Anti-Bribery Policy

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.

TT Club Policy

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.

Interpreting the Policy

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 London@ttclub.com.

Preventing and reporting Bribery

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 London@ttclub.com.

Complaints Procedure

As a mutual insurer we aim at the highest standards of service - and fairness - towards Members and brokers. If you have a complaint, or any other comment, about the maintenance of these standards by the Club, or by anyone acting on behalf of the Club, we ask that you let us know immediately. This will allow us both to resolve the issue which you raise and to take action to improve our service to other Members and brokers in the future.

We are regulated by the UK Financial Conduct Authority (FCA). We will deal with complaints from eligible complainants according to the requirements of the FCA. These include timescales for acknowledgement and response and an obligation to advise the complainant on further action if he or she remains dissatisfied. The notified person for resolving these complaints is the Chief Executive Officer of the TT Club Managers and complaints may be addressed direct to him at charles.fenton@thomasmiller.com or through your usual Club contact.

We will deal with complaints other than from eligible complainants for the purposes of the FCA as far as practicable as if they were from eligible complainants.

Financial Ombudsman Service

If you are dissatisfied with the final response we send you, you may refer your complaint to the Financial Ombudsman Service. You may also refer your complaint to the Financial Ombudsman Service if we have not sent you a final response within eight weeks. The Financial Ombudsman Service will write to us requesting a summary of the matter, and will liaise directly with us in resolving your complaint. If the Financial Ombudsman Service makes a determination that they will take up your case, the matter will be decided by them following a thorough investigation.

Further details of the Financial Ombudsman Scheme are available from the Financial Ombudsman Service.

Contact details

Financial Ombudsman Service
Financial Ombudsman Scheme
South Quay Plaza
183 Marsh Wall
Canary Wharf
London E14 9SR
Telephone: 0845 080 1800
Website: www.financial-ombudsman.org.uk

Regulation

Through Transport Mutual Insurance Association Limited and TT Club Mutual Insurance Limited, trading 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 Bermuda, Through Transport Mutual Insurance Association Limited is authorised and regulated by the Bermuda Monetary Authority. Through Transport Mutual Insurance Association Limited and TT Club Mutual Insurance Limited are eligible surplus lines insurers in all US jurisdictions. For prospective members in the US, coverage is available through licensed surplus lines brokers.

Listed below are the states where TT Club Mutual Insurance Limited (NAIC number AA-1124127) has been granted surplus lines eligibility, and the date when the licence was granted.

 

 

US StateDate
Alabama1st January 2004
Alaska10th December 2004
Arizona13th April 2004
Arkansas1st January 2004
California20th February 2008
Colorado1st July 2004
Connecticut17th October 2006
Delaware1st January 2004
District of Columbia1st January 2004
Florida29th September 2005
Georgia1st January 2004
Hawaii1st January 2004
Idaho13th October 2004
Illinois1st January 2004
Indiana1st January 2004
Iowa1st January 2004
Kansas1st January 2004
Kentucky1st January 2004
Louisiana13th April 2007
Maine31st January 2005
Maryland1st January 2004
Massachusetts28th January 2011
Michigan15th December 2005
Minnesota17th February 2004
Mississippi26th July 2004
Missouri1st January 2004
Montana30th November 2004
Nebraska1st January 2004
Nevada4th October 2005
New Hampshire21st July 2011
New Jersey7th February 2005
New Mexico1st January 2004
New York6th August 2005
North Carolina16th May 2005
North Dakota1st November 2004
Ohio1st January 2004
Oklahoma16th February 2005
Oregon1st January 2004
Pennsylvania9th December 2004
Puerto Rico28th October 2005
Rhode Island22nd September 2006
South Carolina13th December 2004
South Dakota1st January 2004
Tennessee13th November 2006
Texas1st December 2004
Utah23rd August 2004
Vermont19th July 2006
Virginia22nd November 2004
Virgin Islands23rd September 2004
Washington1st January 2004
West Virginia23rd July 2004
Wisconsin1st January 2004
Wyoming1st January 2004

Through Transport Mutual Insurance Association Limited (NAIC number AA-3191044) has surplus lines eligibility in all US States and jurisdictions in accordance with The Dodd–Frank Wall Street Reform and Consumer Protection Act, effective July 21, 2011.

In Hong Kong, TT Club Mutual Insurance Limited is regulated by the Hong Kong Insurance Authority, in Singapore by the Monetary Authority of Singapore and in Australia by the Australian Prudential Regulation Authority,

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Through Transport Mutual Insurance Association Limited and TT Club Mutual Insurance Limited, trading 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.

The UK VAT Identification number for Through Transport Mutual Insurance Association Limited is: GB 564 5244 35 and for TT Club Mutual Insurance Limited is: GB 564 3375 30.

The Italian VAT Identification number for TT Club Mutual Ltd is: 03627210101.