Aviva and CSR

What we mean by CSR

Avivas CSR policy may be summed up by the phrase taking care of what is important for our business, for our customers and for our other stakeholders. It is an umbrella policy, which governs our performance in eight related elements. These are relations with our workforce, customers, suppliers and the community, our management of the environment, human rights and health and safety and our adherence to standards of business conduct. It is therefore a policy that regulates how we deal with one another and with the outside world. The CSR policy contains summary statements of fuller policy statements. The exception is in the case of customers, where one detailed statement would not stretch to cover the diversity of the business activities in which we are engaged. However, our newly revised standards of business conduct policy does contain explicit undertakings in respect of customers. The board of Aviva plc approved the CSR policy in January 2002. The policy underpins our adherence to the Aviva Values of integrity, progressiveness, performance and teamwork, in particular that of integrity. This linkage between CSR and the Aviva Values has been formalised in a new set of human resources CSR measures. We describe CSR as our corporate DNA, since it describes how we do things round here. It represents a behavioural roadmap, setting clear expectations by which we judge ourselves and are content for others to judge us. Achieving good practice in CSR is not like reaching a destination, but more like embarking on a journey. The journey will be marked by achievement milestones, but you can never expect to arrive; there is always another corner and another road. This report is therefore the story of the journey over the past year and tells you what ground we have covered.

Aviva Group Recruitment Policy 1. Policy Statement 1. 1.1 The Group's recruitment policy is underpinned by the requirement to meet its legal and regulatory bodyobligations in the countries in which it operates. 1.2 This policy requires the principles of the Group's equal opportunities policy to be met in recruitment and selectionmethodologies. Assessment for roles should be against objective criteria relevant to the role in question. 1.3 This policy applies to both internal and external recruitment. 2. Purpose 1. 2.1 The purpose of this policy is to meet the Group's legal and regulatory obligations on recruitment and selection worldwide. 2.2 The Group also wishes to put in place a consistent framework against which local business units can test their own recruitment and selection policies. 2.3 Those elements of the policy which go beyond meeting legal obligations are intended as a best practice guide to business units. 3. Scope 1. 3.1 The policy will apply across the Group. 3.2 Business units will give effect to this policy through their own recruitment policy, which will be aligned with the requirements set out in this document. 4. Underlying Philosophy 1.

4.1 Aviva recognises its obligations to meet legal and regulatory standards and requires its business units to have in place policies and practices which meet those standards. 4.2 Aviva also believes that an effective, well managed recruitment process will provide it with a number of benefits:

An improving quality of workforce where people are being recruited on the basis of their ability to perform the role in question better than other candidates. Efficient and effective use of its own resource in managing necessary recruitment. A good experience for candidates through the recruitment process, whether successful or not, that will enhance the Group's reputation as an employer and a company with which to do business.

4.3 The Group-wide recruitment framework is set out in this policy and business units are required to implement this framework. However, business units are best positioned to understand and respond to their particular legal, regulatory and cultural environments. Business units' own recruitment policies should therefore give effect to the Group policywhilst also reflecting those local demands. 5. Corporate Objectives 1. 5.1 To ensure the Group has put in place well structured, fair recruitment policies to meet legal and regulatory obligations. 5.2 To provide guidance on best practice to ensure that recruitment processes are helping to provide the business with staff who have the required levels of technical and

behavioural competence. 5.3 To take candidates, whether internal or external, through a well-managed recruitment process that enhances the Group's reputation as an employer and a partner with whom to do business. 6. Corporate Principles and Practices 1. 6.1 All recruitment and selection procedures used in the Group should comply with:

Relevant employment legislation Legal agreements established with publishers of psychometric and ability tests and copyright laws where copyrighted testing materials are being used Regulatory requirements in those businesses subject to approved person regimes or other such regulatory demands (as set out in Section 6.4) The Group's own recruitment and selection policies for Senior Management Groups 1 & 2 (as set out in Section 6.5) The Group's Equal Opportunities Policy

6.2 Before any decision to recruit, other options should be considered, such as the redistribution of work or changes in work systems. The basis on which recruitment is made should also be considered, including alternatives to full time, permanent employment, such as short term or part time contract work, internal secondments and job share opportunities. 6.3 Once a decision to recruit has been taken, the recruitment process should follow the best practice guidelines set out in Sections 6.6 - 6.9. 6.4 Recruitment of Persons covered by Regulatory Regimes a)

Under a number of regulatory regimes the Group is required to show proper process in the recruitment of individuals to "approved person" roles. Recruitment processes should be sufficiently robust to meet the standards required by the regulatory body. Particular attention should be given to ensuring: Role profiles properly reflect regulatory and other control and compliance accountabilities. Internal and external candidates for approved person roles are properly assessed in terms of their fitness and competence for the specific role to which they may be appointed. That where gaps in overall fitness and competence have been identified during assessment and selection, a structured induction and training programme is put in place to close those gaps in reasonable time frames. Responsibility for monitoring the appointee's progress should be clearly assigned. b) The need to complete and maintain records of recruitment and assessment become particularly important when the appointment is to an approved role. Local business units should ensure their record keeping allows them to show compliance with their regulatory regime's requirements in this area. c) In the United Kingdom this policy is supplemented by the FSA Approved Persons policy, which sets out the framework for recruitment and record keeping necessary in respect of Approved Person roles. 6.5 Assessment & Selection for SMG 1& 2 a) The Group Executives take a direct interest in selection for roles sized at Senior Management Group 1 & 2 levels and particular requirements therefore apply at this level. b) When a vacancy arises for a role in SMG 1& 2 an assessment of potential internal candidates should be made, including the consideration of candidates from elsewhere in the Group. Contact should be made with the Group Management Development Director to ensure any

relevant candidates have been identified and are being considered. External recruitment to roles at that level will normally be initiated only when no suitable internal candidate can be identified or where it is believed to be important to consider external candidates against the best internal candidates. c) The selection process should include external assessment through liaison with the Group Management Development Director to ensure the approved methodology at this level (currently involving assessment with Whitehead Mann GKR) is planned and carried out. Normally, a Group executive director or a senior executive delegated with the task will wish to be involved in the recruitment process at this level. 6.6 General Principles a) The key requirements of the role should have been established and written up in the form of a role profile/job description or equivalent before the recruitment process begins. Assessment will be against job related criteria, i.e., the candidates' technical and behavioral competence against role requirements and their ability to deliver required accountabilities. b) The selection process chosen should be appropriate for the role being filled. It should be kept simple whilst ensuring a sound decision can be made on final selection. Selection decisions are the responsibility of line management, with support and guidance from the HR Department. c) Before final confirmation of an offer of employment suitable checks should be carried out (including, where appropriate, references, work permits and medical checks) to the extent permitted by local law. Where candidates state they have academic or professional qualifications original certificates should be required and copies taken. d) Confidentiality should be respected at all times. Personal information on candidates, including any medical information or references, should be held on a need to know basis. All paper or electronically stored dates should comply with data protection requirements

and must be held securely and accessed only by approved individuals. 6.7 Ensuring Competence in Assessment and Selection a) Before the selection process begins all parties involved should have the necessary skills and knowledge to carry out their role to appropriate standards set by the Business Unit. Where necessary, relevant training will be delivered and individuals will be required to demonstrate competence before involvement in selection processes. b) Where copyrighted testing materials are used only accredited test administrators should receive, administer and score those materials. Only individuals with the relevant professional qualifications should interpret test results. Appropriate records should be kept of test administration for monitoring purposes and all copyrighted materials should be stored securely. Results of such tests may only be used for the reasons detailed as part of the original assessment process unless the express permission of the candidate concerned is received for other uses. 6.8 Treatment of Candidates a) Candidates should be treated professionally and courteously and given every opportunity to perform at their best (e.g., by catering for those with special needs). Communication from candidates should be dealt with promptly and feedback to candidates on success or failure should be timely and constructive. b) Candidates should be informed in advance of what the assessment and selection process will involve, the anticipated timetable of the selection process and details on how to claim any expenses incurred. c) Assessment and selection decisions should be recorded in the same format for all candidates. Assessment results should be stored securely for a minimum for 12 months and disposed of appropriately given their sensitivity. Access to assessment results should be on a need to know basis.

6.9 Use of External Agencies There will be occasions when, for effective recruitment, there is a need to involve external agencies in the recruitment process. Such agencies should be required to meet the same legal and best practice standards required of the Group. 7. Responsibilities 1. 7.1 The group-wide framework set out in this policy is the responsibility of the Group HR Director. 7.2 Responsibility for local application of a suitable policy framework and the necessary training and guidance to ensure it is carried out properly rests with each business unit's HR Director or equivalent. The HR Director should ensure the business:

Has policies and practices in place which support and advance best practice in assessment and selection. Carries out its assessment and selection obligations responsibly, in compliance with legal and regulatory requirements, and provides training to ensure those involved in assessment and selection understand their role and are able to demonstrate competence. Has mechanisms in place to monitor and improve the effectiveness of its recruitment policies and takes action to resolve problems.

7.3 It is the responsibility of all staff involved in assessment and selection to ensure they understand their roles and responsibilities as part of that process and carry out those roles appropriately.

Aviva Group Management Development and Training Policy 1. Policy Statement 1. 1.1 We believe our people are a source of competitive advantage. 1.2 The company will invest in its employees' training and development, building their capabilities to meet the business plans and provide internal management succession. 2. Purpose 1. 2.1 The purpose of this policy is to establish a consistent framework for training and development and to recognise where the Group has an interest in and influence on local practice. 3. Scope 1. 3.1 The policy will apply across the Aviva Group. 3.2 Business units will give effect to this policy through their ownmanagement development and training policies and practices aligned to their business needs and incorporating the principles set out below. 4. Underlying Philosophy 1. 4.1 Aviva believes that effective training and development will help the company to attract and retain high quality people, support them in reaching their potential and building the capabilities necessary to succeed in a changing and challenging environment.

4.2 The senior management of Aviva is regarded as a corporate resource. The Group therefore has an interest in and influence on the development of Senior Management Groups (SMGs) 1 and 2, and the more junior talent identified as having the potential to this level. 5. Corporate Objectives 1. 5.1 Management development:

To ensure that we have effective Group-wide development and succession processes and practices in place directed to satisfying the medium and long-term management requirements. To foster a talent management mid-set across the Group not limited to local business unit boundaries.

5.2 Training: To ensure that the skills and capabilities to meet future business needs are anticipated and developed. To facilitate the identification and transfer of best practice in training and development through establishing appropriate Group-wide forums and networks thereby minimising duplication of effort/cost and capturing the benefits of common approaches. 5.3 To develop a reputation as an employer of choice committed to the ongoing training and development of all employees. 5.4 To provide training and development support to equip appropriate managers/employees with the knowledge and skill to fulfil local regulatory compliance requirements. 5.5 To ensure that the processes and practices of training and development are free from discrimination. 6. Corporate Principles and Practices 1.

6.1 Management development:

the senior management of Aviva will be regarded as a corporate resource where Group has an interest in and influence on appointments, succession to and development of SMG 1 and 2 and their successors . the identification and development of talent with the potential to senior management grades across the Group is led and co-ordinated by Group Management Development in collaboration with business Units. the Organisation and Development Review (ODR) is built up annually within business units and Group overall to: anticipate organisational consequences of medium termbusiness plans review the performance and potential of grades SMG 1 and 2 consider succession plans for such roles nominate candidates for Group led succession pools and development programmes The overall outcomes in key areas are subsequently considered by the Executive Committee and the Board. Functional ODRs will focus on talent development and succession management for respective functional staff e.g., finance, actuarial, IT, and HR across the Group as a whole to facilitate the development and retention of key talent. A common senior management performance management process will be adopted across the Group to bring consistency in assessment and input to development and reward processes. Where vacancies arise in SMG 1 and 2, Group Management Development will be informed to ensure that appropriate internal candidates are identified taking account of Group-wide succession and development plans. Candidates, whether internal or external, proposed for

appointment to SMG 1 and 2 roles will undertake an external assessment to complement internal processes. The external assessment will be co-ordinated through Group Management Development. Candidates for development into senior management grades will be nominated by business units for the Group's development programme (Key Group Resources). Participation on the programme will be by agreement between business units and Group Management Development. Group HR will work with business units to develop programmes appropriate to the senior management succession pools and key group resources. Participation on such programmes is a joint decision between Group and business units. Group HR and BUs will jointly monitor the effectiveness of such programmes. Where Group development programmes require secondment, transfer, project work across the Group, business units must use their best endeavours to release and accept managers.

6.2 Training: Training plans overall will be developed from a systematic assessment of business needs, and individual training needs will be derived from assessment of performance against standards and job requirements. Active support and encouragement will be given to the acquisition of appropriate professional qualifications in the form of study and examination time, financing for courses and recognition of success. Particular attention will be paid to identifying training needs associated with regulatory requirements and fulfilling such requirements to the designated standards. Measuring the effectiveness of training will be an ongoing process.

The Group Management Development Director will utilise the Group Management Development Forum to identify best training practice and facilitate its transfer across the Group. The use of technology is actively encouraged in order to maximise access to learning opportunities

7. Responsibilities 1. 7.1 Management development: The development of senior management talent for the Group's business needs must be a shared agenda between Group and business units. Within that commitment, particularly within the HR function, the responsibilities below apply:

the Group-wide framework as set out in this policy is the responsibility of the Group HR Director the provision of the Group wide ODR process and practice is the responsibility of Group Management Development, the effectiveness of its operation is a shared responsibility between Group HR and business units the provision of the Group-wide management development activities, as determined by the Executive, is the responsibility of Group Management Development Business units are responsible for local application of this policy

7.2 Training: Accountability for the application of this policy lies with the business unit head and HR Director or equivalent. From time to time the Group HR Director/Management Development Director will review with local management their business unit practice to ensure the adoption of the above principles and practices.

Aviva Group Equal Opportunities Policy 1. Policy Statement 1. 1.1 The Group is committed to the principle of equal opportunities for everyone in employment. Business units should have in place equal opportunities policies that reflect local legal requirements and group wide good practice. They should ensure training and guidance is available on equal opportunities issues to managers and staff as appropriate. 1.2 Where the Group's own equal opportunities standards go beyond local legal requirements such standards must be applied appropriately as good practice across the Group. Business unit performance will be reviewed against a range of measures of equal opportunity. 2. Purpose 1. 2.1 The purpose of the Group's Equal Opportunities Policy is to ensure that the Group, its business units and subsidiaries are complying with local legal requirements on equal opportunities. 3. Scope 1. 3.1 The policy will apply across the Group. 3.2 Business units will give effect to this policy through their own equal opportunities policies which will be aligned with the principles set out in this policy. 4. Underlying Philosophy 1. 4.1 The Group believes that the recognition of individual ability and merit, the absence of discrimination and the promotion of

positive attitudes towards diversity will result in the most productive deployment of skills, expertise and competence across the Group. 4.2 The Group recognises and accepts its legal obligations to have suitable equal opportunities policies in place. 4.3 Whereas the general framework for the Group's approach to equal opportunities is best set at Group level, business units are best positioned to understand and respond to the particular legal and cultural environments in which they work. business units should therefore set their own equal opportunities policies using this framework but also reflecting their local environment. 5. Corporate Objectives 1. 5.1 To have in place processes and practices which facilitate individual progression and opportunity based on employees' ability and contribution, and which are free from discrimination and meet legal obligations. 5.2 To establish an equal opportunities culture in which employees and potential employees, customers and business associates are treated with dignity and respect. 5.3 To establish guiding principles within which business units should operate to ensure equal opportunities are properly addressed. 6. Corporate Principles and Practices 1.

6.1 The Group will strive to ensure access to employment, training and promotion is:

Free from discrimination on the grounds of sex, sexual orientation, marital status, creed, colour, race, age, ethnic origin, union status or disability. Based solely on the objective assessment of ability and other relevant job related criteria. In the case of training and career development, based on assessed need.

6.2 Evidence of discrimination will be treated seriously and will be dealt with in accordance with local disciplinary and/or grievance procedures. 6.3 Business units must apply Group standards and establish supporting processes to ensure the objectivity of employment related decisions. Those involved in these decision making processes should be trained to ensure decisions are taken based on objective criteria and can be justified. The main areas where such processes should be established are: Recruitment and selection Career planning, promotion and transfer Training and personal development Performance management 6.4 Business unit performance against a range of equal opportunity measures will be incorporated into the business performance review process. 7. Responsibilities 1. 7.1 Business unit heads are responsible for monitoring performance against this policy, identifying any issues preventing compliance and driving actions to resolve those issues in conjunction with managers and staff.

7.2 The group-wide framework set out in this policy is the responsibility of the Group HR Director. 7.3 Responsibility for local application of a suitable policy framework, and training and guidance on equal opportunities issues rests with the business unit's HR Director/manager who should ensure the HR Department:

Develops policies and practices which support and advance an equal opportunities culture. Administers the Equal Opportunities policy effectively and provide training to ensure managers and staff are aware of their responsibilities under the policy.

7.4 It is the responsibility of all employees to adhere to their local equal opportunities policy and behave in a manner which reflects the equal opportunities culture.

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