TT Club regulation
TT Club is bound by industry and government regulations and operates to the highest standards of integrity at all times.
Through Transport Mutual Insurance Association Limited and TT Club Mutual Insurance Limited trade collectively as the TT Club. TT Club Mutual Insurance Limited is authorised in the UK by the Prudential Regulation Authority and regulated in the UK by the Financial Conduct Authority and Prudential Regulation Authority. In Hong Kong, TT Club Mutual Insurance Limited is authorised and regulated by the Hong Kong Insurance Authority, in Singapore by the Monetary Authority of Singapore and in Australia by the Australian Prudential Regulation Authority. In the United States, TT Club Mutual Insurance Limited is approved as a surplus lines insurer in all states and is accessible through properly licensed surplus lines brokers.
Through Transport Mutual Insurance Association Limited is authorised and regulated in Bermuda by the Bermuda Monetary Authority and is authorised in the UK by the Prudential Regulation Authority and regulated in the UK by the Financial Conduct Authority and Prudential Regulation Authority. It is also approved as a surplus lines insurer in all states and is accessible through properly licensed surplus lines brokers.
Insurance Mediation Directive
The Intermediary Mediation Directive "IMD" was implemented in the UK in 2005. Under the IMD, UK regulated insurance companies may only transact business with those UK intermediaries who are regulated by the PRA/FCA, or those intermediaries in other countries in the European Economic Area (EEA) who are regulated under IMD by their home state. This applies to any risk placed within the European Economic Area.
As a specialist insurer for companies within the international transport and logistics sector we set great store by equity between Members and probity when dealing on their behalf. In support of our commitment to maintaining the highest possible standards of business practice we hold a 'zero-tolerance' stance towards bribery. Bribery is illegal and as such has no place in our organisation.
In accordance with the UK Bribery Act 2010, TT Club prohibits absolutely:
- the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement, regardless of size;
- to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company;
- by any individual employee, agent or other person or body acting on behalf of TT Club;
in order to gain any commercial, contractual or regulatory advantage for TT Club in a way which is illegal or unethical;
- or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.
It is not the intention of the policy, particularly in relation to our international role as an insurer, to prevent normal and appropriate hospitality or the giving and receiving of ceremonial gifts. Such hospitality or gifts must, however, be in moderation and not place any expectation on the recipient to reciprocate either in like or by performing, or failing to perform, any other task in return.
If there is any doubt as to whether an action might constitute bribery the matter should be referred to Angela Gamblin, the Chief Operating Officer at email@example.com.
All management staff working on behalf of the TT Club have a responsibility to prevent, detect and report bribery. We provide appropriate guidance to our staff in fulfilling this duty.
Should you hold any suspicion of bribery or attempted bribery committed by or against an employee, agent or other party acting on behalf of the TT Club, it must be reported immediately to Angela Gamblin, the Chief Operating Officer at firstname.lastname@example.org.
TT Club policy is to protect against the risk of breaching international sanctions and the risk that the Club facilitates a member in the breach of a sanction incurring a loss of reputation, fines, loss of licence(s) or, potentially, imprisonment of Club officers or Directors.
The Club procedures help to ensure that the Club does not enter into business with a person, entity or vessel on the UK, EU, UN & US sanctions blacklists.
The policy makes it clear that any claim where there is a possibility of a breach of sanctions will be carefully scrutinised.
It is the Club's intention to avoid a Member being taken by surprise if the Club refuses reimbursement on sanctions grounds of a claim which the Member has already paid.
No individual or office which is defined as a “US person” under US sanctions regulations will be involved in any claim where there is a possibility of a breach of US sanctions.