The PRA has proposed that all Solvency II firms should produce a
diversity policy, to improve decision-making at board level, and
wants comments by 22 Sep 2017.
The regulator is suggesting that it would require all Solvency
II and large non-directive firms to have a diversity policy,
setting out how the firm will seek 'a broad set of qualities and
competences when recruiting board members' and 'promote diversity
among board members'.
The PRA has stressed that it only wants to introduce measures
that will result in better risk management, and that this is a
genuine consultation - this measure will only be implemented if
insurers believe that it will make a difference.
policy briefing »
Closing date for the consultation is 21 Sep
The consultation can be found on the Prudential Regulation
Beyond the Boardroom
Under existing regulation, firms must have over twenty mandatory
policies, covering topics from remuneration to outsourcing, so how
much difference will another policy make?
Clearly, policies alone cannot create a diverse and inclusive
Barriers to making diversity and inclusion a reality in
insurance include a lack of diversity among key groups of experts
such as actuaries. This is often exacerbated by firms and
regulators prioritising the measurement of capital requirements
over a wider approach to effective risk management, which in turn
leads to an assumption that a high level of financial expertise is
needed for everyone involved in overseeing Solvency II
Ways in which these challenges can be overcome include:
Greater clarity about job roles,so that, for example, the
seniority of part-time roles is recognised properly and are not
seen as less important than full-time roles that bear similar
levels of responsibility.
Diversity and Inclusion: Some Common Mistakes
- Not developing a business case for diversity and inclusion
- Assuming there is a 'quick fix'
- Not making leaders accountable for diversity and inclusion
- Not using data to find out where real barriers lie
- Not measuring progress properly
- Assuming one approach fits across all cultures
- Treating diversity and inclusion in a silo
- Only addressing diversity and inclusion at leadership
- Neglecting flexible working
Lessons from PwC's 'diversity
Action to change culture in settings that are different from the
usual business environment,such as the Lloyd's 'Dive In' festival,
or informal careers-based events for both employees and prospective
Appointing influential diversity champions,especially those who
come from a background that allows them to speak credibly about the
link between diversity and commercial performance
Encourage people to take responsibility throughout the
organisation,for example through the 'HeforShe' initiative, in
which people make personal commitments to promote diversity.
Use data to see what the real career journey is for different
groups within the organisation- organisations that have done this
have found key assumptions to be wrong. For example, it is often a
myth that women leave the workforce to have families - the real
reason why fewer female than male graduates progress to become
senior managers is much more complex.
Promote awareness of non-western cultures through small
details,for example, in the food that is available in the
organisation's restaurant, or recognising holy days from faiths
beyond traditional Christian days.
Mark Carney: 'Inclusiveness unlocks the true value of an
organisation's diversity; through inclusion people can realise
their full potential.'
Give the Regulator the Good News
It will be important for firms to communicate with the PRA about
the work that they do to promote diversity and inclusion during
The regulator is aware of the bureaucratic burden that has been
imposed by Solvency II, and is keen to focus on positive outcomes
rather than make-work activities. The Bank of England is going
through its own diversity and inclusion programme, so it is aware
of the challenges and pitfalls involved in achieving real
The PRA will be in a far stronger position if it can show that
it is working with a sector that is promoting diversity in an
energetic and innovative way, rather than simply imposing more
rules, and it is willing to listen to what firms are