Legal and security
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.
Important legal informationPlease read this information carefully. By accessing this website you confirm that you have understood and agree to be bound by the following terms and conditions. This website and the information provided on it are for the use of permanent residents of the United Kingdom only (for the purposes of this website the United Kingdom excludes the Channel Islands).
JurisdictionThe Vitality Group* controls and operates this website from the United Kingdom and the information delivered via the website is deemed to have been delivered in the United Kingdom. The Vitality Group makes no representation that the material contained in this website is appropriate or available for use outside the United Kingdom and is not soliciting any business from outside the United Kingdom.
This website is not directed to any person in any jurisdiction where (by reason of that person's nationality, residence or otherwise) the publication or availability of this website is prohibited. Persons to whom such restrictions apply must not access this website. If you choose to access this site from outside the United Kingdom you are solely responsible for compliance with local laws.
This website and any transaction effected through it are governed by English law and the English courts shall have exclusive jurisdiction in any legal proceedings.
Terms and conditions of useThe information contained in this website is general in nature and does not constitute a contractual offer. Any medical, health, fitness or other similar information is intended for use solely as an educational aid. The information is intended to supplement where appropriate and in no way substitute the expertise and judgement of your physician, pharmacist or other healthcare professional. You are advised that decisions regarding the diagnosis and treatment of a medical condition, including decisions regarding drug therapy, are complex medical decisions requiring the independent and informed judgement of your appropriate healthcare professional. All specific questions regarding the treatment and care of a medical condition should be posed to your own professional healthcare provider.
To the extent permitted by law, the Vitality Group shall not be responsible for any loss or damage occasioned by the use of the information presented here for any reason and howsoever arising.
The Vitality Group, its suppliers, subcontractors, licensees and sub-licensees are not responsible for any decisions you may make resulting from the use of the information including, but in no way limited to, your choosing to seek, or not to seek, professional medical care or your choosing or not choosing specific treatment. You hereby waive any claim you may have or acquire against the Vitality Group and agree to indemnify and hold the Vitality Group harmless from any claims, lawsuits, proceedings, costs, special, incidental, consequential or indirect damages, including damages for loss of profits, loss of business or downtime of this website arising out of or relating to your use of the information.
The views expressed on this website are not necessarily those of the Vitality Group or its agents, nor are the products advertised herein necessarily endorsed by the Vitality Group or covered as benefits under the Vitality Group policy. Whilst we endeavour to ensure the accuracy of the information, neither the Vitality Group, nor any of its staff or its agents will be held responsible for any omissions or errors, or for any misfortune, injury or damages which may arise therefore. The Vitality Group does not in any manner endorse, assume responsibility for, or recommend the use of any drug or treatment method described on this website. This website contains content provided by third parties of which the Vitality Group is merely a distributor and not publisher. The information available on this website is provided with no warranty, whether express or implied. The Vitality Group makes no representation about the suitability of this information and content for any purpose whatsoever.
Nothing contained on this website or in these terms and conditions shall operate to exclude liability for death or personal injury caused by the negligence of the Vitality Group, its suppliers, subcontractors, licensees and sub-licensees.
As a registered user of this website, you will receive all communications via email. Should you wish not to receive communications via email from the Vitality Group, you may change the way you receive your communication on the website, or you may phone our contact centre.
All elements of this website, including, but not limited to, the general design and the imagery, are protected by trade restrictions, copyright, moral rights, trademark and other laws relating to intellectual property rights. Except if explicitly permitted under this or another agreement with the Vitality Group or one of its subsidiaries, no portion or element of this website or its content may be copied or retransmitted via any means. This website, its content and all related rights shall remain the exclusive property of the Vitality Group or its licensors unless otherwise expressly agreed. Any unauthorised use, alteration or dissemination of information on this website is prohibited. Should a user breach any of these terms then Vitality Corporate Services Limited shall have the right to claim damages which claim shall include the right to claim special, incidental, consequential or indirect damages. The Vitality Group will also be entitled to claim for loss of profits and loss of business and shall be entitled to recover reasonable legal costs.
No warranty is given as to the freedom of this website from errors, defects, viruses, malicious programmes or macros. Links from this website exist for information only and the Vitality Group accepts no responsibility or liability for the availability of, or the information contained on, any such site. The Vitality Group shall have no liability to any person who accesses third party websites via a link from this website and any use of third party websites shall be at the user’s own risk. The existence of a link to another website does not imply or express endorsement of its provider, product or services by the Vitality Group. Links to this website are not permitted without the prior written consent of the Vitality Group.
*The Vitality Group includes Vitality Healthy Workplace Limited, Vitality Health Limited trading as VitalityHealth, Vitality Corporate Services Limited trading as VitalityHealth and/or VitalityLife and/or VitalityInvest and/or Vitality Car and Vitality Life Limited, trading as VitalityLife and VitalityInvest.
Third-Party Data Privacy Notice
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 email@example.com 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:
- a description of the business and performance of the firm;
- a description of the system of governance of the firm and an assessment of its adequacy for the risk profile of the firm;
- a description of the risk exposure, risk concentration, risk mitigation and risk sensitivity separately for each category of risk of the firm;
- 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
- 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 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 2023
Vitality is proud to present its Tax Strategy for the year ended 30 June 2023. 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 2022 and Discovery Group’s Tax Policy Principles.
“Discovery is founded on the premise that businesses, citizens, and society are inextricably linked, and that shared value creation is not only possible, but preferable. We view tax as an environmental, social and governance consideration, – one which is aligned with the Group’s purpose, values and support for the United Nations’ agenda on sustainable development and associated goals.
Taxation represents an acknowledgement of the fact that the Group’s success is derived from the society in which we operate, a moral obligation to improve society, and continuously reinforcing the social contract between citizens, business and government.
Taxes fund essential public services in areas including education, healthcare and the justice system. They fund public infrastructure, public investment and the mechanisms of the state. Therefore, tax directly supports a society which is better able to achieve Discovery’s core purpose: to make people healthier and enhance and protect their lives.” *
* Extracted from Discovery Limited’s Tax Transparency Report for 30 June 2022.
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 previously reviewed and approved by the Policy Sub-Committee, Group Risk Committee, and the Board of Directors in January 2022, with minor changes being reviewed by the CFO and Group Risk this year. The policy is attested to by the CFO & COO on an annual basis. The Board of Directors reviewed and approved the Tax Strategy for the year ended 30 June 2023 on 21 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 the 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.
Modern Slavery Act 2015 | Statement 2021/2022
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 2022.
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.
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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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 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 £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 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 2021 through to June 2022, 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.
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 implement 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 2022.
• VCSL 30 June 2022 Financial Statements including Wates reporting and S172
• VHL 30 June 2022 Financial Statements including S172
• VLL 30 June 2022 Financial Statements including S172
• VHIL 30 June 2022 Financial Statements including S172
• VHWL 30 June 2022 Financial Statements including S172