Annual 2014 Review - Insurance Ireland II Annual Review Final...DURING 2014 In late 2013, Laura...

Insurance IrelandAnnual Review

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2014Annual

Review

Value

International

Flooding

Intelligence

Transformation

Engagement

Progress

Health

Innovation

Pensions

Representation

Customers

Insurance Fraud



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CONTENTS

03 About Insurance Ireland

04 Welcome From Our CEO

05 Insurance Ireland's Strategy House

06 Communications PR & Stakeholder Engagement During 2014

07 Membership Services and Events

15 Insurance Information Service (IIS)

16 Insurance Ireland representing the Industry In Ireland

19 Insurance Ireland representing the Life Insurance Sector

21 Insurance Ireland representing the General Insurance Sector

25 Insurance Ireland representing the International Insurance Sector

27 Insurance Ireland representing the Health Insurance Sector

29 Insurance Ireland representing the Industry in Europe

31 Insurance Ireland's Directory of Members

32 Insurance Ireland Board, Councils, Committees, Forums and Working Groups

33 Structure of Insurance Ireland

33 Insurance Ireland Board

34 Insurance Ireland Councils

36 Life Sector Committees & Working Groups

37 General Sector Committees & Working Groups 40 International Sector Working Group

41 Health Sector Committees & Working Groups

42 Industry Wide (Common) Committees & Working Groups

44 Insurance Ireland Management Team

THE VOICE OF INSURANCE

INSURANCE IRELAND TEAM AT THE FRAUD CONFERENCE

AVIVA STADUIM – 2014


3Insurance IrelandAnnual Review

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As the Voice of Insurance actively promoting the highest standards, Insurance Ireland represents the domestic insurance and international life insurance market. This business generates €25bn in premium income (domestic and overseas), employs 27,000 people, with thousands more in ancillary services and contributes over €1.6bn in tax to the Irish exchequer.

Insurance makes a major contribution to Ireland’s economic growth and development and is a cornerstone of modern life. One of the most important aspects of insurance is to pay claims to customers at times when they need it most. Each year the insurance industry pays out more than €5.4bn in claims to Irish customers.

ABOUTINSURANCE

IRELAND

As the voice of the industry, Insurance Ireland’s key functions include:

• Representing its members’ interests to Government, state agencies, regulatory bodies, public representatives, other national interest groups, the media and the general public.

• Representing the position of members at a European level, particularly via Insurance Europe, the European Association for national insurance company representative bodies, and at a global level via the Global Federation of Insurance Associations (GFIA).

• Keeping members abreast of relevant policy and regulatory developments and providing a forum for member debates on such issues.

• Providing information to Government, the wider policymaking community and the public about insurance.



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WELCOME FROM OUR CEO

Reflecting on 2014, it has been a year in which Insurance Ireland further consolidated its position as the voice of Insurance at a domestic and international level, the latter through our representation via Insurance Europe & Global Federation of Insurance Associations (GFIA).

The 2014 high level metrics supporting our role as the Voice of Insurance continued to show an improvement compared to 2013, highlighted as follows:

• Membership up by 12% • 300 member organisation staff engaged

directly with us in delivering on our strategy for the industry, an increase of 25% compared to 2013

• 35 events held in 2014, up from 8 in 2013• Over 1,700 delegates participating in

Insurance Ireland Events, the highest recorded for any year in the history of the organisation

• Increase in the number of policy & regulatory items we engaged with on behalf of the sector, up by 28% on 2013

• The establishment of Insurance Ireland’s INED Council

• The ongoing building of internal capability to support our ever increasing agenda

• Increased media presence

In continually striving to be more refined in our representation on behalf of the sector, and in doing so seeking to achieve

the right outcomes for our sector and its customers, perhaps the biggest ongoing challenge faced by Insurance Ireland is to increase understanding about the role of insurance, its benefits and how its unique business model works, both at a consumer, institutional and government stakeholder level. To this end and in accordance with our overall strategic plan, our most recent Consumer Conference took the first high profile step in engaging proactively around the consumer agenda on behalf of the sector, with other initiatives, including policy, across Life, General, International & Health demonstrating to our wider stakeholders the role our industry currently plays and can play in the future in providing solutions that address our countries economic and social challenges.

As an organisation we will continue to work in partnership with government and the regulator to ensure that the right solutions are found and implemented so as not to restrict the potential of our sector when our consumers need us most in these ever changing times.

To close I would like to take this opportunity to thank you for your continued support, and as your representative body in the context of an ever growing presence amongst our stakeholders, we will strive even harder in 2015 to represent our members needs at domestic and European level.

Kevin ThompsonCEO

INSURANCE IRELAND

INSURANCE IRELAND STRATEGY HOUSE

ENABLERS: LEADERSHIP & REPRESENTATION; ADVOCACY & POLICY DEVELOPMENT; FOCUSED ON MEMBER NEEDS; HIGHLY PARTICIPATIVE

- THE VOICE OF INSURANCE IN IRELAND.

OUR VALUESTRUST & TRANSPARENCY, KNOWLEDGE

MANAGEMENT, ACCOUNTABILITY, RELATIONSHIP MANAGEMENT, INNOVATION

OUR MISSION IS TO REPRESENT AND SUPPORT THE

DEVELOPMENT OF THE INSURANCE INDUSTRY IN IRELAND IN THE INTERESTS OF OUR

DOMESTIC AND INTERNATIONAL MEMBERS AND THEIR CUSTOMERS

OBJECTIVES

Promoting Ireland as a place to do

business

Influencing theRegulatory

environment

Building theContribution to the

Economy

Serving the Irish Customer

Delivering our Transformation

Programme

OUR VISION IS TO BE THE VOICE FOR

THE INSURANCE INDUSTRY AND RECOGNISED AS A CENTRE

OF EXCELLENCE BY OUR DOMESTIC AND INTERNATIONAL STAKEHOLDERS



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During 2014, our communications focus was on consolidating our position as the voice for the sector both in the media and in direct engagement with our key influencer stakeholders, e.g. Government Ministers and key officials in the Departments of Finance and Environment. Issues that were top of the agenda in both media and stakeholder outreach included health, pensions and flooding, and we made progress with key stakeholders in all of these areas.

Our first major initiative of the year was the announcement in March with Minister Brian Hayes and the OPW, of the Memorandum of Understanding to share flood defence data. This was a major breakthrough in terms of constructive collaboration with this key stakeholder and we will continue to collaborate with OPW on this issue to ensure that both industry and Government have a thorough understanding of the challenges, ultimately with a view to providing more customers with flood insurance. The announcement was very well received in the media.

Our second significant initiative was the publication in April of a major report, commissioned by Insurance Ireland, from PwC on the future of the insurance sector in Ireland and the potential economic benefits to the Irish economy. Entitled ‘Creating the Future for Insurance in Ireland’, the report detailed the important contribution our sector makes to the Irish economy and set out a roadmap for job creation and expansion in the sector.

A key element contained within the road map related also to the International Insurance sector, creating a blueprint on how best to retain existing companies based in Ireland as well as attracting new operations. The first step in promoting this

blueprint to International Stakeholders occurred in May when, Kevin Thompson, CEO of Insurance Ireland, was invited to speak at a high level IFSC Ireland event in the New York Stock Exchange, consolidating our position as the voice of the industry and delivering us another opportunity to underline the importance of our sector to the Irish economy to an influential Irish and US business audience.

In September, we also hosted a conference to discuss pensions, and particularly Universal Pensions, attended by the Minister for Social Protection, Joan Burton. We then launched a report entitled ‘A Universal Pension for Ireland’ in September, and hosted a media briefing and a workshop which was again attended by Minister Burton. The report is another strong example of collaborative work with stakeholders.

Following on from last year’s very successful CEO breakfast meeting with An Taoiseach, Enda Kenny, T.D., guest of honour at this year’s event was Mr. Michael McGrath, T.D. and Fianna Fail spokesperson on Finance, who gave strong insight into the opposition’s views on the economy. This was a further example of our strategy to gain insight into the views of a broad spectrum of stakeholders in a constructive and collaborative manner.

Throughout the year, we maintained frequent contact with the media, particularly business media, with a number of briefings either on a group or one-to-one basis, as well as placing a number of opinion pieces from the Chief Executive in national newspapers, appearing on TV, and dealing with all questions from the media. We will continue to build out our media and stakeholder programme on behalf of our members next year.

COMMUNICATIONS PR & STAKEHOLDER ENGAGEMENT DURING 2014

In late 2013, Laura Farrell was appointed to a newly created role in Insurance Ireland as Director of Membership Services and Events. In mid 2014, the team was expanded with the appointment of Ann O'Leary as Communication and Events Management Executive. The focus of the team is three fold:

• To enhance engagement with our members and strengthen relationships

• To increase awareness and promotion of Insurance Ireland services amongst members

• To further develop the Insurance Ireland value proposition to members

MEMBERSHIP SERVICES OBJECTIVE: TO ENHANCE ENGAGEMENT WITH OUR MEMBERS AND STRENGTHEN RELATIONSHIPS One of the primary vehicles for engagement through Membership Services of existing and new members is the Insurance Ireland Calendar of Events. Up to 2012, Insurance Ireland hosted one event per annum in the form of it’s annual industry lunch. In 2013, we held eight events. This year 35 events were delivered by Insurance Ireland with c1,700 members and stakeholders in attendance over the year.

The calendar included six feature events: our AGM and Annual Industry Lunch, two Pension Policy Stakeholder Workshops, our annual CEO Breakfast, annual Anti-Fraud Conference and the inaugural President’s Conference – Customer 360 .̊

The balance of the calendar covered a range of events serving various targeted segments of our membership base and/or specific stakeholder groupings.

Third party briefings were facilitated on an array of topics including mediation in claims, the pending introduction of postcodes, the UK chargeable events regime and telematics. A training seminar was delivered for 90 fraud specialists operating in Special Investigation Units across our member base. We ran a series

of Flooding Workshops for our members and four Seminars for the Central Bank of Ireland presenting on topics such as RDR.

The Chief Risk Officer Series ran three fora during the year which provided a highly engaging platform for senior risk staff to network and learn from their peers through the exchange of experiences, challenges and ideas.

Our guest of honour for this year’s CEO Breakfast was Michael McGrath, TD, Spokesperson on Finance, Fianna Fáil who engaged in an incisive and lively session with our CEOs that resonated with all in attendance.

We will shortly release details of the 2015 calender.

SOME OF THE HIGHLIGHTS OF THE 2014 CALENDAR…

Pension Policy Workshops & Report Launch - “A Universal Pension for Ireland”A Workshop designed to develop consensus on the details and timing of a universal pension for Ireland amongst key stakeholders was held on February 11th of this year in Dublin Castle. Participants included IBEC, ICTU, Age Action and the Pensions Board. On Tuesday, 30th September, Insurance Ireland hosted a second cross sectoral stakeholder workshop.

At this second session, Insurance Ireland launched a specially commissioned report titled “A Universal Pension for Ireland”, which focused on policy and implementation issues based on international best practice. Joan Burton, TD, Tánaiste & Minister for Social Protection was in attendance along with four high profile speakers; David Harris, Managing Director, TOR Financial, Peter Neilson, CEO, Financial Services Council, David C. John, AARP Policy Institute and Tim Jones, CEO, NEST UK.

MEMBERSHIP SERVICES AND EVENTS

Pictured at the Insurance Ireland Annual Lunch were Garvan O’Neill, Partner, PwC, Tony O’Riordan, Head of Life Insurance Actuarial Practice, PwC and Kevin Thompson, CEO, Insurance Ireland

Ann O’leary, Communication and Events Management Executive

Pictured at the Pensions Policy Initiative are from left to right Gerry Hasset, Managing Director, Irish Life, Joan Burton, Tánáiste and Minister for Social Protection and Kevin Thompsn, CEO, Insurance Ireland.



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Pictured at the Insurance Ireland Fraud Conference ‘Understanding the True Impact of Fraud’ were from left to right Niall Kavanagh, COO, Risk Intelligence, Ciaran McGaley, CEO, Risk Intelligence and Kevin Thompson, CEO, Insurance Ireland.

Anti-Fraud Conference – “Understanding the True Impact of Fraud”250 delegates registered for our Fraud Conference - 'Understanding the True Impact of Fraud' held on November 13th in the Aviva. The turnout was 56% up on 2013, and included C-level executives, functional heads and fraud specialists at middle and senior management levels. There was a strong representation from across all our member sectors: Life, General, International and Health.

The event was designed as a fast paced morning conference with the speakers latterly forming a panel for a highly interactive audience Q&A session to close the event. Speakers included representatives from Europol, City of London Police/IFED, Liberty Insurance and AXA PPP Healthcare. We had six exhibitors and four sponsors on the day, including Risk Intelligence, our Platinum sponsor.

At the event, our Innovation Strategic Alliance Partner Accenture launched the findings of a detailed insurance fraud consumer sentiment survey recently commissioned by Accenture and carried out by Amárach Research in the Irish market. This was developed in conjunction with members of our Anti-Fraud Forum. A video shot by Accenture featuring members of the Forum was played on the day of the conference.

The findings of the survey provided insights into Irish people’s perception of insurance fraud and their opinions on why fraud is committed. A key implication of the research is that attitudes towards fraud are largely appropriately negative however consumer sentiment toward taking action to combat fraud is disturbingly ambivalent. The findings will be used to inform our future anit-fraud advertising campaigns.

Inaugural President’s Conference - Customer 360˚ The Customer 360° Conference took place on December 3rd at the Convention Centre Dublin. There were 260 delegates in attendance for this Inaugural Presidents Conference – an event we are keen to establish as the industry’s annual flagship event.

The conference title Customer 360˚ reflected the rounded discourse that took place on the day with respect to the nature and needs of the customers we serve both now and in the future.

The Insurance Ireland Customer 360° Conference was aimed at Directors and Senior Managers across the Life, General, International and Health insurance sectors. We heard from CEOs from each of these sectors, from Consumer Representatives, from the Regulator and from thought leaders on the new age of the digital consumer. The Conference was largely panel based with discussions hosted by Bryan Dobson.

The format of the conference was a departure from the norm in its highly interactive and participative composition. The voice of the customer was amply facilitated, and we as an industry discussed and engaged around issues of import to our customers and challenges for us in engagement and delivery.

Pictured at the Insurance Ireland Fraud Conference ‘Understanding the True Impact of Fraud’ Tom O’Brien, Senior Manager, SIU, Liberty Insurance.

Pictured at the Customer 360° Conference were Kevin Thompson, CEO, Insurance Ireland, Karen O’Leary Member of the Commission, Competition and Consumer Protection Commission, Bryan Dobson, RTE and Sean Casey, President, Insurance Ireland.

Pictured at the Customer 360° Conference were Kevin Thompson, CEO, Insurance Ireland, Donal Clancy, Managing Director, Laya Healthcare, Anthony Brennan, CEO, Zurich Life and Ciaran McGettrick, Managing Director, Phoenix Group Ireland.



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Chief Risk Officer ForumWe closed the year with the last of three CRO Fora for 2014 on December 11th. The CRO Forum is designed to be a high-level discussion group exclusively formed and attended by Chief Risk Officers of Insurance Ireland Member and Associate Member companies. The purpose of the series is to engender debate and discussion, facilitating peer learning, network building and the sharing of experience and knowledge in this community.

The topics for the last forum of the year was Risk Management and the Regulator which was be delivered by Mark Burke of the Central Bank of Ireland, and the value added dimension of the role of CRO – which took the form of a peer debate facilitated by Milliman, our partners in the Forum Series.

Previous fora have featured presentations on subjects including Emerging Risk, ORSA, the Structuring of the Risk Management Function and the Role of the CRO at the Top Table.

PROGRESS TOWARD 2016….

Insurance Europe General Assembly and International Conference 2016In November 2013, at Insurance Ireland’s CEO breakfast with the Taoiseach, Enda Kenny, T.D. we announced our successful

bid to host the Insurance Europe General Assembly and International Conference 2016.

The conference will bring representatives from 34 national insurance bodies and global insurance leaders to Dublin to address key issues facing the insurance industry.

In the intervening year Insurance Ireland established a Strategic Steering Committee to oversee the design and development of the conference plan. The Committee consists of our CEO, Kevin Thompson, Director of Membership Services and Events, Laura Farrell, our current President Sean Casey, Managing Director New Ireland Assurance, our President for 2015, Ciaran McGettrick, Managing Director Phoenix Group Ireland and our President for 2016 the year of the Conference, Andrew Langford, Group Chief Executive FBD.

The Committee oversees the activities of the Insurance Ireland Advisory Committee, a panel mainly populated by marketing, business development, communications and PR specialists drawn from across our member base to support us in bringing this industry flagship event to fruition. This panel is augmented by the presence of Kieran O Donoghue, Head of International Financial Services, IDA.

Insurance Europe 2016 Advisory Committee Name Title CompanyLaura Farrell Director of Membership Services

and EventsInsurance Ireland

Ann O’Leary Communications and Events Management Executive

Insurance Ireland

Damien O'Neill Allianz Head of MarketingBrian O'Neill Friends First Strategic Marketing DirectorPatrick Nally RSA Group Marketing DirectorDick Harnett OSG Group Head of Business

Development Marketing and Sales,

Brendan McEvoy Irish Life Director MarketingSusan Landers Allianz Worldwide Head of Marketing & Client

Management Bronagh Twomey FBD Insurance Group Head of Marketing

Kieran O'Donoghue IDA Head of International Financial Services

Regina O Connor Senior Vice President Government Affairs & Corporate Compliance XL Group

Paula Hodson Director of Development Services Insurance Institute of Ireland

Pictured at Insurance Ireland - Milliman CRO forum in September are Ger Bradley, Milliman, Fergus Barry Fergus Barry and associates and Eamonn Phelan, Milliman.

Pictured at Insurance Ireland- Milliman CRO forum in September, Niall Butler, Allianz Worldwide Care.

Ireland's Bid document to Host - Insurance Europe General Assembly & International Conference 2016

Pictured at the first planning meeting for the 2016 conference is the Insurance Ireland Members Advisory Committee: Front row left to right – Kevin Thompson, Insurance Ireland, Dick Harnett, OSG, Jennifer Hoban, Insurance Ireland and Brendan McEvoy, Irish Life. Back row left to right – Laura McLellan, Insurance Ireland, Brian O’Neill, Friends First, Damien O’Neill, Allianz, Patrick Nally, RSA, Maurice Cullin, Zurich, Denis Curran, IDA and Ann O’Leary, Insurance Ireland.



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MEMBERSHIP SERVICES OBJECTIVE - TO INCREASE AWARENESS AND PROMOTION OF INSURANCE IRELAND SERVICES AMONGST MEMBERS

Sectoral and European e-NewslettersDuring 2014 Insurance Ireland introduced a series of newsletters that are championed by the Chair of each of our Councils:

These e-newsletters issue shortly after the regular meetings of each Council, typically between three and five times a year. The newsletters feature a note from the Chair highlighting the recent activities of the Council, a note from our CEO Kevin Thompson on the activities of the Secretariat and how those tie back to our strategy as the voice of the industry and the sector to which the newsletters relate, and various updates from relevant Secretariat staff focused on stakeholder and media engagement on behalf of the industry, Committee and Working Group activities and outputs, and relevant publications and events.

This year we have also introduced a quarterly Insurance Ireland European and Global update. This e-newsletter focuses on our work on behalf of our members in Europe and globally. It features updates from the staff of member organisations that represent the industry’s interests on key Committees and Working Groups in Insurance Europe.

Member Contact DevelopmentAs we progressed through the year we actively sought opportunity to engage with our membership base on a broader basis than previously undertaken. We have the highest level of member participation in our Councils, Committees, Working Groups and Forums in the history of the organisation with almost 300 member organisation staff engaged directly with us in delivering on our strategy for the industry.

As indicated, we welcomed c1,700 attendees to our industry and sectoral events and we have significantly grown our communications reach into our membership base through delivery of this calendar. We increasingly communicate with a broader cohort of member staff in fields we have not previously engaged directly with such as marketing, customer services and information.

We will continue to seek new opportunities to deepen our engagement and moreover our value add to our members staff in 2015.

Website EnhancementsIn the second half of the year we designed and delivered a series of infrastructural enhancements to the Insurance Ireland website which allowed us to improve the site’s value as a communication tool.

The website is now restructured in such a way as to facilitate a simplified user experience when searching the member database, events, news and publications.

We are in the process of scoping an online registration system in conjunction with Insurance Europe for delivery by end quarter one 2015 to support promotion of the Insurance Europe General Assembly and International Conference 2016 and to support our own calendar of events for 2015 and onwards.

In 2015, we will also work to improve the web based information we provide to our members customers as part of our Customer Charter.

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Andrew LangfordGroup Chief Executive, FBDChairman, Insurance Ireland Non Life Council

Anthony BrennanCEO Zurich LifeChairman, Insurance Ireland, Life Council

Ciaran McGrettrickManaging Director, Phoenix Group Ireland,Chairman, Insurance Ireland International Council

Dónal ClancyManaging Director, Laya HealthcareChairman Insurance Ireland,Health Council

Vincent SheridanChairman, Insurance Ireland INED Council

MEMBERSHIP SERVICES OBJECTIVE: TO FURTHER DEVELOP THE INSURANCE IRELAND VALUE PROPOSITION TO MEMBERS

Millward Brown Membership ResearchIn November 2013, Membership Services commissioned a research survey conducted on our behalf by Millward Brown amongst our member base.

With respect to how we engage with our members, a core objective of the research was to better understand how to develop and demonstrate our value to our membership base.

We gleaned from the findings of the research that some of our services and the means by which we deliver them required review. This included our website which we have restructured in order to make it more user friendly.

We learned that our members value direct and proactive engagement and we have sought to address this through our calendar of events, range of sectoral e-newletters and quarterly EU updates.

We understand that our members have a need for greater visibility of our public affairs and public relations strategies and workings and our impact in both spheres, and we have addressed this throughout this report and will ramp up communication of our efforts and successes in this regard during 2015 through the medium of our e-newsletters.

Our deliverables against key responsibilities as identified by our members under our mandate as the representative body for the industry both domestically and in Europe/Globally are dealt with in later chapters of this report on an industry wide and sectoral basis.

Anti-Fraud Advertising Campaign on behalf of the IndustryWe know that fraudulent claims cost our insurers c.€200m per annum. As the voice of the industry Insurance Ireland invests in an annual advertising campaign to combat insurance fraud. Millward Brown has tracked awareness of the Insurance Ireland Fraud Hotline - Insurance Confidential and advertising campaign at various stages since 2005 on our behalf. The approach involves a pre & post measure to assess recall of the advertising campaign and impact on attitudes to fraud and fraudulent behaviour in Ireland.

Awareness of our confidential telephone line to report fraud reached an all-time high in 2014 on the back of our most recent TV advertising campaign according to Millward Brown who estimate that 54% of the public are aware of the campaign with some age groups and regions experiencing 60%+ scores.

Our TV advertising campaign has been successful in cutting through, with an above norm recall of the advert. This is a positive score in light of the normative database we were bench marked against for the purposes of the Millward Brown research containing many FMCG brands with significant ad spend.

However, attitudinally the Millward Brown research tells us that we have further work to do to reinforce the negative impact of insurance fraud.

The findings of Accenture’s consumer sentiment research coupled with Millward Brown’s research pertaining to our advertising campaign indicate some consideration should be given to changing the existing messaging of our advertising and/or showing other means by which the Irish public are impacted by fraudulent behaviour.

It's not funny when it's your Money - Insurance Ireland Advertising Theme and Creative.



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To this end we intend to review our advertising campaign in 2015 in the context of the Amárach and Millward Brown research and initiate a tender process for the business with a shortlist of advertising agencies which we are currently collating.

Our primary aims for next year’s campaign are to endeavour to impact on attitudes amongst the general public toward fraud and ultimately to address behaviours. These are complex, ambitious and long term goals but we view these as being integral to our remit as the voice of the industry.

As part of the process of briefing the shortlisted advertising agencies we will engage with our members to collate inputs as to how we could build the next campaign to achieve these goals.

Strategic Alliance PartnershipsInsurance Ireland introduced its Strategic Alliance Partnership proposition to the market in quarter one 2014.

The concept of the Alliance when first proposed took the form of an alignment of our brand with targeted professional services/consultancy firms working within our industry.

We initially offered a limited number of firms the opportunity to co-brand select Insurance Ireland industry activities for an intended period of up to three years - in the lead-in to the Insurance Europe 2016 Conference and General Assembly, with an annual fee attaching to the alliance arrangement.

The Strategic Alliance Partnership proposition has evolved throughout 2014 into a true partnership opportunity for firms seeking to achieve meaningful strategic alignments within our industry.

In the six months to April 2014 an independent & rigorous assessment

of the industry was conducted by PwC on our behalf. This process engaged a broad range of national and international stakeholders across the insurance industry & related sectors. The final product of this exercise was our report Creating the Future for Insurance in Ireland.

Recommendations fol lowing the assessment have now been incorporated into Insurance Ireland’s Strategic Plan to align with our other objectives as per our Strategy House, see page 8.

The evolution of the Strategic Alliance Partnership proposition from inception in quarter one 2014 has mapped the development of our Strategy House for the Industry in conjunction with our Board and Councils, contextualised by the findings of our industry report.

This year saw the development of the Insurance Ireland – Accenture Innovation Strategic Alliance Partnership which will be finalised by contract later this month and formally announced early in 2015. Thus far the alliance has contributed greatly to our calendar of events with Accenture providing high profile speakers for both our Anti-Fraud and Customer 360˚ conferences, undertaking and sharing valuable market research in the area of Fraud, supporting our Membership Services team in the delivery of these flagship events and producing a video about fraud featuring members of our Anti-Fraud Forum.

The Alliance will work this month to constitute the Industry Innovation Task Force which will report to the Non-Life Council and will be populated by representatives from across our membership base, the IDA, Accenture and the Insurance Ireland Secretariat.

We continue discussions with a shortlist of other professional services/consultancy firms and hope to announce further alliances early in 2015.

Insurance Ireland operates a free Insurance Information Service (IIS) which answers questions on all types of insurance for the Irish Public. IIS is a sub division of Insurance Ireland. It also investigates complaints made against our members.

IIS staff liaise between policyholders and our members in areas of dispute, providing assistance to people having difficulty in obtaining car insurance quotations under the Declined Cases Agreement and advise the general public on all areas relating to insurance. In provision of this free service IIS engages with the broker industry, the Consumers Association of Ireland, the Central Bank of Ireland, and Citizen Information Branches.

A breakdown of statistics from IIS for the first six months of the year is provided to the right of the page. IIS notes a continued positive reaction to the resolution of complaint cases to the satisfaction of both insurer and policyholder negating the need for such cases to pursue the Financial Service Ombudsman‘s route.

IIS continues to accept calls from the Financial Services Ombudsman’s Office as part of early intervention in resolving a dispute, before it may escalate to a full review with the office of the Financial Service Ombudsman.

Setanta Insurance On the 17th April 2014, the announcement was made by Setanta Insurance to surrender its insurance licence and dissolve the company. As a result, IIS encountered a substantial volume of contact by phone and email from the following:

• Public • Solicitors • Citizen Information Branches • Broker Industry

Total contacts regarding this matter for the period 17th April to 30th May 2014 was 1,541.

INSURANCE INFORMATION SERVICE (IIS)

2014 Queries from Jan – June 7,430 (20% increase compared to same period for 2013)

2014 Complaints from Jan – June 637 (34% increase compared to same period for 2013)

January • 1096February • 1012March • 1056April • 1522May • 1440 June • 1304

Queries from Previous Years 2010 – 2013 Year 2013 - 12,004 Year 2012 - 10,802 Year 2011 - 11,278 Year 2010 - 11,130

Complaints on Previous Years 2010 – 2013 Year 2013 - 835 Year 2012 - 791 Year 2011 - 803 Year 2010 - 1029

January • Y84% N16%February • Y84% N16%March • Y81% N19%April • Y88% N12%May • Y90% N10% June • Y87% N13%

YesNo

Pictured at Insurance Ireland CEO Breakfast 2013 are Frank Farrell, Insurance Ireland, Taoiseach, Enda Kenny, TD, Fine Gael Leader and Paul Holohan, Insurance Ireland.



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A survey of our members, conducted on our behalf by Millward Brown, showed that the most important function to members is that of representing the industry to key stakeholders. Public policy and advocacy are deemed to be the critical areas for members. Almost 50% of members agreed that it is very important that members are kept abreast of relevant policy and regulator developments, while the majority of members agreed that Insurance Ireland is effective at helping the industry reach agreed policy positions. Identifying areas for legislative or regulatory reform and commenting on draft legislation are also important functions of Insurance Ireland on behalf of members. The majority of our members believe Insurance Ireland has the correct strategy. Encouragingly, one in three members said they would like to get more involved and a further one in two members believe they will be more involved in Insurance Ireland initiatives in the future.

The survey indicated that regulation and legislation are the key areas where Insurance Ireland can provide members with critical advice and updates. These are our main areas of focus, through a programme of direct engagement with stakeholders, media engagement and the production of meaningful statistics and industry information. The following is a round-up of the activities carried out on your behalf throughout the year.

Engagement with CBI Insurance Ireland continues to engage on behalf of members with CBI at all levels of the organisation. At the most senior level, II’s President Mr Sean Casey and II’s CEO meet with the Deputy Governor – Financial Regulation Mr Cyril Roux. There was also a senior meeting between the II Board and CBI Director of Consumer Protection Mr Bernard Sheridan. Such meetings reinforce II’s commitment to engage with the CBI strategically, as well as at a technical level, in the interests of a more productive and constructive relationship. It also ensures

unintended consequences are avoided for both the regulator and regulated entities. CBI PresentationsEarlier this year, Insurance Ireland agreed to run a number of sessions for CBI prudential staff on the challenges facing insurers. The first of the presentations by Aviva, on UK RDR, took place in July. In September, Irish Life and Zurich Life collaborated on a presentation on the domestic life market. In October, a session from Aegon and Prudential covered variable annuities, portfolio bonds and QROPS in the international market. A presentation on the domestic non life market is also planned.

Risk Appetite Discussion PaperThe CBI published a Risk Appetite discussion paper in June and the deadline for responses was 1st September. Most of the questions were aimed at entities that had direct experience of implementing a risk appetite statement. Insurance Ireland’s Regulation, Compliance and Legal (RCL) Committee was of the view that the paper was broadly helpful and should be welcomed by Insurance Ireland, but that there was no need for a more specific response.

Auditor Assurance The Central Bank (Supervision and Enforcement) Act 2013 means that the CBI can require external auditors to provide an opinion to the CBI as to whether an institution has complied with certain requirements. The CBI has advised that this will be implemented on a pilot basis for High Impact insurers for the 2014 financial year - the requirements that auditors will be asked to comment on will be the CBI Solvency II Interim Guidelines. We met with the CBI in May to discuss its proposals in more detail and we have asked the CBI to meet with us again when the exercise is complete to review how successful it has been from their point of view, and to discuss any issues which have arisen for insurers e.g. costs.

INSURANCE IRELAND REPRESENTING THE INDUSTRY IN IRELAND

OUR VISION IS TO BE THE VOICE FOR THE INSURANCE INDUSTRY AND RECOGNISED AS A CENTRE OF EXCELLENCE BY OUR DOMESTIC AND INTERNATIONAL STAKEHOLDER

OUR MISSION IS TO REPRESENT AND SUPPORT THE DEVELOPMENT OF THE INSURANCE INDUSTRY IN IRELAND IN THE INTERESTS OF OUR DOMESTIC AND INTERNATIONAL MEMBERS AND THEIR CUSTOMERS

Fitness and Probity ChangesThe RCL Committee requested additional clarification from the CBI about its proposals to make the following positions Pre-Approval Controlled Functions:

• Chief Operating Officer, and• Head of Claims.

Amended Regulations have now been published.

Variable Remuneration for Sales Staff The CBI published Guidelines on Variable Remuneration for Sales Staff on 25th July. The guidelines apply to all insurers, banks and investments firms and follow recommendations issued in relation to insurers in November 2013. The Guidelines require insurers to review their remuneration structures and the Chairperson of the Board is required to confirm to the CBI that the necessary changes have been implemented by 1st January 2015. Insurance Ireland has highlighted to the CBI that this timescale is extremely challenging and the CBI has indicated that it is open to discussing this with individual insurers.

Solvency II Working Group The committee’s activities in 2014 have, in the main, been focused around the implementation of or the responding to legislation. In late 2013 the Central Bank of Ireland (CBI) published four preparatory guidelines to be implemented variously in 2014 and 2015. The Omnibus II Directive which set the start date of the Solvency II regime as the 1st January 2016 was published in the Official Journal in May 2014. A draft Solvency II delegated act was circulated in January 2014 and further ones in March, July and October 2014. In conjunction with Insurance Europe the Committee was involved in making a number of representations on the delegated

act. Due to the number of areas on which comments were made, eight were identified as priority areas for discussion with the EU Commission. These were focused on the following aspects of the delegated act;

• The credit risk adjustment• The volatility adjustment• The matching adjustment• Extrapolation• Long-term investments• Equivalence• Currency risk• Own funds

When the version of the delegated act for consideration by the EU Parliament and Council were published, in October, progress was visible in a number of these areas.

The European Insurance and Occupational Pension Authority (EIOPA) is issuing Implementing Technical Standards (ITS) and guidelines in two ‘waves’. This first of these, in June 2014, consisted of 6 ITS’s and 32 Guidelines. ‘Wave 2’ is due to be published for consultation in the fourth quarter of 2014 and will comprise 20 ITS’s and 19 Guidelines.

The first set of 32 guidelines contained a total of 521 individual guidelines. The Committee contributed a large number of comments through Insurance Europe who made in total over 1,000 comments to EIOPA.

In the final quarter of the year a number of consultations will be carried out which the Committee will consider and if appropriate make a response. The European Central Bank (ECB) is to publish its proposal for the provision of data from insurers to the ECB; EIOPA will hold a consultation on its proposal for the auditing of reports. The CBI will hold a consultation on national specific templates, ones it will require in addition to

the standard EIOPA quarterly and annual ones. Finally the Department of Finance will hold a consultation on the transposition of EU Solvency II legislation into national law.

The Committee collaborated with the Taxation Committee in considering the taxation implications of Solvency II, which included the commission of a study on this matter by PWC. In total the Committee will have held a total of nine meetings during 2014.

Solvency II and taxThe Finance and Taxation Committee agreed a submission to Revenue in August on the tax consequences of Solvency II. Most of the issues relate to the domestic life closed book of business but there are some areas of broader application. Representatives of the Committee held a follow-up meeting with Revenue on 15th September at which Revenue requested additional information. Discussions with Revenue on this issue are continuing.

Financial Services OmbudsmanInsurance Ireland engaged with the Financial Services Ombudsman in relation to the new legislation giving the FSO the power to name individual providers in regular reports.

The first bi-annual report on the new basis was published on 26th February and eight insurers were named. In advance of publication Insurance Ireland had formulated a (reactive) PR strategy but in the media coverage of the FSO’s report, there was very little focus on the insurance industry.

The FSO subsequently wrote to us to advise that his next report will be published in early 2015 covering the year 2014. We plan to meet with the FSO in advance of this.

THE VOICE OF THE INDUSTRY INSURANCE IRELAND REPRESENTS 95% OF THE DOMESTIC MARKET AND 80% OF THE INTERNATIONAL LIFE MARKET



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FATCARevenue published its FATCA Guidance Notes in October following extensive consultation with industry, including Insurance Ireland. They have also advised that Insurance Ireland will be asked to participate in an Automatic Exchange of Information industry consultation group which will look at issues arising from the implementation of the OECD Common Reporting Standard and other initiatives.

Shared Services – Industry StatisticsThe provision and publication of statistics is an important part of Insurance Ireland’s work. Insurance Ireland publishes this data in its Factfile, Annual Report and other key reports. Statistical information gathered by Insurance Ireland is used by members on a regular basis as it covers key data on life and non-life market trends.

Insurance Ireland issued 3rd quarter headline statistics for Life and Non-Life domestic members in October. Results show a year-on-year increase of around 9% under life premium on APE basis. Under Non-Life, results show a year-on-year overall increase of around 0.3% with motor segment recording an increase of 5%. Insurance Ireland is currently exploring solutions to provide enhanced market intelligence to members in a centralised place - a solution is expected to be in place by Q2 2015.

A revamped version of our FactFile was issued in September. This forms part of a series published by Insurance Ireland annually providing the key facts and figures on the industry in Ireland. The scope of this year’s publication was increased to include statistics for International and Health members for the first time.

New Industry Wide Independent Non-Executive Director (INED) Council Insurance Ireland has recently established an INED Council. At its first meeting in June the INED Council agreed the following terms of reference:

• Promote best practice for insurance industry INEDs

• Act as a sounding board for the various regulatory entities in relation to existing and proposed legislation impacting on insurance INEDs

• Organise appropriate training for insurance INEDs

• Act as a networking hub for insurance INEDs

• To build a community for II member company INEDs, supported by an annual event

The first INED annual event is being planned for May 2015. We will be jointly hosting the industry’s inaugural INED conference with the Central Bank of Ireland on the 14th of May 2015.

Vincent Sheridan, Chairman, Insurance Ireland INED Council

Pensions Policy InitiativeThe key policy initiative during 2014 was Insurance Ireland’s response to the OECD’s recommendation that Ireland introduce a universal pension system.

We firstly established an Academic Advisory Panel which includes the following social security / pensions policy experts: • Susan St.John, University of Auckland• David Laibson, Harvard Business School• Constantin Gurdgiev, Trinity College

Dublin Business School• Jeff Brown, University Illinois, Chicago • Colm McCarthy, University College Dublin

The Academic Advisory Panel reviewed Insurance Ireland’s proposals to reach out to the key stakeholders in Irish society, including trades unions, IBEC and NGOs with a view to taking the first step towards building a national consensus on what needs to be done.

Insurance Ireland developed, with the support of Tor Financial Consulting (who had assisted the OECD in its Review of the Irish Pension System), our own proposals as to how the Government should meet the challenge.

Insurance Ireland then hosted a Stakeholder Workshop in Dublin Castle on 11th February where representatives from Government, IBEC, ICTU and SIPTU discussed with leading economists the options available to implement a universal pension system.

This was followed in September of this year with a further Workshop in Dublin’s Marker Hotel to launch the final Insurance Ireland report and to host a discussion with stakeholders, the industry and policy specialists with a view to identifying the first steps to a universal pension.

Phasing out of Pensions LevyInsurance Ireland also welcomed the Minister for Finance’s statement in the Budget that the pensions levy would be phased out by the end of 2015.

Kevin Thompson, Chief Executive, Insurance Ireland, said, “Insurance Ireland was very disappointed last year at the continuation of the pensions levy, which was widely regarded as a serious disincentive to saving for retirement. The country has public debt of €192bn but this becomes insignificant when you take account hidden state pension liabilities estimated at €440bn. Our population is continuing to grow and people are living longer into retirement, and clearly we need to address the issue of pensions in a very fundamental way. Government wants people to save for retirement to reduce the significant burden on the state, but the pensions levy ran entirely counter to achieving that goal. Today’s announcement in relation to the ending of the levy is very significant and will encourage more people to save for their pension.”

The positioning of Insurance Ireland as a key commentator on pensions issues is one of the strategic goals in the PWC report.

Pensions CommitteeRevenue Large Cases earlier this year established a joint Revenue/pensions industry forum to discuss technical issues. Insurance Ireland representatives are participating along with other industry stakeholders. Revenue personnel also attended a meeting of the Pensions Committee in October at which useful progress was made towards agreeing new procedures to streamline the scheme approvals process.

Following submissions from Insurance Ireland, the Minister for Finance agreed that the Revenue Commissioners will

INSURANCE IRELAND REPRESENTING THE LIFE INSURANCE SECTOR

Life Sector MembersAcorn LifeArk LifeAviva Life & PensionsECCUEquitable LifeFriends First LifeGenworth Financial AssuranceIBRC AssuranceIrish LifeLondon General LifeNew Ireland AssurancePhoenix IrelandQuinn-life DirectRoyal London t/a Caledonian LifeScottish FriendlyStandard LifeSun Life of CanadaZurich Life

Pictured at the Pensions Policy Initiative are from left to right Gerry Hassett, Managing Director, Irish Life, Joan Burton, Tánaiste and Minister for Social Protection and Kevin Thompson, CEO, Insurance Ireland.



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allow access to the Approved Retirement Fund option for all holders of Buy-out Bonds arising from DC pension schemes regardless of the date of transfer.

Members of the Pensions Committee also assisted in preparing a response to the Department of Social Protection consultation on the review of the IORPs Directive which proposes changes to the governance and information requirements for pension schemes. The Insurance Ireland response queried whether some of the proposals were proportionate, particularly for insured and small schemes.

Genetic Testing and Life Assurance The Disability Act 2005 introduced a ban on access to genetic test results by life assurers and provided that the legislation should be reviewed after a number of years in operation. This review is being progressed by the National Disability Authority which held a seminar on 30th September to initiative a consultation.

Dr. Paul Gueret, who is Chief Medical Officer of a number of life offices, gave a presentation on the practical experience of insurers in implementing the legislation and other speakers included Garrett O’Neill, Office of the Data Protection Commissioner, Aisling de Paor, Lecturer in Law at Dublin City University, Dr. David Barton, National Centre for Medical Genetics and Avril Daly, the Genetic and Rare Disorders Organisation.

Insurance Ireland’s submission was progressed by the Genetics Working Group comprising underwriters from four member companies. The submission highlighted that although the ban on access to genetic

test results has not had a significant impact to-date, any restrictions on access to family history information could have a negative impact on the cost and/or availability of covers and particularly serious illness cover. Insurance Ireland will continue to participate in this important debate, particularly if any changes to current legislation are proposed by Government.

Unclaimed Life Assurance Policies AdvertThe annual Unclaimed Life Assurance Policies advertisement was published by Insurance Ireland on behalf of members on 1st October in the Irish Times and Irish Independent and on 3rd October in Iris Oifigiuil.

Jennifer HobanLife Assurance Manager,

Insurance Ireland

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Anthony BrennanCEO, Zurich Life

Chairman, Insurance Ireland Life Council

Michael Curtin, Operations Executive - General Sector

In 2014, the General Sector team was expanded with the appointment of Michael Curtin as Operation Executive. Michael joins us from Allianz where he worked in underwritting since 2009.

Insurance Ireland - OPW Memorandum of Understanding on Flooding Insurance Ireland launched a Memorandum of Understanding (MOU) on Flooding in March at a joint press conference with Minister Brian Hayes TD, Minister of State at the Department of Public Expenditure and Reform with Special Responsibility for the OPW. The MOU went live in June.

Under the terms of the MOU the OPW will share flood defence data with Insurance Ireland so that members can take this data into account when assessing flood risk. The MOU is the start of a process which will help our members make flood insurance more widely available in areas benefiting from flood defences built to the desired standard of 1:100 years. The OPW has so far provided data on 12 completed flood defence schemes with more to follow.

Insurance Ireland met the new Minister of State for the OPW and IFSC, Simon Harris TD, in October of this year. Our aim in engaging with Minister Harris was to build on the Insurance Ireland/OPW MOU and secure more flood defence information.

In October, Insurance Ireland participated in the OPW’s National Stakeholder Meeting on their Catchment based Flood Risk Assessment and Management Programme, i.e. reviewing progress with their flood mapping prior to production of OPW Flood Risk Management Plans in 2015 in line with the EU Floods Directive.

Our endeavours in the area of flooding are aimed at ensuring that robust flood defence strategies and adequate investment in flood defences are put in place so that insurers can provide cover against the risk of flooding rather than against inevitable events.

Shared Services Effective Management and Quantification of Flood Risk ProjectInsurance Ireland is participating in an industry project which would help insurers to effectively manage and quantify flood risks at high spatial and temporal resolutions which aligns directly with the current and likely future needs of our Insurance industry.

A project team comprising researchers and engineers from Universities and organisations like DCU, IBM, Marine Institute and a representative from Insurance Ireland is in place to progress this project. The project is underway and currently at analysis phase.

Office of Public Works Flooding ConferencePaul MacDonnell, Insurance Ireland’s Head of EU Regulatory Affairs & Planning, presented an overview of the dangers posed by inappropriate public policy concerning insurance at the Office of Public Works Flooding Conference at Dublin Castle on 10th April.

Winter StormsClaims costs resulting from the storms between mid-December 2013 and February 2014 amounted to approximately €157m. There were just over 30,000 claims in this period with approximately 70% of the claims by number and cost resulting from the storms in February, which climaxed with Storm Darwin on 12th February. Insurers rose to the logistical challenge of dealing with 30,000 claims in such a short period of time and worked hard to ensure that policyholders’ claims were handled quickly.

INSURANCE IRELAND REPRESENTING THE GENERAL INSURANCE SECTOR

General Sector MembersACE EuropeAIGAllianzAmtrust InternationalAviva InsuranceAXADAS GroupDeCare DentalEcclesiasticalEuro InsurancesFBDGenworth Financial InsuranceIPB InsuranceLiberty InsuranceLondon General InsuranceMapfre AssistenciaRSA InsuranceTravelers InsuranceZurich Insurance

Pictured from left to right : Jerry McGrath, Business Product Manager, FBD Insurance, Nigel Dawkins, Risk Control Manager, Commercial Underwriting, RSA Insurance, Zoe Panayotou, GIS Analyst ,Product Underwriting, Zurich Insurance, John Carey, Underwriting, Allianz, John Dooley ,Head of Commercial Property, Liberty Insurance, Liam Basquille, Principal Officer, OPW, Michael Horan, Non-Life Insurance Manager, Insurance Ireland, Vincent Hussey, Senior Engineer, OPW, Tom Bolger, Assistant Chief Engineer, OPW and David Parke, GIS Analyst, Aviva Insurance.

Paul McDonnell, Head of EU Regulatory Affairs & Planning, Insurance Ireland at the Office of Publics Works Flooding Conference



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SetantaSetanta Insurance Company Limited announced in April that it had surrendered its insurance business licence to the Malta Financial Services Authority, that Setanta was immediately dissolved and that a liquidator of the company had been nominated. Setanta was not an Insurance Ireland member.

Insurance Ireland’s advice to Setanta policyholders was that they should arrange new motor insurance immediately. We issued press releases saying that our members would make every effort to assist Setanta policyholders to do this. The liquidator cancelled all remaining policies at the end of May.

Insurance lreland has liaised with all relevant stakeholders over the past few months, i.e. the liquidator, the Central Bank of Ireland and the Departments of Finance and Transport. At the time of writing it appears as if the Insurance Compensation Fund will be triggered. It is unclear as to when this will happen as the liquidator’s work is ongoing and the extent to which he will discharge claims is unknown. As things stand under the relevant legislation, the Insurance Compensation Fund will part-discharge claims up to 65% or €825,000, whichever is the lower with payments to companies not covered by the Insurance Compensation Fund.

The fall-out from Setanta affected the Motor Declined Cases Agreement and our Information Service in general both of which Insurance Ireland put at the disposal of Setanta policyholders. We processed 347 cases under the Agreement in the first half of 2014 compared with 133 cases over the same period in 2013. The increase was largely due to Setanta.

There has never previously been a case in Ireland where an insurer has gone into liquidation without having first met its obligations to policyholders. An

Administrator has been used a number of times to operate a company on a going concern basis and the Administrator process requires the Administrator to meet all obligations to a company’s policyholders. Quite apart from the immediate claims issues associated with Setanta, there are also important medium-term issues to explore, e.g. how best to address the shortcomings in existing arrangements whereby an insurer regulated in Malta or similar jurisdictions and transacting business exclusively in Ireland can fail, potentially leaving a claims bill with Irish insurers and policyholders.

We will be engaging further with the Department of Finance and other stakeholders on these matters over the coming months and will be lobbying for changes in the legislative framework. Anti-Fraud.Our Anti-Fraud Forum continued to be very active in 2014 and we now have separate Forum meetings dealing with claims fraud and sales/underwriting fraud. We held a training day for Special Investigation Unit staff in April. Our health insurance members joined the Anti-Fraud Forum in June. In November we held our second annual Insurance Fraud Conference, which approximately 250 people attended. There were presentations at the conference on the Insurance Fraud Enforcement Department within the UK police, liability claims fraud, health insurance fraud, the impact of cybercrime and on a survey outlining consumer sentiment in Ireland on insurance fraud. Our anti-fraud advertising campaigns formed the backdrop to the Forum’s activity with regular advertising on TV, radio and billboards promoting the anti-fraud hotline, Insurance Confidential.

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Andrew LangfordGroup Chief Executive FBD,Chairman, Insurance Ireland

Michael HoranNon-Life Insurance Manager,Insurance Ireland

Shared Services Insurance LinkThe InsuranceLink system continues to operate and has been an efficient check for possible fraudulent claims since 1990. The database helps users identify possibly fraudulent claims. All claims involving personal injury in motor accidents, employer’s and public liability insurance as well as written-off vehicles, household, commercial property, personal accident and travel insurance are run through the Insurance Link system.

A project to enhance the data quality of the system is currently underway and all Insurance Ireland non-life members are participating in this project. It is envisaged that with an improved data set in hand; members will be able to derive better matching results from the system at the end.

Shared Services Integrated Information Data Service (IIDS) The Integrated Information Data Service (IIDS) project continued in 2014 with the aim of delivering a real time technology service that electronically integrates core data with industry members’ underwriting and claims systems. The project covers two streams 1) ‘No Claims Discount’ (NCD) and 2) Penalty Points (PP). The NCD stream went live in 2013 and most of the members have NCD test & production connectivity at this stage. Around 40% of the market is already live with most of the companies aiming to upload their data by Q1 2015 on the NCD system.

We have also made good progress with the PP module, signing an agreement with the Department of Transport and testing connectivity to the Department’s system with the aim of going live with the PP stream in early 2015.

Shared Services Uninsured DrivingThe Automatic Number Plate Recognition (ANPR) system enables Garda to identify uninsured vehicles on roads via their ANPR-equipped vehicles. The system includes fleet and motor trade vehicles via the National Fleet Database (NFD). New measures are being put in place to the system to manage uninsured driving efficiently.

Periodic Payment OrdersInsurance Ireland met the Departments of Justice and Finance in September. The Department of Justice chairs an Inter-Departmental Working Group charged with examining the feasibility of implementing Periodic Payment Orders (PPOs) for both State and private defendants. Having previously made a submission and completed a questionnaire for the Working Group, we once again outlined our position that we see the advantages of PPOs, would advocate them as a solution for State Claims Agency cases where security is not an issue but point to the unacceptable security issues of depending on individual general insurers over the long-term for PPOs.



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Recoverable Benefits and Assistance Scheme We liaised with the Department of Social Protection throughout 2014 in an effort to ensure the orderly implementation of this scheme, which commenced in August. The Recoverable Benefits and Assistance Scheme requires insurers to obtain certificates of benefit paid to claimants before insurers pay personal injury claims so that the relevant benefits can be refunded by insurers to the Department. Insurance Ireland brought the concerns of members to the Department of Social Protection and worked with the Department in an effort to keep any problems and delays to a minimum.

Public Consultation on the Operation of the PIAB ActsWe responded in July to the Public Consultation on the Operation and Implementation of the Personal Injuries Assessment Board Acts 2003 and 2007. We commented on the scope, powers and operation of the Acts and made some suggestions as to how the legislation could be improved to address problems such as non-attendance by some claimants at Injuries Board arranged medical examinations and the practice on the part of some claimants of not providing full details of their claims for special damages etc.

Central Bank’s Household Property Claims InspectionFollowing on from the above inspection in 2013 we had constructive discussions with the Central Bank in quarter one with particular reference to retentions. We explained why insurers operate this practice, the usefulness and legitimacy of retentions and how insurers have made their documentation on retentions more transparent. The matter has now been closed out.

CP73 – Consultation on Requirements for Reserving and PricingThe Central Bank published the final requirements in May. Insurance Ireland had made a submission in December 2013 and some of our points were taken on board, e.g. the text on pricing was deleted from the final requirements.

European Court of Justice Motor CaseThe European Court of Justice delivered its judgement in September in the Slovenian ”Vnuk” case – an accident in a farmyard where a tractor with a trailer reversed into a ladder on which the claimant was climbing, thereby injuring him. The judgement appears to bring accidents on private property into the scope of the minimum insurance requirements of the Motor Insurance Directives. We are currently liaising with the Department of Transport on the implications of the judgement for Irish road traffic legislation, in particular the compulsory insurance requirements of same.

Engagement with MediaIn line with one of Insurance Ireland’s key strategic objectives of proactively promoting the insurance industry, we made numerous contributions to the print and broadcast media on issues such as bad weather claims costs, fraud, motor and health insurance. This included contributions to RTE’s Morning Ireland, RTE TV News, RTE Radio News and Today FM.

INSURANCE IRELAND REPRESENTING THE INTERNATIONAL INSURANCE SECTOR

Engagement with IDA New IDA Chief Executive Martin Shanahan made time during his first week in his new role to meet with Insurance Ireland’s International Council on 3rd September. Mr. Shanahan said that the IDA fully appreciated the importance of insurance and praised the Insurance Ireland commissioned PwC report’s contribution to discussions.

Insurance Ireland and the IDA have recently agreed Terms of Reference which reflect their common interest in promoting the advantages of Ireland as a location for cross-border insurance business and in developing centres of innovation and which set out the principles of how II and the IDA will work together to achieve these objectives.

Engagement with Minister Simon Harris, TDDuring the year, Insurance Ireland had a number of engagements with Minister Harris, who is a key stakeholder for the International Industry. Insurance Ireland’s CEO, Kevin Thompson participated in IFSC Ireland meeting with Minister Harris, the new Minister with responsibility for the IFSC.

Issues highlighted included:

• The impact of regulation;• The personal tax regime and difficulties of

attracting employees from overseas; and • The possibility of having an annual

Financial Services Bill to deal with regulatory issues.

On October 2nd a further bilateral meeting was held between Minister Harris & II at the Ministers office in Leinster House. The meeting was productive and focused on both a domestic and international agenda with the Minister being a key stakeholder for II and an example of where II can bring its domestic & International advocacy strength together. On International, the

Minister was provided with a detailed brief of the II commissioned PwC report and the actions II was taking with the support of its membership to help make the recommendations contained within the report a reality. In addition to discussing the report, specific agenda items included regulation and the current impediment of the personal tax regime in attracting employees to Ireland to help start new ventures within existing companies based here.

The Minister confirmed he is in the process of drafting a strategy for the IFSC, which would be incorporated into the program of government, it is envisaged that publication will not be until the first quarter of next year. In highlighting the ground covered by II in this area through the work carried out already to produce the PwC report, the Minister kindly agreed to accept II’s offer to provide the necessary resource and further information that supported the PwC report to help as a key stakeholder develop the governments IFSC strategy. In December, the minister attended a meeting of the Insurance Ireland International Council which provided Industry CEO’s with an opportunity to discuss a wide range of topics directly with the minister.

Engagement with City of LondonII representatives recently had a bilateral session with City of London represented by Paul Sizeland - Director of Economic Development, & Audrey Nelson – Senior European Officer, to discuss what common European agenda items could the City of London collaborate on that would lend support to the work Insurance Ireland & the Association of British Insurers are working on via Insurance Europe or on a bilateral basis.

Italian tax assetIn November of 2013, Insurance Ireland and FSI facilitated a meeting of members and the CBI to discuss CBI proposals in relation to the Prudential treatment of

International Sector MembersAegon IrelandAllianz ReAllianz Worldwide CareAugura LifeAXA Life EuropeAXA MPSBarclays AssuranceBarclays InsuranceCanada Life EuropeDarta Saving LifeEurop AssistanceGenerali PanEuropeHansard EuropeHawthorn LifeHSBC LifeIntesa Sanpaolo LifeLawrence LifeMetLife EuropeNew TechnologyPartner RePrudential InternationalScottish Mutual InternationalSEB Life InternationalSkandia LifeSt. James’s Place

Sean Casey, President, Insurance Ireland, Minster Simon Harris, TD and Ciaran McGettrick, Managing Director, Phoenix Group



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Italian tax assets. The discussions which took place subsequently were lengthy and technical in nature and required significant input from members which was facilitated with the assistance of Milliman and KPMG.

The CBI withholding Tax - Guidance and requirements have now been published. The final requirements were less prescriptive than those originally envisaged but do require the board of the insurer to ensure that it is happy with the arrangements that are in place. The exercise represented a broadly constructive engagement between industry and the CBI which we hope will set the tone for future dealings.

Variable Annuity Working GroupInsurance Ireland established a Variable Annuity Working Group last year to provide a forum for providers to discuss issues of common interest and to engage with the CBI on what is a key area for the international market. The Working Group comprises eight providers and has had a number of meetings with the CBI during the year to discuss the CBI’s stress testing exercise and its plans for a VA risk monitor.

The CBI issued its risk monitor requirements in October. The Working Group had some concerns about the resources necessary to implement the changes and, following further representations, the CBI agreed to streamline some of the requirements by requiring less frequent stress tests and allowing companies not currently in a position to provide daily attribution information to provide it weekly. This is a positive outcome for providers and the working group is now moving on to consider the CBI’s proposed Solvency II National Specific Templates relating to VA business.

SARPThe Minister for Finance announced in the Budget that the Special Assignee Relief Programme, which was introduced with the aim of reducing the cost to employers of assigning skilled individuals in their companies from abroad to take up positions in their Irish operations, is being extended to 2017. The upper €500,000 salary threshold is being removed and certain other requirements have been relaxed.

When the SARP consultation took place earlier in the year, Insurance Ireland’s submission highlighted the PwC report findings which reflected input from insurance and reinsurance company CEOs and senior executives that the high income tax barrier was a deterrent to the employment of non-national executives. This point was also made by Insurance Ireland at two subsequent meetings with Minister Harris and we are pleased that Government has recognised industry concerns.

UK Chargeable Event Legislation In April Insurance Ireland hosted a presentation by the UK HMRC on the UK (life assurance) chargeable event legislation. The UK officials described their audit approach and answered a range of policy questions. Seventeen insurers were represented at the session and feedback has been positive.

Jennifer HobanLife Assurance Manager,

Insurance Ireland

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Ciaran McGettrickMD Phoenix Group Ireland

Chairman, Insurance Ireland International Council

John McCrossan, HM Revenue and Costumes, speaking at the UK Chargeable Event.

INSURANCE IRELAND REPRESENTING THE HEALTH INSURANCE SECTOR

Bed ChargesInsurance Ireland’s efforts in 2014 were focused on addressing the lack of clarity around public hospital bed charges. Insurance Ireland’s position is that existing bed charges are deemed to remain in place and were not altered by virtue of the provisions of the Health Amendment Act 2013. The HSE do not agree and also appear to believe that the revised charging structure permits the billing of chairs, recliners and trollies too. At the time of writing Insurance Ireland are seeking to establish concrete rules and clarity around bed charges so that insurers have certainty in terms of pricing.

Lifetime Community RatingLifetime Community Rating (LCR) will be implemented on 1st May 2015. The LCR Working Group liaised with the Department of Health over the second half of 2014 on technical points of detail. The Working Group has worked through the LCR Regulations with the help of the Department’s feedback to ensure that LCR is implemented in an orderly fashion.

Private Health Insurance PackageA special meeting of the Health Council was held in November at the request of the new Minister for Health, Leo Varadkar TD, so that the Minister could brief the Health Council on his Private Health Insurance Package. The key measures of this package are as follows:

• A reduction in stamp duty• Co change in TRS• Lifetime Community Rating• A reduction in the Health Insurance

Authority levy• Young adult rates• Implementation of the Pat McLoughlin

reports• Refining the Risk Equalisation Scheme.

Insurance Ireland subsequently released a statement welcoming the Minister’s engagement with the industry.

Health SubmissionsInsurance Ireland made a submission in May to Pat McLoughlin on the Review of Measures to Reduce Costs in the Private Health Insurance Market 2013. The second McLoughlin report was published in November.

Insurance Ireland responded in May to the Department of Health on their Public Consultation on the White Paper on Universal Health Insurance. Since then Minister Varadkar has made public statements which suggest that UHI is off the Government’s agenda for the foreseeable future.

We made our pre-budget submission to the Department of Finance in July. A significant proportion of our submission was devoted to health insurance. We highlighted the bed charges and tax relief issues, the effect of these measures on the affordability of health insurance and the potentially increased burden on the State as people drop out of the market.

Health MembersAviva HealthGloHealthLaya HealthcareVHI Healthcare

Pictured are - Donal Clancy, Managing Director, Laya Healthcare, Minister for Health, Leo Varadkar, T.D., and Kevin Thompson, CEO, Insurance Ireland, following a meeting between the Minister and the Insurance Ireland Health Council.



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eClaimsIn 2010 Aviva Health, Laya Healthcare and VHI Healthcare formed the Multi-Insurer Group to develop and promote electronic submission of claims by healthcare providers to insurers. Following the development of a new eClaims standard, key benefits such as improved operational efficiencies, enhanced payment/cashflow and faster processing of claims are now being realised by the participating insurers and healthcare providers. Ireland is one of the last OECD countries to adopt an electronic claims submission standard. The MIG reports to the Health Council and is supported by a project manager and by the Insurance Ireland secretariat.

The promotion and ongoing rollout of eClaims across the healthcare industry has been a key focus for 2014. This has seen the piloting of eClaims by three providers – the Beacon, Euromedic and St James’. Furthermore,a number of Scan Centres have fully implemented eClaims during the third quarter of 2014.

The eClaims launch phase has included the establishment of a dedicated ehealth claims website and media coverage of the project. Rollout and stakeholder engagement has been supported on a continuous basis with the private and public pilot hospital sites. The participating insurers are already processing electronic claims. Further information on eClaims is available on www.ehealthclaims.ie or by emailing [email protected]

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Dónal ClancyManaging Director Laya Health CareChairman, Insurance Ireland Health Council

Michael HoranNon-Life Insurance Manager,Insurance Ireland

In order of appearance left to right: John McCall (Head of Provider Relations , laya healthcare); Michael Horan (Non-Life Manager, Insurance Ireland); Noelle Bourke (Senior Health Claims Manager, Aviva Health); John Creedon (Director - Claims, Vhi Healthcare)

INSURANCE IRELAND REPRESENTING THE INDUSTRY IN EUROPE

The first half of 2014 saw Insurance Ireland expand on its involvement with EU and global issues at Insurance Europe, the Global Federation of Insurance Associations (GFIA) and in our advocacy with the Irish Government. Insurance Ireland now has representatives at the following Insurance Europe and GFIA Committees:

Our primary areas of concern for 2014 were: • Solvency II• International Capital Standards• Distributions (IMD, PRIPS and MiFID)• Data Protection• Financial Reporting• Long-term investment• Anti-Discrimination

Providing Insurance Ireland’s input to help develop the following positions taken by Insurance Europe and GFIA advocating at a European and Global level on behalf of our sector.

Solvency II: During the first quarter Insurance Europe prioritised eight proposed SII Delegated Acts that were of concern. These were: the credit risk adjustment, the volatility adjustment, the matching adjustment, extrapolation, long-term investments, equivalence, currency risk and own funds. Following input by and discussion

with Insurance Ireland Insurance Europe agreed that its letter to Klaus Wiedner, Head of the Insurance Unit at the European Commission, would also indicate that contract boundaries are a concern, an item of great importance for our members and one we now had the support of Insurance Europe on.

The Delegated Acts were published in October and in line with an element of Insurance Irelands (II’s) strategy, II provided input to Insurance Europe as their focus shifted to seeking changes that would enhance the ability of insurers to invest in long-term assets – infrastructure and securitisations in particular – and to the interaction of SII with an emerging International Capital Standard.

International Capital Standards: In January the IAIS published proposals for the development of a Basic Capital Requirement (BCR) which is the first step of a long-term project to develop risk-based, group-wide global capital standards. The second step is the development of Higher Loss Absorbency (HLA) requirements to apply to Globally Systemic Important Insurers (G-SIIs), due to be completed by the end of 2015.

Insurance Ireland comments emphasised our understanding that the BCR will apply only to G-SIIs and that compliance with SII would be deemed compliance with it. As with Solvency II our input along with other national associations helped with our colleagues in Insurance Europe and GFIA shift to the IAIS’ broader project for an International Capital Standard (ICS), as this will apply to a wider range of companies, and to enhancing insurers’ long-term, liability-driven approach to investments.

Distribution (IMD, PRIPS and MiFID):During the first quarter Trilogue (Parliament, Commission and Council) discussions led to an agreement to amend the original Insurance Mediation Directive (IMD 1) through the revised Markets in Financial

Insurance Europe CommitteesName Title CompanyKevin Thompson Executive Committee Insurance IrelandPaul MacDonnell Single Market Committee Insurance IrelandJulianne Lee Economic & Finance Committee MetLifeDarragh Graham Solvency II WG New Ireland Eanna O’Hogartaigh Financial Reporting Steering Group &

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Lisa Bolger International Affairs & Reinsurance Committee

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Jennifer Hoban Life Committee Insurance IrelandMichael Horan Non-Life Committee Insurance IrelandPatrick Nally Communications and PR Committee RSAAjay Pathak Economics and Statics Committee Insurance Ireland

GFIA: Lukas Ziewer Global Capital Task Force MetLife

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Instruments Directive (MiFID 2) allowing each Member State to decide whether to prohibit or further restrict the offer or acceptance of fees, commissions or non-monetary benefits from third parties in relation to the sale of insurance investment products.

Data Protection: It was clear during the first quarter that progress on the regulation would be slowed by a failure to reach agreement on provisions relating to profiling. Insurance Ireland and Insurance Europe supported the position of most governments that the provisions on profiling should follow the 1995 Directive principles and limit their scope to automated decision making.

Despite the Council’s slow progress under the Greek Presidency, the Justice and Home Affairs Council reached a partial general approach on the chapter of the proposed EU General Data Protection Regulation on international transfers at its meeting on 6th June.

There is currently a possibility that, under the Italian Presidency, the regulation’s applicability to the public sector could be removed. If this were to occur the proposed regulation could make more rapid progress.

Financial Reporting: During the first quarter of 2014 there was the emerging concern relating to the work of IAIS on valuation — part of which will concern the capital component of the common framework for supervising international groups (ComFrame) - conclusions of which are likely to inform both the development of the ICS and the basic capital requirement (BCR).

In dialogue with the other national insurance associations via Insurance Europe concern was raised that principles of proportionality and materiality should be embedded into the IAIS’s work and argued that companies should be able to apply simplifications to the methodology, such as excluding business units or risks

that have a non-material impact on the total valuation. Insurance Europe advocated that technical provisions should reflect insurers’ business model to avoid artificial volatility and pro-cyclical effects.

Moving on to the third quarter and in consultation with the national associations Insurance Europe advocated the concerns with the approaching finalisation of IFRS 4 that the IASB was seeking to achieve before the end of October. It was indicated that the IASB did not plan to accept key elements of the industry’s proposals. It was noted that the IFRS 9 endorsement process was scheduled to begin in the Autumn and that while the IASB had provided reasonable solutions for non-par products, for par products it had not yet accepted industry proposals. Advocacy is ongoing to establish the link between assets and liabilities and therefore between IFRS 9 and IFRS 4.

Anti-Discrimination / Gender Directive: After consultation with Insurance Ireland and other national associations on 15th May Insurance Europe sent its reply to an EC questionnaire on the implementation of the Gender Directive and the effect of the European Court of Justice (ECJ) Test-Achats ruling. It presented the implementation of the Gender Directive by insurers before and after the ECJ ruling and explained the implications of the ban on the use of gender as a risk factor. Insurance Europe stressed that, whilst insurers are fully compliant with both the rules of the Gender Directive and the ECJ ruling, it is difficult to provide reliable, quantitative data about the impact of the change, as many other factors may have influenced products in addition to the move to unisex pricing, such as legal and regulatory developments at national and EU level.

The EC is expected to follow up on this consultation with a stakeholders’ conference in September before the publication of its report, which is expected at the end of 2014.

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Lisa BolgerInternational Affairs & Reinsurance Committee

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Lukas ZiewerGlobal Capital Task Force

Patrick NallyCommunications and PR Committee

INSURANCE IRELAND DIRECTORY OF MEMBERS

Life MembersAcorn LifeArk LifeAviva Life & PensionsECCUEquitable LifeFriends First LifeGenworth Financial AssuranceIBRC AssuranceIrish LifeLondon General LifeNew Ireland AssurancePhoenix IrelandQuinn-life DirectRoyal London t/a Caledonian LifeScottish FriendlyStandard LifeSun Life of CanadaZurich Life

Health MembersAviva HealthGloHealthLaya HealthcareVHI Healthcare

Associate MembersAccentureAssociated Loss AdjustersCunningham LindseyDeloitteInternational Financial Data ServicesIrish Progressive ServicesKennCo UnderwritingLloydsOSGProAdjustThornton & PartnersLiberty Specialty MarketsCAAWilliam FryMilliman

International MembersAegon IrelandAllianz ReAllianz Worldwide CareAugura LifeAXA Life EuropeAXA MPSBarclays AssuranceBarclays InsuranceCanada Life EuropeDarta Saving LifeEurop AssistanceGenerali PanEuropeHansard EuropeHawthorn LifeHSBC LifeIntesa Sanpaolo LifeLawrence LifeMetLife EuropeNew TechnologyPartner RePrudential InternationalScottish Mutual InternationalSEB Life InternationalSkandia LifeSt. James’s Place

Non-Life MembersACE EuropeAIGAllianzAmtrust InternationalAviva InsuranceAXADAS GroupDeCare DentalEcclesiastical

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