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Corporate Governance

Code of Ethics

The fundamental aim of our code of ethics is to guide management and employees in how to act with integrity and good judgement.

The code is reviewed annually.

Complaint Procedure

Acting honestly, fairly and quickly

It is our intention to provide you with a first class service. However there may be occasions when you feel that this objective has not been achieved. If you are dissatisfied with any aspect of the service that you receive, please write to:  

The Claims Manager CNA/Hardy
20 Fenchurch Street

Or e.mail

Please state the nature of your complaint and quote the claim reference number. Your letter / e.mail will be acknowledged promptly and we will provide a timely and detailed response thereafter.

Alternatively you can complete the complaint form on the website and send to any of the contacts listed above.

If your complaint is in respect of Hardy and you remain dissatisfied with the response you have received from Hardy, you may refer the matter to Lloyds for their independent review of our handling of the case.

Their contact details are as follows
Lloyd’s Market Services
1 Lime Street
London EC3M 7HA
Tel +44(0)20 7327 5693
Fax +44(0)20 7327 5225

Details of Lloyd’s complaints procedures are set out in the leaflet “Your Complaint” – How We Can Help” available at
Ultimately, should you remain dissatisfied with Lloyd’s final response, you may, if eligible, refer your complaint to the Financial Ombudsman Service.

The Financial Ombudsman Service
South Quay Plaza
183 Marsh Wall
London E14 9SR
Telephone: 0845 080 1800

The Financial Ombudsman Service will become involved if you are an eligible complainant as defined by the rules of the Financial Conduct Authority.

If your complaint relates to CNA and the matter is not resolved to your satisfaction, you may request assistance from:

United Kingdom
The Consumer Information Department
The Association of British Insurers
51 Gresham Street,
Telephone 0207 600 3333

Alternatively, you may seek assistance from:

The Financial Ombudsman Service contact details as above

The Financial Ombudsman Service will become involved if you are an eligible complainant as defined by the rules of the Financial Conduct Authority.

If your complaint relates to one of our European offices and you are not satisfied with the response from us you may refer the matter to your local regulator, contact details are listed below


L’Ombudsman Des Assurances
Square De Meesus 35
1000 Brussels
Tel + 32 2 547 59 75
Le Mediateur De L FFSA
The Ombudsman of the FFSA
BP 290
75425 Paris
Ankenævnet for Forsikring,
Anker Heegaards Gade 2,
1572 København V
Telefon: 33 15 89 00 (telefontid kl. 10-13)
Commercial insurances:
Amaliegade 10,
1256 København K
Tlf. 33 43 55 00
hverdage kl. 10-15
Graurheindorfer Street 108
53117 Bonn
Telephone 0228 4108 0

via del Quirinale 21
00187 Roma
Telephone: +39

The Netherlands
PO Box 93257
Den Haag
Telephone: +31 900 355 2248
Fax number: +31 70 333 8999


Relations with Customers & Brokers

We recognise that our reputation and the loyalty of our customers depends on the confidence that both customers and producing brokers have in our professional standards and service levels. As such, we have adopted policies and related procedures on Complaints Handling and Treating Customers Fairly which we expect all employees to follow.

We expect our employees to act in a courteous, fair and honest manner towards anyone they deal with in the course of their day-to-day duties.

We maintain a Policy and Procedures in relation to key and material outsourced arrangements. This provides for an annual review of the operation of such contracts to ensure satisfaction on both sides.

Relations with Regulators & Lloyd's

Hardy will at all times deal with its regulators and the Society of Lloyd's in an open and cooperative manner and will seek to, as a minimum, comply with all applicable regulatory and Lloyd's requirements.

We operate a compliance function that promotes a culture of pro-active compliance throughout the company. This is described in the Company's Compliance Policy & Framework.

Hardy operates in a regulated industry, and is principally regulated by the Prudential Regulation Authority ('PRA') and the Financial Conduct Authority (‘FCA’) in the UK and the Bermuda Monetary Authority in Bermuda, with further risk management standards enforced by Lloyd's as a franchisor. Accordingly, the business practices which we have adopted are reinforced by the principles established by the PRA, FCA and by Lloyd's.

Conflicts of Interest

We have adopted a Policy on Conflicts of Interest, Gifts & Hospitality and as such seek to avoid any conflicts arising in the business. Employees are instructed to seek to avoid personal conflicts and to recognise conflicts which may arise in the context of the insurance process.

Each employee is required to sign an annual Conflicts of Interest statement.

Financial Crime

We are committed to the monitoring and prevention of any financial crime by our employees, producing brokers, clients or any third parties involved in the transactions in which we are involved. As such we have adopted risk based procedures in relation to Anti Money Laundering, Financial Sanctions and Anti Bribery & Corruption. The giving and receiving of bribes is expressly prohibited within this policy and observation of this policy is a condition of employment.

Training is provided to employees on joining and annually thereafter.

Reporting a Breach (Whistleblowing)

Hardy seeks to create a working atmosphere where employees have the opportunity to voice genuine concerns about any unethical behaviour and where they believe any aspect of this code has been breached. Any employee raising a genuine concern in this manner will have their confidentiality maintained and be protected from any retaliation.

Any such concerns should be reported to the Head of Legal, Compliance & Company Secretarial or to the Head of Human Resources.

The Head of Legal, Compliance & Company Secretarial is responsible for investigating any reported breaches of the code and for ensuring that appropriate action is taken if necessary.

This Code is regularly reviewed to ensure it kept current and up-to-date.


Our policy is to deal with suppliers on the basis of agreed terms and to adhere to such terms consistently and fairly and not to withhold payment unreasonably. Arrangements, similar to those outlined above, apply in relation to the acceptance of corporate hospitality or gifts from suppliers.


Hardy is committed to the principle of equal opportunities for all employees and aims to have competitive and fair reward policies in place which motivate the workforce and enhance performance, thereby contributing to the long term success of our business.

We seek to align ourselves with those organisations which adopt high standards of employment practice and will recruit and promote employees irrespective of colour, race, ethnic origin, age, sex, disability, marital status or sexual preference. Hardy will not tolerate any sexual, physical or mental harassment of its employees by management, colleagues or third parties.

Hardy is committed to providing a safe and healthy working environment as part of its wider responsibilities to staff. Employees also have a duty to take proper precautions to safeguard themselves, their colleagues and any visitors to the offices.

We have a comprehensive training and development programme which encourages staff at all levels to develop relevant skills to help them progress in their careers and to reach their potential. Furthermore, as a responsible employer, we seek to provide guidance and support to individuals in relation to their personal health and also to their overall financial well-being, in particular as regards future pension arrangements.

We have a grievance and disciplinary procedure, the aim of which is to treat employees fairly and consistently in cases where an employee fails to meet the standards of performance, attendance or conduct required by Hardy and where appropriate, to give the employee an opportunity to improve. Where possible, we would seek to resolve minor breaches of rules, misconduct, poor performance, poor timekeeping, etc. informally, without recourse to disciplinary action.

As an employer, Hardy has the right to expect undivided loyalty from its employees. Any personal interest, or that of a connected party, which might give rise to the possibility of a conflict must therefore be disclosed. This included directorships and significant shareholdings.

As well as endeavouring to maintain the fullest communication with each member of staff as an individual, Hardy holds monthly staff meetings at which there is an opportunity for communication and consultation on relevant issues.

The Community

Our primary asset is our people. Engendering loyalty and goodwill from the team and more widely from the extended Hardy family is critical to the success of the business. We are an equal opportunities employer and also take our health and safety responsibilities seriously.

We are also committed to providing staff with comprehensive training, both to support the specific needs of the business and to facilitate personal development.

Charity and Community investment

Hardy encourages employees to participate in charitable work and fund raising activities, and supports this by committing time to these activities and by contributing to the funds raised. Many of these activities are organized by the Charity and Social Committee. In addition, Hardy makes ad-hoc charitable donations to worthy causes identified by employees, including where employees themselves engage with a particular charity to undertake a sponsored event.

Supporting Climate Awareness Amongst Our Customers

Claims management is an everyday part of our business. Where practical, our claims team will encourage the repair of damaged property. If this is not possible, we do try and ensure that items are scrapped and recycled as much as possible.

Risk Analysis

Hardy monitors the effects that the environment has on the policies it underwrites through its modelling of natural catastrophe events. This process involves the use of sophisticated software developed by dedicated market specialists. In relevant classes of business, our approach to pricing a risk also incorporates this modelling software, which takes account of the changes in the climate that are leading to adverse weather and environmental conditions. The modelling team attend forums throughout the year to keep abreast of the current issues and to share knowledge with others in the market place which means that the models are built with the most up to date environmental information.

Press Releases: 20/10/14: Hardy builds Property and Engineering capability with the hire of two new Senior Underwriters  |  04/09/14: Hardy Appoints Two New Underwriting Experts to Drive Engineering Business in Asia  |  12/08/14: Tom Motamed Appointed Chairman of CNA Europe Board Of Directors  |  07/08/14: David Brosnan Appointed Chief Executive of CNA Europe  |  07/08/14: John Hennessy Appointed President and COO of CNA Canada  |  02/07/14: Hardy Appoints Anna Maria D'Hulster as Non-Executive Director  |  14/05/14: Hardy appoints new Head of Casualty Underwriting  |  19/02/14: Hardy Appoints David Brosnan Chief Executive  |  19/12/13: Hardy Appoints David Stevens Director to Board and Chief Financial Officer  |  21/10/13: Hardy makes senior appointment to its property treaty business  |