BOARD DIVERSITY POLICY
CONFIDENTIALITY STATEMENT
This document is a best effort to accurately describe the subject policy at the time of publication and will be effective from the date of Board approval.
The material contained herein is confidential and proprietary to Apollo Syndicate Management Limited (Apollo) and may not be reproduced or disclosed to others without the express authorisation of Apollo.
CONTENT
1 Document Information 4
1.1 Purpose 4
1.2 Regulatory Requirements 4
1.3 Audience 4
1.4 Documentation Framework 5
1.5 Document Categorisation, Ownership & Review 5
2 Policy 6
2.1 Introduction 6
2.2 Purpose and Scope of Policy 6
2.3 Definitions 7
2.4 Policy Statements 7
2.4.1 Commitments 7
2.4.2 Approach 8
2.5 Monitoring and Reporting 10
DOCUMENT INFORMATION
1.1 Purpose
This document sets out the Board Diversity Policy which sets out the approach to diversity on the Board of directors (the ‘Board’) for Apollo Syndicate Management Limited (“Apollo”).
1.2 Regulatory Requirements
This Policy Statement has been documented giving consideration to, and in compliance with, the following regulatory requirements.
1.3 Audience
This Policy has been designed for distribution to all within Apollo and on Apollo’s website.
POLICY
2.1 Introduction
Apollo recognises and embraces the benefits of having a diverse and inclusive Board. The Board’s effectiveness and enabling it to govern the business appropriately as well as support continued effective and prudent decision-making leading to a better understanding of the risks faced by Apollo. Central to this is improved policyholder protection, a reduction in conduct risk and a culture centred upon delivering good customer outcomes.
From a regulatory perspective, the PRA currently requires that regulated firms:
• engage a broad set of qualities and competences when recruiting members to the board; and
• put in place a policy promoting diversity on the board.
Firms must also explain on their website how they comply with the above requirements.
Apollo recognises that by understanding and valuing diversity, within a culture of inclusivity that welcomes and encourages input and the sharing of ideas from all perspectives, it can build trusted relationships with clients, colleagues, and communities.
Apollo values diversity and inclusivity as an important asset that enhances its culture, helps to provide a better service to clients, and therefore benefits all stakeholders including staff, capital providers, and shareholders.
2.2 Purpose and Scope of Policy
The Policy applies exclusively to the Board and does not apply to diversity and inclusion in relation to employees of Apollo and its associated entities which is covered in the Employee Handbook and wider HR documentation.
2.3 Definitions
Apollo considers diversity and inclusion to refer to:
• Protected characteristics detailed in the Equality Act 2010 (Gender, Age, Disability, Ethnicity, Religion/Belief, Sexual Orientation)
• Socio-economic background, Nationality, and/or Veteran Status
• Diversity of skill and experience;
• Cognitive diversity (i.e. bringing together a range of different styles of thinking among members of a group. Factors that could lead to cognitive diversity include, but are not limited to: different perspectives, abilities, knowledge, attitudes, and communication styles.
2.4 Policy Statements
To enable it to achieve a truly diverse and inclusive membership, the Board has developed a diversity and inclusion strategy which sets out its objectives and aims and how it intends to meet them. The strategy includes:
- the firm’s core values, the culture that it is trying to create, and its commitment to diversity and inclusion;
- clear objectives and goals for improving diversity and inclusion in the firm, and a plan for meeting these, for example targets and aspirations for gender and ethnicity;
- ways of measuring progress against the objectives and goals;
- and the role of the firm and staff in fostering an open and inclusive environment, including empowering colleagues to speak up and express their views.
2.4.1 Commitments
The Board:
• led by the Chair, will ultimately be responsible for ensuring the diversity of the Board and creating an inclusive environment with the ability to have healthy challenge and debate
• is committed to achieving a truly diverse membership in its composition and in that of its committees
• recognises the value of cognitive, skill and experiential diversity with a range of insights, perspectives, and opinions, and supports the recommendations set out in the Hampton-Alexander Review on gender diversity, and those in the Parker Review on ethnic diversity.
• gives considerable emphasis to diversity in its holistic sense which includes but is not limited to social, educational and industry diversity and has agreed measurable objectives in its composition in respect of gender and ethnicity, in particular:o Board Diversity – The Board aspires to reflect leadership diversity in the Insurance Market which is currently 27% gender diversity at board level, 36% in Leadership and 7% ethnic diversity at board level and 12% in Leadership (source: MP&P 2025). The Board will be proactive in ensuring a broad range of candidates are considered for Board opportunities.
o The Board will document the rationale alongside the record of the recruitment practices resulting in the composition of the Board
• is committed to preventing any conscious or unconscious discrimination or bias by ensuring all members receive ongoing training and support to identify and recognise any bias and challenge such behaviour to support Apollo’s culture of diversity.
• is committed to the development of a diverse pipeline of employees for succession to senior leadership and will oversee the launch of a programme to identify, support, and develop those employees with the potential to become future senior leaders by providing training and personal development opportunities.
• will take part, where applicable, in the organisation-wide Inclusion & Diversity training program that Apollo actively supports.
2.4.2 Approach
The Board’s approach includes:
• undertaking an annual Board Effectiveness Review, led by the Chair, which will be independently performed at least every three years, and will include an assessment of individual and collective competence and suitability and how the Board works together as a unit including specific consideration of the balance of skills, knowledge and experience, and its composition in respect of independence and diversity.
• delegating responsibility to the Remuneration & Nominations Committee to review and assess, at least annually, the composition of the Board, including its diversity and inclusivity, including:
o in reviewing the composition, the consideration of the benefits of all aspects of diversity including, but not limited to the definitions listed in 2.3
o recommending the annual objectives for achieving diversity on the board for adoption by the Board
o ensuring that, in identifying suitable candidates for appointment to the Board:
o ensuring candidates are considered on merit, based on objective criteria, taking account of the specific skills, experience, independence, and knowledge needed to ensure a suitably diverse Board composition.
o only using search firms who are signatories to the Search Firms’ Voluntary Code of Conduct.
o ensuring that adequate succession planning is in place for the Board. In doing so, the Board shall have regard to this policy and the composition and skill requirements of the Board at that time.
o this Policy is reviewed annually by the Remuneration & Nominations Committee
2.5 Monitoring and Reporting
The Remuneration and Nominations Committee will report annually to the Board on the process it has used in relation to Board appointments. Such report will include a summary of the policy approach, measurable objectives set for implementing the Policy and progress made towards achieving those objectives.