 13 January, we began the customer mailing in March. This consisted of an annual notice which included details of any bonuses granted to their policy together with a leaflet covering investment information and information about the changes we made to the PPFM and the way we manage the fund. We also told policyholders that the PPFM Compliance Report for the year 2013 would be available on the with-profits page of the company s website (www.zurich.co.uk/withprofits) by 30 June 2014. Customers can also telephone to request a copy. May 2014 We published the 2013 annual report on compliance with the PPFM on the ZAL website. This document consisted of a report to policyholders from ZAL on compliance with the PPFM and a report to policyholders from the With-Profits Actuary covering discretion exercised by ZAL. Those were the 2013 editions of these reports. 9. COMPETING OR CONFLICTING RIGHTS, INTERESTS OR EXPECTATIONS 9.1 FAIRNESS BETWEEN DIFFERENT GROUPS OF POLICYHOLDERS One of ZAL s objectives is to achieve an orderly run-off of the fund over the remaining lifetime of the policies in force. This means that both the assets needed to support current and future liabilities and any additional assets within the fund are taken into account in determining the level of bonuses, MVRs and the extent of smoothing. We currently achieve a fair distribution across different groups of policyholders by targeting 100% of asset share on claim for each group of similar contracts and paying guaranteed values if greater. 9.2 FAIRNESS BETWEEN POLICYHOLDERS AND SHAREHOLDERS Expense allocation, tax and distributions of surplus are the main areas where equity between with-profits policyholders and shareholders could potentially be an issue. 9.2.1 Expense allocation The court sanctioned Scheme of Arrangement effective 1 January 2005 laid down the expenses which can be charged to the fund. Where this requires ZAL to exercise discretion, the principles and their application have been reviewed by the With-Profits Actuary. 9.2.2 Tax The PPFM sets out the basis for applying tax to the fund as if it had been a standalone business independent of the other business of the Company. This has removed any judgement as to how much tax should be allocated to the fund. Distributions of surplus from the 90:10 Fund are shared between with-profits policyholders and shareholders in the proportions 90% to policyholders and 10% to shareholders. From 30 June 2005, any tax liability in respect of a distribution of surplus is attributed to the Estate. For distributions of surplus made before 30 June 2005 any tax liability was attributed to asset shares. 9.2.3 Distributions of Surplus In line with established practice, the shareholders share of any distribution of surplus is 10% of the surplus reported in the annual returns to the Prudential Regulatory Authority with the remaining 90% being allocated to policyholders. An enhancement to asset share at the time of claim was added as described in Sections 3 and 5. We assess whether a distribution can be made from the Estate whenever we revise bonus rates. 9.2.4 Processing Issues We are vigilant in monitoring the accuracy of our systems. If we discover an error, we take action to ensure that policyholders are not materially disadvantaged. 6
APPENDIX WITH-PROFITS ACTUARY S REPORT 2014 Annual Report from the With-Profits Actuary to 90:10 Fund Policyholders It is my opinion, in my capacity as With-Profits Actuary of Zurich Assurance Ltd (ZAL), that the annual report from ZAL contained above and the discretion exercised by ZAL during 2014 have taken the interests of the different categories of with-profits policyholders into account in a reasonable and proportionate manner. I have formed this opinion based on the information and explanations given to me by ZAL, and taking into account the relevant rules and guidance in the Financial Conduct Authority s Conduct of Business Sourcebook Chapter 20 (With-Profits) and Supervision Manual Rule SUP 4.3.16AR (With-Profits Actuary s duty to provide With-Profits Policyholders with an annual written report). The Financial Reporting Council has issued standards known as Technical Actuarial Standards applying to reports produced by actuaries. Four of these standards, TAS R (Reporting Actuarial Information), TAS D (Data), TAS M (Modelling) and the Insurance TAS were in effect at the date of preparation of this report. My report, and the work on which it is based, complies with all four standards except that, in terms of completeness, I have not considered it necessary or beneficial to policyholders to reproduce or expand on material covered in the company s report to policyholders to which my report is annexed. Martin Godwin FIA With-Profits Actuary Zurich Assurance Ltd 22 April 2015 7
Please let us know if you would like a copy of this in large print or braille, or on audiotape or CD. NP716647002 (04/15) RRD Zurich Assurance Ltd, authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Registered in England and Wales under company number 02456671. Registered Office: The Grange, Bishops Cleeve, Cheltenham, GL52 8XX. Telephone 0870 514 3624 We may record or monitor calls to improve our service.