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Legal and security

VitalityHealth is a trading name of Vitality Health Limited and Vitality Corporate Services Limited. Registered numbers 05051253 and 05933141 respectively. VitalityLife and VitalityInvest are both trading names of Vitality Life Limited and Vitality Corporate Services Limited. Registered numbers 03319079 and 05933141 respectively. 

Vitality Life Limited is the insurer which issues the VitalityLife plan, is the provider and manager of the VitalityInvest ISA and VitalityInvest JISA and the provider and scheme administrator of the VitalityInvest Retirement Plan. Vitality Health Limited is the insurer which underwrites the VitalityHealth plan. Vitality Corporate Services Limited is an authorised intermediary of Vitality Health Ltd and Vitality Life Ltd and arranges and administers the VitalityHealth, VitalityLife and VitalityInvest plans. All companies are registered in England and Wales. Registered office at 3 More London Riverside, London, SE1 2AQ.

VitalityCar is a trading name of Vitality Corporate Services Limited. Registered in England and Wales under company registration number 05933141. Vitality Car Insurance is underwritten by Covea Insurance plc which is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority (FRN: 202277)

Vitality Corporate Services Limited is authorised and regulated by the Financial Conduct Authority (FRN: 461107).

Vitality Health Limited and Vitality Life Limited are authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority (FRNS: 400057 & 675028 respectively). Vitality Health trust administration business is handled by Vitality Corporate Services Limited and this activity is not regulated by the Financial Conduct Authority.

Vitality Healthy Workplace Limited (registered in England and Wales with company number 10840679 and registered office address: 70 Gracechurch Street, London, EC3V XL). Vitality Healthy Workplace Limited is a wholly-owned subsidiary of Vitality Corporate Services Limited.

Calls may be recorded/monitored to help improve customer service. Call charges may vary.

Site security

Vitality take information security very seriously and take all reasonable steps to secure and protect your information. We have an effective encryption system in place to protect any electronic communications to our website. We also have secure firewall software and other measures in place to prevent unauthorised access. Look for a padlock symbol next to the address bar to confirm that you are in a secure area.

All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site or applications, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

When you send information to us by email, please bear in mind that the transmission of information over the internet is not completely secure, unless the information is encrypted. Whilst we take all reasonable steps to protect your personal data on our systems, we cannot guarantee the security of any data you choose to email to us, so, please be aware that sending us your personal data via email is at your own risk. Once we have received your information, we will use strict procedures and security controls to ensure its ongoing confidentiality and protection.

With regards to each of your visits to our site we may automatically collect the following:

  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); plans you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page and any phone number used to call our customer service number.

If you have any concerns in relation to the security of our site or your personal data contained within it, please contact the Subject Access Request team:

Post: DSAR Team, St Christopher House, 217 Wellington Road South, Stockport, SK2 6NG.
The Group Head of Data Protection can be contacted at for any other enquiries.

Telephone calls

Calls may be monitored and recorded for training and compliance purposes.

Call charges may vary.

Unless indicated lines are open Monday to Thursday, 8.30am to 6.00pm and Friday, 8:30am - 5:00pm.

Solvency and Financial Condition Report

Under the Prudential Regulation Authority (PRA) rules and Solvency II regulations, a PRA-authorised insurance undertaking (firm) must disclose publicly, on an annual basis, a Solvency and Financial Condition Report (SFCR). The SFCR contains narrative information in quantitative and qualitative form supplemented, where appropriate, with quantitative templates. A firm’s SFCR must contain the following information:

1. a description of the business and performance of the firm;
2. a description of the system of governance of the firm and an assessment of its adequacy for the risk profile of the firm;
3. a description of the risk exposure, risk concentration, risk mitigation and risk sensitivity separately for each category of risk of the firm;
4. a description, separately for assets, technical provisions and other liabilities, of the bases and methods used for their valuation, together with an explanation of any major differences in the bases and methods used for the valuation of those assets, technical provisions and other liabilities in financial statements of the firm; and
5. a description of the capital management of the firm, including information on own funds, solvency capital requirement and minimum capital requirement.

The Group have prepared two individual SFCRs for Vitality Life Limited and Vitality Health Limited and an EEA Group SFCR for Discovery Group Europe Limited. Historically, the Group produced a solo SFCR for Vitality Health Insurance Limited, however due to the de-authorisation of Vitality Health Insurance Limited as an insurance company in May 2019, an SFCR is no longer required.


Vitality Health Limited SFCR for the year ended 30 June 2021
Vitality Life Limited SFCR for the year ended 30 June 2021
Discovery Group Europe Limited SFCR for the year ended 30 June 2021


Vitality Health Limited SFCR for the year ended 30 June 2020
Vitality Life Limited SFCR for the year ended 30 June 2020
Discovery Group Europe Limited SFCR for the year ended 30 June 2020


Vitality Health Limited SFCR for the year ended 30 June 2019
Vitality Life Limited SFCR for the year ended 30 June 2019
Discovery Group Europe Limited SFCR for the year ended 30 June 2019


Vitality Health Insurance Limited SFCR for the year ended 30 June 2018
Vitality Health Limited SFCR for the year ended 30 June 2018
Vitality Life Limited SFCR for the year ending 30 June 2018
Discovery Group Europe Limited SFCR for the year ended 30 June 2018


Vitality Life Limited SFCR for the year ending 30 June 2017
Vitality Health Insurance Limited SFCR for the year ending 30 June 2017
Vitality Health Limited SFCR for the year ending 30 June 2017
Discovery Group Europe Limited SFCR for the year ending 30 June 2017


Vitality Life Limited SFCR for the year ending 30 June 2016
Vitality Health Insurance Limited SFCR for the year ending 30 June 2016
Vitality Health Limited SFCR for the year ending 30 June 2016
Discovery Group Europe Limited SFCR for the year ending 30 June 2016

UK Tax Strategy: Financial Year Ending 30 June 2022

To satisfy the UK legislative requirements of paragraph 19(2) and, as applicable, paragraph 22(2) of Schedule 19 to the Finance Act of 2016, this strategy is published by and on behalf of Discovery Group Europe Limited and Discovery Finance Company Europe Limited (collectively “Discovery UK”), and all of the relevant group operating entities in the UK under the Vitality banner (collectively “Vitality UK”), which are subsidiaries of Discovery Limited, a South African based company listed on the Johannesburg Stock Exchange (“Discovery”)

1. Our approach to tax risk management and governance arrangements

We are committed to full compliance with all statutory tax obligations. This includes filing accurate, timely tax returns, as well as settling any tax obligations in the correct period.

Due to the complex nature of tax legislation, potential differences in interpretation can create tax risk. We have sufficient processes and internal controls in place to identify, evaluate, mitigate, and manage this risk.

Responsibility for the tax strategy lies with the Board of Directors. Day-to-day responsibility in relation to the tax affairs of Vitality UK and in relation to the tax affairs of Discovery UK, is delegated, respectively, to the CFO of Vitality UK, and to the COO of Discovery UK, supported by the UK Group Tax function. Appropriate accounting and financial oversight are exercised through the Audit Committee, with our Group Internal Audit function carrying out regular reviews.

Discovery has a centralised Group tax function that is based in South Africa, which is supported by tax professionals. This function is responsible for the group's overall tax management policy and risk framework and monitoring the impact of in-country (South African) tax rules and respective tax amendments.

The respective tax and finance teams are therefore adequately staffed with appropriate skills (reflecting the size of the operation) to monitor tax compliance and keep abreast of changes in tax legislation. Each entity is also supported by a separate team of external tax advisors, which also ensure tax controls are followed. In line with the internal tax control framework, these advisors are consulted as appropriate.

2. Our attitude towards tax planning

Commercial activities are structured in a manner to maximise value on a sustainable basis for shareholders. Tax planning is undertaken within this context - economic substance and commercial rationale for transactions undertaken are paramount. All transactions are required to have a business purpose and therefore no artificial arrangements may be implemented.

3. The level of tax risk we are prepared to accept

We have no appetite for non-compliance with tax regulations and our internal controls operate to ensure compliance with tax legislation.

Tax affairs are structured in a manner to optimise the tax position of the entity, while remaining within the confines of the legislation. Where interpretations of the legislation are unclear, complex, or material, external advice is sought. Where the tax advisor is uncertain, if deemed appropriate, an advanced tax ruling is sought.

When making tax decisions we consider the materiality of any item, the financial impacts, as well as any perceived reputational risk.

4. Our approach to dealings with HMRC

Engagements with HMRC are conducted in an honest, courteous and timely manner.

Where considered appropriate, we would be prepared to litigate on matters where we disagree with a ruling or decision of a tax authority, after having sought to first resolve the matter through active and discussion, should the group strongly believe that their interpretation of the law is correct.

Date of last review: 26 April 2022.

Statement by Neville Koopowitz, Vitality Group CEO

"Vitality seeks to eliminate human trafficking and slavery from our supply chains. We strongly oppose any use of slavery or human trafficking in the provision of our services and promote ethical and lawful business practices within our workplace. Vitality will not tolerate or condone any form of policy or practice that constitutes human trafficking or slavery in any part of our organisation. This policy complies with the UK Modern Slavery Act 2015."


This statement is reviewed and updated on our public website annually. This statement covers our business operations during the year ending 30 June 2021.

About Vitality

Our business
Companies in the Vitality Group are involved in the provision and distribution of private medical insurance, life/protection insurance, motor insurance and investment products to customers based in the United Kingdom. Our insurance plans are purchased by private individuals, small to medium enterprises and large corporate customers.

All our life and health insurance plans include our wellness programme that helps our members understand their health along with access to tools that support healthy behaviours and rewards them for making healthier lifestyle choices.

Vitality has a broad range of distribution channels which includes direct to consumer, intermediated and online sales. Where we market our products through intermediaries, they are authorised and regulated by the Financial Conduct Authority.

Our values
1. Great people
We attract great people from diverse backgrounds, with distinctive personal experiences and outlooks. We find the best person for every role, maintaining our exceptional standards with every hire.  

2. Liberating the best in our people
We believe there is greatness in every person, and intervene to bring this out of them. We insist on an inclusive environment, enabling everyone to be themselves. 

3. Intellectual leadership
We’re thought leaders in the markets we operate in. We actively engage in policy debate based on science and facts, inspired by our core purpose. We're committed to continuous learning and self-development. 

4. Force for good
Our goal is to be an exceptional employer, excellent partner and a good corporate citizen. We are also committed to nation building and protecting our planet. 

5. Customer, customer, customer
We are all about our customers and their experiences with us. We empathise as though their problems are our own and recognise the impact of our actions on the people we serve. Every interaction matters, and we articulate this care through intuitive customer journeys. Anecdotes matter. We use every customer touchpoint to nurture lifelong relationships. 

6. Innovation and optimism
We are a profound disruptor. We enter markets where we believe that through our core purpose and shared-value model, we can effect change for good. We do so through products that are brilliant - they deal with complex issues yet, should be simple to understand. 

7. Drive, tenacity and urgency

We think like founders. We despise unnecessary bureaucracy and irrespective of our scale – we seek insurgency. We execute brilliantly, and at rapid pace, marrying our ambitions with short-term, urgent goals.

8. Business astuteness and prudence
We think like owners. We pursue the business case and invest only if there is a clear benefit for the organisation, our customers and society. We embrace necessary governance in substance and form. We pursue exceptional risk management, financial excellence and financial strength. We face challenges constructively and head-on.

9. Integrity, honesty and fairness
We ensure we contrast the complexity of the organisation with simple, old-fashioned values of doing the right thing. We are truthful in our interactions and transparent in all of our dealings. We ensure that every single rule and policy meets the highest ethical standards. We treat everyone fairly, recognising the inherent worth of every human being.

Our company structure

The Vitality Group in the United Kingdom consists of the following companies:

  • Discovery Group Europe Limited
  • Discovery Holdings Europe Limited
  • Vitality Corporate Services Limited
  • Vitality Health Limited
  • Vitality Life Limited
  • Vitality Health Insurance Limited
  • Vitality Invest Trustee Company Limited
  • Vitality Healthy Workplace Limited
  • Better Health Insurance Advice Limited.
These firms are owned by the Discovery Group which is based in South Africa.

We employ around 2000 employees across a number of locations in the United Kingdom and our primary offices are in Bournemouth, London, Croydon and Stockport. The Group turnover is more than £500M and we insure more than 1.5 million customers.


We have in place robust recruitment and screening processes for new employees to ensure that we do not inadvertently employ anyone who might fall within the scope of the Act. Our recruitment processes comply with UK employment and regulatory laws. We ensure that new recruits are eligible to work in the UK and we carry out due diligence and background checks. All employees are provided with an employment contract and we periodically benchmark our salaries and benefits to ensure they remain competitive.

Our supply chains

Vitality suppliers are an important part of our success and our culture.  We expect each business partner to conduct their business with the same commitment to ethical business practices as Vitality. This means suppliers must:

  • Not use slave labour, illegal child labour or forced labour
  • Ensure  the overall terms of employment are voluntary
  • Follow all local employment laws regarding minimum age requirements, wages, overtime benefits and the number of hours worked in a seven-day week
  • From time to time certify that they conform to the expectations above
  • Be able to demonstrate compliance with this policy at the request and satisfaction of Vitality.  
Vitality will maintain internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and human trafficking. Vitality will promptly and thoroughly investigate any claim or indication that a supplier is engaging in human trafficking or slave labour. If any supplier is found in violation of this policy, Vitality will take prompt, remedial action to address the violation.

Vitality will provide ongoing training to relevant employees on the law and Vitality’s approach to human trafficking and slavery.

Given the nature of our business, our board and management teams believe there is an extremely low likelihood of there being any involvement in slavery or human trafficking either within our group or within the supply chains that we use to deliver services to our customers. We have limited exposure to high risk sectors or geographical areas. Our supply chains are limited and include:
  • Offshore firms that provide IT support and “back office” functions, such as invoice processing and plan administration
  • Business partners who support our Vitality programme.
  • Hospital partners who provide clinical services to our customers.
  • Software providers of “Software as a Service” solutions.
  • Professional Services providers – this would cover everything from architects, through to business consultants and legal services.

Our policies on slavery and human trafficking

We have a People Policy and an Equality, Diversity and Inclusion Policy that promote a workplace environment that is respectful, fair, open and inclusive.

We have a Whistleblowing Policy that enables our employees to raise concerns about malpractice in the business.

We also have a Supplier Code of Conduct that outlines the expectations we have in areas such as:

  • Employment Standards (which includes Freedom of Association, Diversity and Equality, Pay and Benefits, Working Hours, Forced or Involuntary Labour and Child Labour)
  • Competition and Anti-trust
  • Health, safety and the environment
  • Bribery and corruption
  • Financial Crime.


Due diligence processes for slavery and human trafficking

As part of our Supplier Risk Management process we will evaluate any potential slavery and human trafficking risk presented by new and existing suppliers. 

We have in place systems to:

  • Identify and assess potential risk areas in our supply chains
  • Include specific contract clauses on modern slavery where required
  • Evaluate the risk of slavery and human trafficking occurring in our supply chains and take remediation action where necessary
  • Monitor potential risk areas in our supply chains
  • Protect whistle blowers. 

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values, we have a supplier monitoring programme that involves periodic reviews of our suppliers. All our key suppliers will be subject to bespoke relationship management arrangements. During the period July 2020 through to June 2021, no instances of Modern Slavery were identified.


To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to staff involved in the procurement of goods and services.

Further steps

We will continue to monitor our supplier base and to further develop our processes and procedures to ensure that we identify and eliminate risks related to slavery and human trafficking. 
We will continue to enhance the training that we provide to relevant staff.

We are implementing our corporate sustainability strategy, which includes reviewing the way we do business with third parties. This involves a deeper exploration into the environmental and social standard our suppliers work within and the governance that oversees them.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 30 June 2021.

Date: 03/02/2022

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