Legal and security

Privacy Notice

Our latest privacy notice can be found here.

Third-Party Data Privacy Notice

You can see our Third-Party Data Privacy Notice here.

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:

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

 

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.

2024

Vitality Health Limited SFCR for year ending 30 June 2024
Vitality Life Limited SFCR for year ending 30 June 2024
Discovery Group Europe Limited- SFCR for the year ended 30 June 2024

2023

Vitality Health Limited SFCR for the year ended 30 June 2023
Vitality Life Limited SFCR for the year ended 30 June 2023
Discovery Group Europe Limited - SFCR for the year ended 30 June 2023

2022

Vitality Health Limited SFCR for the year ended 30 June 2022
Vitality Life Limited SFCR for the year ended 30 June 2022
Discovery Group Europe Limited SFCR for the year ended 30 June 2022

2021

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

2020

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

2019

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

UK Tax Strategy: Financial Year Ending 30 June 2024

Vitality is proud to present its Tax Strategy for the year ended 30 June 2024. This report provides details on our:

• Approach to tax governance and risk management
• Attitude towards tax planning
• Tolerance towards tax risk
• Tax-related stakeholder engagement

This document has been prepared and published in accordance with paragraph 19(2) and, as applicable, paragraph 22(2), Schedule 19, Finance Act of 2016, 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”). For the purposes of this document both Discovery UK and Vitality UK are collectively referred to as “Vitality”.

It should be read in conjunction with Discovery Limited’s Tax Transparency Report for 30 June 2023 and Discovery Group’s Tax Policy Principles.

FOREWORD

“Discovery believes that businesses, citizens and society are inextricably linked, and that taxation reinforces this social contract. Through the funding of essential public services, infrastructure, public investment and the mechanisms of the state, taxes directly support a society that is better able to achieve Discovery’s core purpose of making people healthier and enhancing and protecting their lives. Our approach to tax governance extends beyond compliance and reflects our broader approach to governance as an enabler of value creation and preservation.

Tax is an environmental, social and governance consideration that supports the Group’s purpose, values and endorsement of the United Nations’ agenda on sustainable development and associated goals. As a responsible corporate citizen, we strengthen our tax approach through ethical behaviour, accountability, leadership, risk management, performance management and transparency. We participate in industry debate to influence fair outcomes from a tax perspective and maintain open interaction with revenue authorities and government tax policy divisions in our markets, sharing our expertise on technical issues as needed.”

* Extracted from Discovery Limited’s Tax Transparency Report for 30 June 2023.

Vitality is committed to complying with the spirit and letter of the tax laws and regulations that underpin Discovery Group’s Tax Principles:

• commitment to compliance
• responsible attitude to arranging tax affairs
• constructive approach to engaging with tax authorities
• tax reporting procedures and provisions
• monitoring, control, and tax risk assessment

We are committed to complying with statutory tax obligations in the UK and the other jurisdictions in which we operate in a responsible manner. This includes:

• Filing accurate, timely tax returns as well as settling any tax obligations in the correct period
• Disclosing relevant facts and circumstances to tax authorities when required
• Claiming tax reliefs and incentives where these are available and appropriate

OUR APPROACH TO TAX GOVERNANCE AND RISK MANAGEMENT

The Vitality Board of Directors, together with the Group Audit Committee and Group Risk Committee, oversees the UK group’s tax practices and affairs, providing appropriate accounting and financial oversight.

Responsibility for compliance with the Group’s Tax Strategy lies with the Board. The Board delegates the day-to-day responsibility for tax risk management of Vitality UK and of Discovery UK to the Chief Financial Officer (CFO) of Vitality UK and the Chief Operations Officer (COO) of Discovery UK respectively, and finance teams of the various business areas, who are supported by the UK Group Tax team. Together, the CFO, COO, and Group Tax team are responsible for monitoring the group’s overall tax compliance, monitoring changes in tax legislation while proactively managing the impacts thereof and ensuring that appropriate financial controls are in place in terms of King IV (the South African corporate governance code). Appropriate accounting and financial oversight are exercised through the Audit Committee, with our Group Internal Audit function carrying out regular reviews.

Our respective tax and finance teams are adequately staffed with appropriate skills to monitor tax compliance and keep abreast of changes in tax legislation. The Group Tax team is an active strategic business partner, understanding the tax implications and ensuring that business strategies are executed in the most tax efficient and responsible manner. The Group Tax team are also supported by external professional tax advisors, who are consulted as appropriate as detailed in our Tax Policy.

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. This includes process and control documentation and regular Internal Financial Control monitoring and reviews by Group Internal Audit.

The UK Head of Group Tax considers the Tax Strategy and Tax Policy on an annual basis and brings updates to the tax policies for review and approval as required.

Vitality’s Tax Policy has been reviewed and approved by the Policy Sub-Committee, Group Risk Committee, and the Board of Directors in April 2024. The policy is attested to by the CFO & COO on an annual basis. The CFO & CCO reviewed and approved the annual refresh to the Tax Strategy for the year ended 30 June 2024 in June 2024, which only contained minor amendments to linked documents, following the Board Approval of the 2023 Tax Strategy in April 2023.

OUR ATTITUDE TOWARDS TAX PLANNING

Commercial activities are structured to maximise value on a sustainable basis for shareholders and all other stakeholders. 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
• Due consideration is given to tax laws of the countries in which Vitality operates and double taxation is eliminated where possible
• So-called tax havens are not used to avoid taxes on business activities that would in the normal course of events take place elsewhere
• Cross border, and domestic, intragroup transactions are undertaken on an arm's length basis in accordance with the Organisation for Economic Co-operation and Development (OECD) transfer pricing principles

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 group, 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 adviser 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.

OUR APPROACH TO DEALINGS WITH HMRC

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

The Group endeavours to build sustainable, transparent relationships with tax authorities.

Should unintended errors arise, these will be corrected as soon as practicable after identification.

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 transparent discussion, should the group strongly believe that their interpretation of the law is correct.

Date of last review: 25 June 2024

Modern Slavery Act 2015 | Statement 2022/2023

Statement by Neville Koopowitz, Vitality Group CEO

 "Vitality seeks to ensure that human trafficking and slavery do not form part of 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 2023.

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 members based in the United Kingdom. Our insurance plans are purchased by private individuals, small to medium enterprises and large corporate customers.

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 2,500 employees across a number of locations in the United Kingdom and our primary offices are in Bournemouth, London and Stockport. The Group turnover is more than £900m and we insure more than 1.7 million customers.

Recruitment

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 that 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 our policies 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:

• Firms that provide IT support and “back office” functions, such as invoice processing and plan administration
• Our parent company – Discovery in South Africa
• 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 and their supply chains. 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 2022 through to June 2023, no instances of Modern Slavery were identified.

Training

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 continuing to review the way we do business with third parties through our corporate sustainability strategy. 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 2023.

• VLL Financial Statements 30 June 2023
• VHL Financial Statements 30 June 2023
• VCSL Financial Statements 30 June 2023 including Wates Reporting
• DHEL Financial Statements 30 June 2023
• Audit Charter