Environmental, Social and Governance

December 2022

Thomas Miller’s ESG strategy builds on our very successful Corporate Social Responsibility (CSR) initiatives, and in delivering it we will leverage the 5 pillars of our CSR strategy; Our People, Our Company, Our Community, Our Planet and Our Marketplace to provide a solid platform on which to shape our thinking around ESG. 

The ESG strategy will encompass a much broader set of environmental, social and governance criteria than the existing CSR programme and will include, amongst many other factors, our approach to energy and climate efficiencies, workplace diversity and talent management as well as sustainability and risk and compliance.   We will also align our ESG actions with the United Nations Sustainable Development Goals.

As a reminder, our CSR programme ‘Be the Difference’ focusses on encouraging our employees to get involved and working out how they can make a difference.  This has resulted in Thomas Miller employees engaging directly with a number of charitable organisations, as well as becoming active with colleagues in volunteering initiatives such as supporting local community garden projects, contributing their professional experience to encourage greater gender diversity in science and technology as well as helping the homeless and supporting food banks.

We also make a formal commitment to charitable giving through a Corporate Charity partnership, currently Street Child, and with an additional proportion of Group profit directed to other charities supported by our employees through matched funding and directly in areas of need that are closest to us and our operations.

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Thomas Miller

in Numbers

ESG Strategy - Initiatives and Milestones

We have developed an ESG Roadmap to guide the work we will do over the next few years to take our ESG strategy forward at each stage of development.  We will publish a comprehensive ESG report each year to lay out our commitments and achievements.

Our Investment business has embedded ESG considerations into its investment process in line with client requirements and has enhanced its approach to Stewardship supported by the Stewardship Code and UN PRI submissions, both of which are voluntary.

The Thomas Miller leadership teams supporting the mutual businesses we manage are helping their boards to develop their own ESG strategies specific to their operations and industries.  We will continue to work closely with them to ensure that the Thomas Miller ESG strategy is aligned with them, particularly in respect of those ESG criteria over which we retain control.

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Hugh Titcomb, Chief Executive Officer:

Thomas Miller has a long and rich heritage in providing international market-leading insurance services and we pride ourselves on delivering exceptional service to the businesses we own and manage. Although we have a wide range of businesses within our portfolio, our shared purpose of outstanding service is very clear within the Company; this defines who we are and how we conduct ourselves both with our Mutual businesses & other clients and with each other. Our commitment to achieving strong and sustainable growth, supported by our core values of service excellence and integrity, underpin everything that we do. We recognise and embrace the responsibilities and opportunities from having a robust Environmental, Social and Governance strategy and are committed to ensuring the key principles are embedded in our business. 


We will meet all regulatory, legal and financial requirements to report on the environmental impact of our business.  We meet our current reporting obligation in the UK in line with the Streamlined Energy and Carbon Reporting (SECR) policy for private companies.

We plan to report on our baseline Global Carbon Footprint including Scope 1, Scope 2 and business-related Scope 3 emissions in our ESG report in the second quarter of 2023.  As a service business, our own operations are limited to the offices occupied by our employees around the world and our travel in support of the services to our clients.  However, we have launched environmental initiatives across our offices to start to make a difference and reduce our carbon emissions where we can.

Office Emissions and Waste

We use technology where possible to reduce the amount of paper used in our business processes and have rationalised the number of printers available to employees.  There is a programme of light replacement underway to install efficient LED lighting as well as adjusting the temperature at our headquarters in London, to maximise overall energy efficiency throughout relating to temperature. 

Different recycling and waste reduction systems have been integrated throughout our London head office, allowing for improved waste management and promoting environmental responsibility among our employees.

The introduction of agile working across the Group has enabled us to review our office needs and we have been able to reduce our footprint in our London headquarters thereby reducing our overall consumption of energy.


Thomas Miller is in the relationship business and face to face interactions with mutual businesses and clients is an important part of our service proposition.  Our ability to reduce significantly the amount of international travel that is undertaken is therefore relatively limited.  However, we have introduced ESG principles into our travel policies to raise awareness and to challenge our employees to take environmental considerations into account when planning business trips.  This may result in people working remotely for short periods in offices other than their own to facilitate a longer visit or reducing short visits by using technology to connect with well-established clients.


Employee Engagement

In 2022 we conducted an ESG Employee Engagement Survey to begin the formal engagement with employees on our ESG strategy. Thomas Miller employees overwhelmingly supported the Company’s direction of travel on ESG and indicated a strong desire to be more involved in helping to shape it.

We are developing a communications plan to ensure that employees are actively engaged with our ESG activities through focus groups/networks and as ESG Ambassadors.

Learning and Development

Ensuring all employees have access to a range of training and development opportunities is of great importance at Thomas Miller.  This enables our people to reach their full potential and be successful.

Employee Wellbeing

We are a people business, and it is our talented employees who strive to deliver the best possible service to our mutual businesses and clients.  A key element of our employee value proposition is our approach to employee wellbeing, the thread of which runs through all of our operating principles.  We recognise that by investing in our employees we engender the loyalty and commitment that enables them to thrive and for us to develop long and sustainable relationships with our clients, and this is good for all of us.

All employees have access to an independent employee helpline 24/7 to provide them with support on a wide range of work and home related issues.  We also have trained Mental Health First Aiders available to provide confidential support at work when needed.  We also have a range of other health and wellbeing policies to support employees across our different regions.

Diversity, Equity and Inclusion

We follow fair and inclusive processes in recruitment and selection both externally and internally through promotions and internal appointments and we are committed to identifying ways in which we can further improve the diversity of our employees over time.  We have implemented Diversity Data monitoring in the UK and Isle of Man as a pilot and have built this into our new joiner processes.  Diversity, Equity and Inclusion will be a key ESG focus for us and we will engage further with our employees to build out our actions in this area.

We comply with the requirement to publish our UK Gender Pay Gap which has improved in the four years since reporting began.


Thomas Miller is well governed as a company led by a Board of Directors with both Executive and Independent Non-Executive representation who are charged with setting the strategy for the Group.  The Board has both Audit & Risk, and Remuneration & Nominations Committees to oversee the detailed governance of the Group across these areas.  In addition, an Executive Committee, representing the largest of our businesses and functions and with a global focus, is accountable for the delivery of the Thomas Miller Group Business Plan.

Operationally, effective delivery of the Group’s central services is overseen by the Group Operating Committee to ensure efficiencies across the Company where possible.

Thomas Miller has a comprehensive and effective mechanism for reviewing its risks and those of the businesses it owns and manages.  The improvement plans on our risk registers are linked directly to the objectives of those individuals who are accountable for the areas covered to ensure an ongoing drive for managing and mitigating the risks we face.

ESG Governance

An early focus of our ESG strategy was to agree the governance framework through which we would plan and implement actions arising from our ESG project and to then take forward the agreed actions into BAU activities.  Thomas Miller's ESG strategy is driven by our Board of Directors and the planning and implementation is the responsibility of a newly formed ESG Committee under the oversight of the Thomas Miller Executive Committee.  Embedding ESG into our business has been identified as a key objective for the Group.

A further key priority for the Company was to establish a framework through which we are able to identify ahead of time any formal regulatory, financial or legal reporting that we may be required to comply with globally.  We have done this through active horizon scanning.  This is being embedded into our BAU processes so we are ready to meet future obligations and so that decisions can be taken at appropriate points as what reporting we may wish to adopt on a voluntary basis.

Ethical Governance

Thomas Miller takes very seriously its approach to the ethical oversight of its activities.  Employees are encouraged to raise their concerns through the appropriate route including formal policies for raising grievances and for whistleblowing.  There is independent oversight of our whistleblowing procedure by the Chair of our Audit & Risk Committee.

We have a very clear policy on Conduct Risk and all employees are asked to live by the standards outlined.  Thomas Miller’s values and structured Behaviours Framework for setting the standards for our employees provide a high-level definition of our strengths and our beliefs and guide the way in which we are expected to behave.

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Looking Ahead

ESG data collection has been, and will continue to be a key focus, and we recognise that the quality and relevance of the ESG targets we set in the future will be improved by having robust and up to date data.  Initially our focus will be on the priority areas of Carbon Emissions and Diversity.

We plan to publish our baseline Global Carbon Footprint for the full year of 2022 in the second quarter of 2023.  We will continue to encourage our employees in the UK and Isle of Man as part of the Diversity Data monitoring pilot to provide this data to us, as we understand that this will enable us to better track our progress against our Diversity, Equity and Inclusion actions over time.

Further communicating with our stakeholders will form a large part of our activities over the next six months when we will:

  • publish our first comprehensive ESG report which will incorporate specific ESG data
  • agreeing an internal communications plan with targets to engage with employees through focus groups and the launch of a new ESG Ambassador role
  • agreeing an external communications plan to meet the needs of our mutual clubs and other businesses

We will also formalise our ESG data gathering processes in our priority areas to ensure that these are built into individuals’ day to day responsibilities.

In Summary

We have made a strong start on our ESG journey and we continue to make good progress.  We know that our ESG strategy will help us to take explicit actions that will drive a change in the way we approach our business that will positively impact Thomas Miller and the businesses we own and manage.

It fits with our culture and is at the heart of our values.  In very simple terms, we believe it is the right thing to do.