Regulation & complaints procedure

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 - EEA countries

We aim to provide the highest standards of service and fairness towards our assureds 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 in the future. 

If you have a complaint, or any other comment, concerning the Club please communicate it to your underwriting or claims contact, or direct to the UKNV Compliance Officer in writing via
complaints-EU@thomasmiller.com.

We are regulated by the Authority for the Financial Markets (AFM) as far as concerns eligible complainants.

Klachteninstituut Financiele Dienstverlening

If you are dissatisfied with the response we give, you can refer your complaint to the Klachteninstituut Financiele Dienstverlening (Kifid). You can either file a complaint form online or send a letter to the address below. Please note that a complaint must be written in Dutch. 

Klachteninstituut Financiele Dienstverlening
Postbus 93257
2509 AG Den Haag
The Netherlands
00 31 (0)70 - 3338999
www.kifid.nl

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. Thomas Miller B.V. is the authorised agent for UK P&I Club N.V. in the Netherlands (registered in the Netherlands Chamber of Commerce No:72109106) and authorised and regulated by the Authority for Financial Markets (AFM). UK P&I Club N.V. authorised and regulated by the De Nederlandsche Bank (DNB), firm reference number  R161589. 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.

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.