Skilled Person Report relating to governance of an overseas owned insurance company

The UK regulator had ongoing concerns in three key areas:
– effectiveness of the board and its governance arrangements;
– effectiveness of risk management framework and processes; and
– systemic issues of conduct and culture at the firm and whether the board was sufficiently well set up, resourced and operating effectively in order to address these.

The regulator required a Skilled Person to report on all three areas in a two phase review.

We assembled a team based on the specific nature of the regulator concern, as well as the general governance and oversight assessment. This team included several senior staff with extensive experience of Board evaluation work and cross disciplinary competence:
– UK general corporate governance guidance and best practice;
– UK financial services regulatory governance requirements;
risk and controls; and
– organisational development / culture professionals.

We adopted a strictly evidence-based approach to the assessment, this included document reviews, interviews with key officers, managers and staff and live observation of Board and governance committee meetings over a period of several months. We triangulated the results of these various sources of evidence to arrive at robust conclusions supported by clear evidence.

This was a two phased and complex review with multi-layered issues to explore. We adopted an approach that was aimed at enabling the firm to draw on useful recommendations in addressing multiple issues. At the end of the second phase, we were able to assure the regulator that the firm had undertaken significant steps in setting up appropriate governance and risk and control structures and was on the right path in terms of setting the tone and embedding practices for good conduct culture.